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United States District Court for the District of Maryland — Case 1:23-cr-00210-RDB, Document 48

Summary

A Defendant's Motion for Extension of Time to Report (Consent) filed July 30, 2025 in United States of America v. David Epstein, Cr. No. RDB-23-210, in the United States District Court for the District of Maryland (Document 48). The motion states that on May 7, 2025, the Court sentenced Mr. Epstein to incarceration of one year and one day, followed by nine months of home confinement, and permitted self-surrender on August 7, 2025. It asks the court to permit Epstein until September 4, 2025 to self-surrender to the facility designated by the Bureau of Prisons, citing agreements that were canceled by the other side. It states that Assistant United States Attorney Paul Riley advises that he consents.

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“United States District Court for the District of Maryland — Case 1:23-cr-00210-RDB, Document 48.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-mdd-538629-48-0-ef555b4f88/, SHA-256 702d3e646d07775d4dd7575aace9e3318fea2775ec32793e27fe43b0192df257.

Full text

    Case 1:23-cr-00210-RDB            Document 48        Filed 07/30/25      Page 1 of 3




                         UNITED STATES DISTRICT COURT
                         FOR THE DISTRICT OF MARYLAND


UNITED STATES OF AMERICA                      *

     V.                                       *                        Cr. No. RDB-23-210
DAVID EPSTEIN                                 *

                Defendant                     *

For: DAVID EPSTEIN                            *

          DEFENDANT’S MOTION FOR EXTENSION OF TIME TO REORT
                              (CONSENT)

    Defendant, David Epstein, though his undersigned counsel, hereby submits this

motion to extend the time for him to report to serve his jail term and as grounds and

states:

    1.    On May 7, 2025, this Court sentenced Mr. Epstein to a period of

          incarceration of one year and one day, followed by nine months of home

          confinement.    ECF 45. At that time, the Court permitted the defendant to

          self-surrender to his sentence on August 7, 2025.    Id.

    2.    Mr. Epstein has been trying diligently to get his financial affairs in order

          since being sentenced in in May. Unfortunately, in the past 10 days, two

          of his significant agreements were canceled by the other side.

    3.    Therefore, he is asking for an additional 4 weeks to work out the financial

          problems before he goes to jail.

    4.    First, he had a deal to sell his employment business, PEI, for a cash

          payment, plus a monthly profit share (expected about $10k a month) based
Case 1:23-cr-00210-RDB           Document 48         Filed 07/30/25       Page 2 of 3




     on the profits from the customer base that PEI was giving to the new

     purchaser. He had worked on this deal for months, even before the

     sentencing. On July 22, 2025, just two weeks before his self-surrender

     date, the buyer told him they were backing out of the deal and would make

     no current or future payments to him or his family.

5.   Secondly, Mr. Epstein had made arrangements with a real estate investor in

     a "subject to purchase" deal in which the buyer would obtain his house

     eventually at a reduced rate, but would pay part of the purchase price now,

     and agree to pay the mortgage payments while Epstein was in jail. Weeks

     ago, the investor sent Epstein a contract for his review. However, on July

     23, 2025, the day after the sale of PEI fell through, the investor

     told Epstein that he would not go forward on the deal.

6.   Obviously, his family's financial ability to survive while he is in jail is

     paramount to him.

7.   A consequence of these unexpected changes to income he expected while

     incarcerated, he can no longer afford to send his daughter to Garrison

     Forrest private school, where she has attended since she was 2 years

     old. He is in the process of scrambling to find somewhere else for her to

     go.

8.   The defendant worked to arrange financial stability for his family in

     anticipation of his jail service and, until recently, those plans appeared to

     bear fruit.   Due to the backing out by both buyers, he is now faced with
    Case 1:23-cr-00210-RDB            Document 48         Filed 07/30/25      Page 3 of 3




           trying alternate routes to find a way for his family to stay in the house and

           survive. An additional four weeks to surrender is requested to give him

           time to make the necessary arrangements.

    9.     Assistant United States Attorney Paul Riley advises that he consents to the

           granting of this motion.

    10. The defendant has complied with all of his conditions of release.       He has

           been designated to the BOP facility in Otisville, New York, as requested by

           this Court.

    WHEREFORE, the the defendant respectfully requests that the Court permit him

until September 4, 2025 to self-surrender to the facility designated by the Bureau of

Prisons.

                                      Respectfully submitted,

                                         _______/s/__________________
                                         Richard Bardos, Of Counsel
                                         Schulman, Hershfield & Gilden, P.A.
                                         1 East Pratt Street, 9th Floor
                                         Baltimore, Maryland 21202
                                         (410) 332 0850

                               CERTIFICATE OF SERVICE

    I HEREBY CERTIFY that on this 30th day of July, 2025, a copy of the foregoing
was served electronically by ECF to: Office of the United States Attorney, 36 South
Charles Street, Fourth Floor, Baltimore, Maryland 21201.

                                 _____/s/______________________
                                 Richard Bardos


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