{
  "document_metadata": {
    "page_number": "1",
    "document_number": "30",
    "date": "07/17/19",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 30 Filed 07/17/19 Page 1 of 1\nU.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nJuly 17, 2019\n\nVIA ECF\nThe Honorable Richard M. Berman\nUnited States District Judge\nSouthern District of New York\nUnited States Courthouse\n500 Pearl Street\nNew York, New York 10007\n\nRe: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)\n\nDear Judge Berman:\n\nThe Government respectfully submits this letter to briefly respond to one aspect of the defendant's July 16, 2019 letter (ECF No. 24), and to provide the Court with additional information regarding the defendant's foreign passport. The defendant's July 16, 2019 letter asserts: \"[A]s for the Austrian passport the government trumpets, it expired 32 years ago. And the government offers nothing to suggest—and certainly no evidence—that Epstein ever used it.\" (ECF No. 24 at 7). In fact, the passport contains numerous ingress and egress stamps, including stamps that reflect use of the passport to enter France, Spain, the United Kingdom, and Saudi Arabia in the 1980s.\n\nThe Government further notes that the defendant's submission does not address how the defendant obtained the foreign passport and, more concerning, the defendant has still not disclosed to the Court whether he is a citizen or legal permanent resident of a country other than the United States.\n\nRespectfully submitted,\n\nGEOFFREY S. BERMAN\nUnited States Attorney\n\nBy: /s Alison Moe\nAlison Moe / Alex Rossmiller / Maurene Comey\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2225 / 2415 / 2324\n\nCc: All counsel of record (Via ECF)\n\nDOJ-OGR-00000470",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 30 Filed 07/17/19 Page 1 of 1",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nJuly 17, 2019",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "VIA ECF\nThe Honorable Richard M. Berman\nUnited States District Judge\nSouthern District of New York\nUnited States Courthouse\n500 Pearl Street\nNew York, New York 10007",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Dear Judge Berman:\n\nThe Government respectfully submits this letter to briefly respond to one aspect of the defendant's July 16, 2019 letter (ECF No. 24), and to provide the Court with additional information regarding the defendant's foreign passport. The defendant's July 16, 2019 letter asserts: \"[A]s for the Austrian passport the government trumpets, it expired 32 years ago. And the government offers nothing to suggest—and certainly no evidence—that Epstein ever used it.\" (ECF No. 24 at 7). In fact, the passport contains numerous ingress and egress stamps, including stamps that reflect use of the passport to enter France, Spain, the United Kingdom, and Saudi Arabia in the 1980s.\n\nThe Government further notes that the defendant's submission does not address how the defendant obtained the foreign passport and, more concerning, the defendant has still not disclosed to the Court whether he is a citizen or legal permanent resident of a country other than the United States.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,\n\nGEOFFREY S. BERMAN\nUnited States Attorney",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "By: /s Alison Moe\nAlison Moe / Alex Rossmiller / Maurene Comey\nAssistant United States Attorneys\nSouthern District of New York\nTel: (212) 637-2225 / 2415 / 2324",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Cc: All counsel of record (Via ECF)",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000470",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Richard M. Berman",
      "Jeffrey Epstein",
      "GEOFFREY S. BERMAN",
      "Alison Moe",
      "Alex Rossmiller",
      "Maurene Comey"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "Southern District of New York"
    ],
    "locations": [
      "New York",
      "France",
      "Spain",
      "United Kingdom",
      "Saudi Arabia",
      "United States"
    ],
    "dates": [
      "July 17, 2019",
      "July 16, 2019",
      "1980s"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 30",
      "19 Cr. 490 (RMB)",
      "ECF No. 24",
      "ECF No. 24 at 7",
      "DOJ-OGR-00000470"
    ]
  },
  "additional_notes": "The document is a letter from the U.S. Department of Justice to the Honorable Richard M. Berman, United States District Judge, regarding the case United States v. Jeffrey Epstein. The letter is dated July 17, 2019, and is signed by GEOFFREY S. BERMAN, United States Attorney. The document appears to be a formal legal document, with no visible damage or redactions."
}