{ "document_metadata": { "page_number": "1", "document_number": "31", "date": "07/18/19", "document_type": "Letter", "has_handwriting": true, "has_stamps": false }, "full_text": "Case 1:19-cr-00490-RMB Document 31 Filed 07/18/19 Page 1 of 1\nLAW OFFICE OF\nMARC FERNICH\nMARC FERNICH maf@fernichlaw.com ALSO ADMITTED IN MASSACHUSETTS 810 SEVENTH AVENUE, SUITE 620 NEW YORK, NEW YORK 10019 212-446-2346 FAX: 212-459-2299 www.fernichlaw.com\nJuly 18, 2019\nBY ECF\nHon. Richard M. Berman USDJ-SDNY Daniel P. Moynihan US Courthouse 500 Pearl St. Courtroom 17B New York, NY 10007-1312\nRe: US v. Jeffrey Epstein, 19 CR 490 (SDNY) (RMB)\nDear Judge Berman:\nJeffrey Epstein replies to yesterday's government letter.\nEpstein was given the passport at issue by a friend. Some Jewish-Americans were informally advised at the time to carry identification bearing a non-Jewish name when traveling internationally in case of hijacking. He never used the document to travel internationally and never presented it to any immigration or customs authority. The passport stamps, predating his receipt of the document, do not reflect Mr. Epstein's entries or exits. His expired US passports, seized by the government and in its possession, would verify his true travel. The defense has asked the government to bring the original document to court for examination and inspection.\nAs Mr. Epstein truthfully reported in his Pretrial Services interview, he is a life-long American citizen. He has no other citizenship or legal permanent residency.\nRespectfully,\nMarc Fernich Martin Weinberg Reid Weingarten\ncc: All counsel\nDOJ-OGR-00000471", "text_blocks": [ { "type": "printed", "content": "Case 1:19-cr-00490-RMB Document 31 Filed 07/18/19 Page 1 of 1", "position": "header" }, { "type": "printed", "content": "LAW OFFICE OF MARC FERNICH", "position": "top" }, { "type": "printed", "content": "MARC FERNICH maf@fernichlaw.com ALSO ADMITTED IN MASSACHUSETTS 810 SEVENTH AVENUE, SUITE 620 NEW YORK, NEW YORK 10019 212-446-2346 FAX: 212-459-2299 www.fernichlaw.com", "position": "top" }, { "type": "printed", "content": "July 18, 2019", "position": "top" }, { "type": "printed", "content": "BY ECF Hon. Richard M. Berman USDJ-SDNY Daniel P. Moynihan US Courthouse 500 Pearl St. Courtroom 17B New York, NY 10007-1312", "position": "middle" }, { "type": "printed", "content": "Re: US v. Jeffrey Epstein, 19 CR 490 (SDNY) (RMB)", "position": "middle" }, { "type": "printed", "content": "Dear Judge Berman: Jeffrey Epstein replies to yesterday's government letter.", "position": "middle" }, { "type": "printed", "content": "Epstein was given the passport at issue by a friend. Some Jewish-Americans were informally advised at the time to carry identification bearing a non-Jewish name when traveling internationally in case of hijacking. He never used the document to travel internationally and never presented it to any immigration or customs authority. The passport stamps, predating his receipt of the document, do not reflect Mr. Epstein's entries or exits. His expired US passports, seized by the government and in its possession, would verify his true travel. The defense has asked the government to bring the original document to court for examination and inspection.", "position": "middle" }, { "type": "printed", "content": "As Mr. Epstein truthfully reported in his Pretrial Services interview, he is a life-long American citizen. He has no other citizenship or legal permanent residency.", "position": "middle" }, { "type": "handwritten", "content": "", "position": "bottom" }, { "type": "printed", "content": "Respectfully, Marc Fernich Martin Weinberg Reid Weingarten", "position": "bottom" }, { "type": "printed", "content": "cc: All counsel", "position": "bottom" }, { "type": "printed", "content": "DOJ-OGR-00000471", "position": "footer" } ], "entities": { "people": [ "Marc Fernich", "Richard M. Berman", "Jeffrey Epstein", "Martin Weinberg", "Reid Weingarten" ], "organizations": [ "LAW OFFICE OF MARC FERNICH", "US Courthouse" ], "locations": [ "New York", "Massachusetts" ], "dates": [ "July 18, 2019" ], "reference_numbers": [ "1:19-cr-00490-RMB", "Document 31", "19 CR 490 (SDNY) (RMB)", "DOJ-OGR-00000471" ] }, "additional_notes": "The document appears to be a letter from Marc Fernich to Judge Richard M. Berman regarding the case US v. Jeffrey Epstein. The letter is typed on the Law Office of Marc Fernich letterhead and includes a handwritten signature. The document is in good condition with no visible damage or redactions." }