{
  "document_metadata": {
    "page_number": "4",
    "document_number": "22",
    "date": "July 16, 2019",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 4 of 9\n\nHon. Richard M. Berman\nJuly 16, 2019\nPage 4\n\ndefendants accused of trafficking minors are bailed - notwithstanding the remand presumption.\n\nThird, as apparent from Mr. Epstein's initial financial disclosure, Mr. Epstein's finances are fairly complex. It would be impossible for Mr. 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 5pm deadline. Mr. 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 Mr. 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.\n\nAs counsel said during the July 15 argument, Epstein will agree to any\n\nDOJ-OGR-00000434",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 22 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": "defendants accused of trafficking minors are bailed - notwithstanding the remand presumption.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Third, as apparent from Mr. Epstein's initial financial disclosure, Mr. Epstein's finances are fairly complex. It would be impossible for Mr. 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 5pm deadline. Mr. 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 Mr. 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.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As counsel said during the July 15 argument, Epstein will agree to any",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000434",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Richard M. Berman",
      "Mr. Epstein",
      "Joel Podgor"
    ],
    "organizations": [
      "Baker Tilly Virchow Krause, LLP"
    ],
    "locations": [
      "Manhattan"
    ],
    "dates": [
      "July 16, 2019",
      "July 15"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 22",
      "DOJ-OGR-00000434"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Mr. Epstein, with discussions about bail and financial disclosures. The text is printed and there are no visible stamps or handwritten notes. The document is page 4 of a 9-page document."
}