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Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page4of9 Hon. Richard M. Berman July 16, 2019 Page 4 defendants accused of trafficking minors are bailed — notwithstanding the remand presumption. 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. As counsel said during the July 15 argument, Epstein will agree to any DOJ-OGR-00000434