{
  "document_metadata": {
    "page_number": "1 of 16",
    "document_number": "6",
    "date": "07/11/19",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 1 of 16\n\nReid Weingarten\n1114 Avenue of the Americas\nNew York, NY 10036\n212 506 3900 main\n212 506 3955 direct\nwww.steptoe.com\nrweingarten@steptoe.com\n\nJuly 11, 2019\n\nVIA ECF\nThe Honorable Richard M. Berman\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n(212) 805-6715\n500 Pearl Street\nNew York, NY 10007\n\nRE: United States v. Jeffrey Epstein, Criminal No. 19-490\n\nDear Judge Berman:\n\nWe write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of conditions that will effectively guarantee his appearance and abate any conceivable danger he's claimed to present.\n\nIn essence, the government seeks to remand a self-made New York native and lifelong American resident based on dated allegations for which he was already convicted and punished - conduct the relitigation of which is barred by a prior federal nonprosecution agreement (the \"NPA\"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States - despite a Florida federal judge's stated belief that he could void the NPA in appropriate circumstances, possibly threatening new charges there, and notwithstanding legally erroneous government assertions in ancillary litigation that Mr. Epstein was subject to potential prosecution in other federal judicial districts, including this one specifically. Indeed, Mr. Epstein feared the toxic political climate might tempt the government to try and end-run the NPA - yet continually returned home from travel abroad, fully prepared to vindicate his rights under the agreement and otherwise mount a full-throated defense. Finally, the government takes its extreme position in the teeth of Mr. Epstein's perfect compliance with onerous sex offender registration requirements - pinpointing his exact nightly whereabouts - across multiple jurisdictions over a 10-year period.\n\n1\n\nDOJ-OGR-00000274",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 1 of 16",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Reid Weingarten\n1114 Avenue of the Americas\nNew York, NY 10036\n212 506 3900 main\n212 506 3955 direct\nwww.steptoe.com\nrweingarten@steptoe.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "July 11, 2019",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA ECF\nThe Honorable Richard M. Berman\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n(212) 805-6715\n500 Pearl Street\nNew York, NY 10007",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "RE: United States v. Jeffrey Epstein, Criminal No. 19-490",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Berman:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of conditions that will effectively guarantee his appearance and abate any conceivable danger he's claimed to present.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In essence, the government seeks to remand a self-made New York native and lifelong American resident based on dated allegations for which he was already convicted and punished - conduct the relitigation of which is barred by a prior federal nonprosecution agreement (the \"NPA\"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States - despite a Florida federal judge's stated belief that he could void the NPA in appropriate circumstances, possibly threatening new charges there, and notwithstanding legally erroneous government assertions in ancillary litigation that Mr. Epstein was subject to potential prosecution in other federal judicial districts, including this one specifically. Indeed, Mr. Epstein feared the toxic political climate might tempt the government to try and end-run the NPA - yet continually returned home from travel abroad, fully prepared to vindicate his rights under the agreement and otherwise mount a full-throated defense. Finally, the government takes its extreme position in the teeth of Mr. Epstein's perfect compliance with onerous sex offender registration requirements - pinpointing his exact nightly whereabouts - across multiple jurisdictions over a 10-year period.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000274",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Reid Weingarten",
      "Richard M. Berman",
      "Jeffrey Epstein"
    ],
    "organizations": [
      "Steptoe & Johnson LLP",
      "United States District Court",
      "Southern District of New York",
      "United States Courthouse"
    ],
    "locations": [
      "New York",
      "NY",
      "Florida",
      "United States"
    ],
    "dates": [
      "July 11, 2019",
      "10-year period"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 6",
      "Criminal No. 19-490",
      "DOJ-OGR-00000274"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from Reid Weingarten to Judge Richard M. Berman regarding the case of United States v. Jeffrey Epstein. The letter is typed on Steptoe & Johnson LLP letterhead and includes a date and reference number. The content is a legal argument regarding pretrial release conditions for Jeffrey Epstein."
}