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Case 1:19-cr-00490-RMB Document 24 Filed 07/16/19 Page4of9 Hon. Richard M. Berman July 16, 2019 Page 4 courts have determined that there are suitable conditions under which defendants accused of trafficking minors are bailed — notwithstanding the remand presumption. Third, as apparent from Epstein’s initial financial disclosure, his finances are fairly complex. It would be impossible for 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 5 pm deadline. 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 erant bail, include a release condition directing 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 DOJ-OGR-00000448