{
  "document_metadata": {
    "page_number": "4",
    "document_number": "24",
    "date": "07/16/2019",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 24 Filed 07/16/19 Page 4 of 9\n\nHon. Richard M. Berman\nJuly 16, 2019\nPage 4\n\ncourts have determined that there are suitable conditions under which defendants accused of trafficking minors are bailed - notwithstanding the remand presumption.\n\nThird, as apparent from Epstein's initial financial disclosure, his finances are fairly complex. It would be impossible for Epstein - given, among other impediments, his detention, inability to quickly access pertinent records, and inability to quickly make a precise valuation of particular assets - to provide a sufficient financial statement by the Court's 5 pm deadline. Epstein certainly recognizes the Court's request for further transparency and is committed to providing a complete and accurate disclosure. Accordingly, we propose that the Court preliminarily accept the initial disclosure proffered last Friday and, if intending to grant bail, include a release condition directing Epstein to tender a comprehensive forensic accounting of his finances as expeditiously as practicable. Joel Podgor, Partner Emeritus at prominent Manhattan accounting firm Baker Tilly Virchow Krause, LLP, has agreed to conduct the forensic investigation and prepare a report rapidly. As counsel said\n\nDOJ-OGR-00000448",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 24 Filed 07/16/19 Page 4 of 9",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Hon. Richard M. Berman\nJuly 16, 2019\nPage 4",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "courts have determined that there are suitable conditions under which defendants accused of trafficking minors are bailed - notwithstanding the remand presumption.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Third, as apparent from Epstein's initial financial disclosure, his finances are fairly complex. It would be impossible for Epstein - given, among other impediments, his detention, inability to quickly access pertinent records, and inability to quickly make a precise valuation of particular assets - to provide a sufficient financial statement by the Court's 5 pm deadline. Epstein certainly recognizes the Court's request for further transparency and is committed to providing a complete and accurate disclosure. Accordingly, we propose that the Court preliminarily accept the initial disclosure proffered last Friday and, if intending to grant bail, include a release condition directing Epstein to tender a comprehensive forensic accounting of his finances as expeditiously as practicable. Joel Podgor, Partner Emeritus at prominent Manhattan accounting firm Baker Tilly Virchow Krause, LLP, has agreed to conduct the forensic investigation and prepare a report rapidly. As counsel said",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000448",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Richard M. Berman",
      "Epstein",
      "Joel Podgor"
    ],
    "organizations": [
      "Baker Tilly Virchow Krause, LLP"
    ],
    "locations": [
      "Manhattan"
    ],
    "dates": [
      "July 16, 2019",
      "07/16/2019"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 24",
      "DOJ-OGR-00000448"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. The text is printed and legible, with no visible handwriting or stamps. The document is page 4 of a 9-page document."
}