EFTA00035394Set 8
2014-11-1313p5,234w
Institution
Supplement
OPI: CMC
NUMBER: NYM 7331.04e
DATE: November 13, 2014
SUBJECT: Pretrial Inmates
I. PURPOSE AND SCOPE: The primary mission of the Metropolitan Correctional Center (MCC),
New York ... confine pretrial inmates for the United States Marshals (USM) Service. Pretrial
inmates are defined as those individuals who are legally detained, but for whom the Bureau of Prisons ... received notification of conviction. Ordinarily, pretrial inmates will be separated, to the
extent possible, from convicted inmates. The purpose of this supplement is to establish the procedures
and operations
https://www.justice.gov/epstein/files/DataSet%208/EFTA00035394.pdf
EFTA00034760Set 8
2014-11-1314p5,234w
Institution
Supplement
OPI: CMC
NUMBER: NYM 7331.04e
DATE: November 13, 2014
SUBJECT: Pretrial Inmates
1. PURPOSE AND SCOPE: The primary mission of the Metropolitan Correctional Center (MCC), New
York ... confine pretrial inmates for the United States Marshals (USM) Service. Pretrial inmates are
defined as those individuals who are legally detained, but for whom the Bureau of Prisons ... received notification of conviction. Ordinarily, pretrial inmates will be separated, to the extent possible,
from convicted inmates. The purpose of this supplement is to establish the procedures and operations
https://www.justice.gov/epstein/files/DataSet%208/EFTA00034760.pdf
EFTA00808816Set 9
2009-12-0738p7,270w
discovery matters were addressed.
On December 22, 2017, Edwards and Epstein filed a Joint Pretrial Stipulation
(Res.App.5, pp.59-303).4 In the Joint Pretrial Stipulation, the parties identified the
issues ... same
circumstances.).
(Res.App.5, p.68). Thus, Edwards recognized in the Joint Pretrial Stipulation that
there was a possibility of prejudice to Edwards or confusion of the jury resulting
4 Epstein ... included the Joint Pretrial Stipulation in his Appendix to the Petition for
Writ of Certiorari; however, he did not include the exhibits to the stipulation.
Edwards has included the Joint
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808816.pdf
EFTA00804571Set 9
125p25,245w
filed that
10 as part of our compliance with this Court's
11 pretrial order, which then we discussed
12 yesterday.
13 THE COURT: Okay. Mr. Scarola may still ... Your Honor's actual
14 ruling was that there were so many,
15 essentially, pretrial motions that required
16 days to get through that would either shorten
17 or lengthen ... that is as it
10 relates to any exhibits provided after the
11 pretrial conference or the conference wherein
12 the parties are to prepare a pretrial
13 stipulation
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804571.pdf
EFTA00793881Set 9
34p23,564w
approach, is
26 the last seven to eight years. 26 laid out in our pretrial stipulation.
27 HR. LINK: Judge, we disagree with 37 And the case law is really ... think it's that simple, I 24 lawyers enter into a pretrial stipulation,
29 really don't. I think we're confusing two 29 Your Honor should follow ... whether it makes sons* or not. And this about the sanctity of the pretrial
4 Court needs to understand, no matter what stipulation.
Mr. Scuola wants, Mr. Rothstein la going
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793881.pdf
EFTA00801275Set 9
90p17,710w
legal significance, if I can approach, is
16 laid out in our pretrial stipulation.
17 And the case law is really clear. When
18 lawyers enter into a pretrial stipulation ... concern -- spoke eloquently and at length
3 about the sanctity of the pretrial
4 stipulation.
5 So before I even read it, and what it
6 says here, you quoted ... read it. I didn't go back and look at the
8 pretrial stipulation itself, among the --
9 just so everybody knows -- among the 1,239
10 docket entries here
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801275.pdf
EFTA00058429Set 9
2019-07-1116p7,359w
Dear Judge Berman:
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 ... Document 6 Filed 07/11/19 Page 2 of 16
Nonetheless, it is fundamental that pretrial detention is reserved for "a small but
identifiable group of particularly dangerous defendants as to whom ... Manhattan residence, with permission to leave only for
medical appointments as approved by Pretrial Services, including (at the Court's
discretion) the installation of surveillance cameras at the front
https://www.justice.gov/epstein/files/DataSet%209/EFTA00058429.pdf
EFTA00074029Set 9
2019-07-0837p11,762w
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 2 of 33
pretrial release. § 3142 states that: "if there is probable cause to believe that the person
committed ... forth in § 3142(e)"). In most federal cases the
rebuttable presumption that applies favors pretrial release, not remand.
There is another very important issue to be considered in this case ... Offender
Registration and Notification Act." Id.
The Defense moved on July 11, 2019, for pretrial release of Mr. Epstein, arguing that
"Mr. Epstein's strict compliance with the various monitoring
https://www.justice.gov/epstein/files/DataSet%209/EFTA00074029.pdf
EFTA00097460Set 9
2019-07-1116p7,359w
Dear Judge Berman:
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 ... Document 6 Filed 07/11/19 Page 2 of 16
Nonetheless, it is fundamental that pretrial detention is reserved for "a small but
identifiable group of particularly dangerous defendants as to whom ... Manhattan residence, with permission to leave only for
medical appointments as approved by Pretrial Services, including (at the Court's
discretion) the installation of surveillance cameras at the front
https://www.justice.gov/epstein/files/DataSet%209/EFTA00097460.pdf
EFTA00039383Set 9
2019-07-0833p10,702w
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 2 of 33
pretrial release. § 3142 states that: "if there is probable cause to believe that the person
committed ... forth in § 3142(e)"). In most federal cases the
rebuttable presumption that applies favors pretrial release, not remand.
There is another very important issue to be considered in this case ... Offender
Registration and Notification Act." Id.
The Defense moved on July 11, 2019, for pretrial release of Mr. Epstein, arguing that
"Mr. Epstein's strict compliance with the various monitoring
https://www.justice.gov/epstein/files/DataSet%209/EFTA00039383.pdf
EFTA00095871Set 9
2019-07-1146p15,250w
Dear Judge Berman:
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 ... Document 6 Filed 07/11/19 Page 2 of 16
Nonetheless, it is fundamental that pretrial detention is reserved for "a small but
identifiable group of particularly dangerous defendants as to whom ... Manhattan residence, with permission to leave only for
medical appointments as approved by Pretrial Services, including (at the Court's
discretion) the installation of surveillance cameras at the front
https://www.justice.gov/epstein/files/DataSet%209/EFTA00095871.pdf
EFTA00081947Set 9
2019-07-0833p10,720w
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 2 of 33
pretrial release. § 3142 states that: "if there is probable cause to believe that the person
committed ... forth in § 3142(e)"). In most federal cases the
rebuttable presumption that applies favors pretrial release, not remand.
There is another very important issue to be considered in this case ... Offender
Registration and Notification Act." Id.
The Defense moved on July 11, 2019, for pretrial release of Mr. Epstein, arguing that
"Mr. Epstein's strict compliance with the various monitoring
https://www.justice.gov/epstein/files/DataSet%209/EFTA00081947.pdf
EFTA00091595Set 9
2021-04-2724p5,120w
Appellee,
AFFIRMATION IN OPPOSITION
TO DEFENDANT'S
RENEWED MOTION FOR
GHISLAINE MAXWELL, PRETRIAL RELEASE
Defendant-Appellant.
x
STATE OF NEW YORK
COUNTY OF NEW YORK : ss.:
SOUTHERN DISTRICT ... submit this affirmation in
opposition to defendant-appellant Ghislaine Maxwell's renewed motion for pretrial
release following this Court's order, dated April 27, 2021, which denied Maxwell's
prior ... motion for bail or temporary pretrial release and affirmed the District Court's
orders denying such relief.
EFTA00091595
PRELIMINARY STATEMENT
2. Indictment 20 Cr. 330 (AJN) was filed on June
https://www.justice.gov/epstein/files/DataSet%209/EFTA00091595.pdf
EFTA00808590Set 9
2017-12-0519p5,443w
they are going
to use this hyper technicality to say the pretrial order was
invalid because the case was not at issue; a new pretrial
order needs to be issued ... intention to relinquish the right.").
Moreover, Epstein has already tried unsuccessfully (twice) to reopen pretrial deadlines to
allow the amendment of his Exhibit List. First, on November ... Court entered its Order
on Motion to Reconfirm Existing Pretrial Deadlines and Re Pretrial Stipulation'', in which this
Court rejected Epstein's request to push the pretrial deadlines given
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808590.pdf
EFTA00728661Set 9
2010-12-035p2,005w
through Friday. December 3, 2010. The
parties shall comply with the attached Uniform Pretrial Procedures.
If the parties resolve this case before calendar call and/or trial, this court directs ... note; si yeas etes mutts ou
sourds, appelez 1-800-955-8771.
EFTA00728662
Uniform Pretrial Procedures
A. Exchange of Exhibit and Witness Lists. On the last business day no later ... stipulate, in writing, to as many facts and issues as possible;
3. prepare a Pretrial Stipulation in accordance with Paragraph E; and
4. list all objections to trial exhibits
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728661.pdf