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.”
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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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