United States District Court for the District of Maryland — Case 1:23-cr-00210-RDB, Document 50

Summary

A Defendant's Final Motion for Extension of Time to Report (Consent) filed August 25, 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 50). 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 October 16, 2025 to self-surrender to the facility designated by the Bureau of Prisons. It states that Assistant United States Attorney Paul Riley consents to the motion but will not consent to any further requests for extensions.

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    Case 1:23-cr-00210-RDB           Document 50       Filed 08/25/25      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 FINAL MOTION FOR EXTENSION OF TIME TO REORT
                          (CONSENT)

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

second, and final, 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.   Subsequently, Mr. Epstein had been trying diligently to get his financial

         affairs in order since being sentenced in in May. As outlined in this prior

         motion, unfortunately, two of his significant agreements were canceled by

         the other side.

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

         problems before he goes to jail. This Court granted his request to self

         surrender on September 4, 2025.     ECF 49.
Case 1:23-cr-00210-RDB             Document 50         Filed 08/25/25   Page 2 of 3




4.   Undersigned counsel has now received a request from Esptein’s wife,

     Danielle Epstein, to seek additional time, until October 16, 2025. She

     assures counsel that this is the final request.

5.   As listed in the defendant’s prior motion, the purchase of PEI staffing, and

     monthly income expected from it, fell through. As a result, the family

     cannot afford to stay in their house. They have located a small apartment

     in Towson and expect to be moving there in the next 30 days. Danielle

     seeks her husband’s availability to assist in the move.

6.   In addition, because of the move, and the decrease in income, their

     daughter will be starting a new school at the end of this month. At the

     same time, Danielle is starting a job full time in Hanover, Maryland.

7.   Danielle states that both parents well be needed for transportation at the

     beginning until a schedule can be worked out and needs her husband

     present during this transition period.

8.   Finally, Danielle is having dental surgery involving a series of necessary

     implants at some point in the next month (it was scheduled for 8/25/25, but

     that turns out to be her first day at the new job). She will be out of

     commission for at least 2 days after surgery and David would need to care

     for her and their daughter.

9.   All of these events are occurring in the next 30 days. She has asked

     counsel to request an extension until October 16.

10. The defendant does not anticipate requesting any further extensions.
    Case 1:23-cr-00210-RDB              Document 50      Filed 08/25/25      Page 3 of 3




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

           granting of this motion but advises that he will not consent to any further

           requests for extensions. .

    12. 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 October 16, 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 25th of August, 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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