MEMY-1805 marker2 court-us-v-epstein-cr (salt 4090): 201/201

marker2/court-us-v-epstein-cr/EFTA02824136/EFTA02824136.md

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+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+(Sex COUNT ONE A in Trafficking Conspiracy '-, ,01- • <sup>l</sup>
+
+x
+
+SEALED INDICTMENT
+
+19 Cr.
+
+19 490
+
+ORIGINAL
+
+.4\ r tiii °NI EL CI "... 'F-vt , r ?p/,, On 4 ',ILI. Ppi, --,i1/41:-
+
+X
+
+The Grand Jury charges:
+
+#### OVERVIEW
+
+1. As set forth herein, over the course of many years, JEFFREY EPSTEIN, the defendant, sexually exploited and abused dozens of minor girls at his homes in Manhattan, New . York, and Palm Beach, Florida, among other locations.
+
+2. In particular, from at least in or about 2002, up to and including at least in or about 2005, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and recruited, minor girls to visit his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residence") to engage in sex acts with him, after which he would give the victims hundreds of dollars in cash. Moreover, and in order to maintain and increase his supply of victims, EPSTEIN also paid certain of his victims to recruit additional girls to be similarly abused by EPSTEIN. In
+
+this way, EPSTEIN created a vast network of underage victims for him to sexually exploit in locations including New York and Palm Beach.
+
+3. The victims described herein were as young as 14 years old at the time they were abused by JEFFREY EPSTEIN, the defendant, and were, for various reasons, often particularly vulnerable to exploitation. EPSTEIN intentionally sought out minors and knew that many of his victims were in fact under the age of 18, including because, in some instances, minor victims expressly told him their age.
+
+4. In creating and maintaining this network of minor victims in multiple states to sexually abuse and exploit, JEFFREY EPSTEIN, the defendant, worked and conspired with others, including employees and associates who facilitated his conduct by, among other things, contacting victims and scheduling their sexual encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence.
+
+### FACTUAL BACKGROUND
+
+5. During all time periods charged in this Indictment, JEFFREY EPSTEIN, the defendant, was a financier with multiple residences in the continental United States, including the New York Residence and the Palm Beach Residence.
+
+6. Beginning in at least 2002, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and
+
+recruited, dozens of minor girls to engage in sex acts with him, after which EPSTEIN paid the victims hundreds of dollars in cash, at the New York Residence and the Palm Beach Residence.
+
+7. In both New York and Florida, JEFFREY EPSTEIN, the defendant, perpetuated this abuse in similar ways. Victims were initially recruited to provide "massages" to EPSTEIN, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts. EPSTEIN paid his victims hundreds of dollars in cash for each encounter. Moreover, EPSTEIN actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. EPSTEIN incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each girl that they brought to EPSTEIN. In so doing, EPSTEIN maintained a steady supply of new victims to exploit.
+
+### The New York Residence
+
+8. At all times relevant to this Indictment, JEFFREY EPSTEIN, the defendant, possessed and controlled a multi-story private residence on the Upper East Side of Manhattan, New York, i.e., the New York Residence. Between at least in or about 2002 and in or about 2005, EPSTEIN abused numerous minor victims at the New York Residence by causing these victims to be recruited to engage in paid sex acts with him.
+
+9. When a victim arrived at the New York Residence, she typically would be escorted to a room with a massage table, where she would perform a massage on JEFFREY EPSTEIN, the defendant. The victims, who were as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress before beginning the "massage." During the encounter, EPSTEIN would escalate the nature and scope of physical contact with his victim to include, among other things, sex acts such as groping and direct and indirect contact with the victim's genitals. EPSTEIN typically would also masturbate during these sexualized encounters, ask victims to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys.
+
+10. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, paid the victim in cash. Victims typically were paid hundreds of dollars in cash for each encounter.
+
+11. JEFFREY EPSTEIN, the defendant, knew that many of his New York victims were underage, including because certain victims told him their age. Further, once these minor victims were recruited, many were abused by EPSTEIN on multiple subsequent occasions at the New York Residence. EPSTEIN sometimes personally contacted victims to schedule appointments at the New York Residence. In other instances, EPSTEIN directed employees and associates, including a New York-based employee ("Employee-1"), to communicate with victims via phone to arrange for these victims to return to the New York Residence for additional sexual encounters with EPSTEIN.
+
+12. Additionally, and to further facilitate his ability to abuse minor girls in New York, JEFFREY EPSTEIN, the defendant, asked and enticed certain of his victims to recruit additional girls to perform "massages" and similarly engage in sex acts with EPSTEIN. When a victim would recruit another girl for EPSTEIN, he paid both the victim-recruiter and the new victim hundreds of dollars in cash. Through these victimrecruiters, EPSTEIN gained access to and was able to abuse dozens of additional minor girls.
+
+13. In particular, certain recruiters brought dozens of additional minor girls to the New York Residence to give massages to and engage in sex acts with JEFFREY EPSTEIN, the defendant. EPSTEIN encouraged victims to recruit additional girls by offering to pay these victim-recruiters for every additional girl they brought to EPSTEIN. When a victimrecruiter accompanied a new minor victim to the New York Residence, both the victim-recruiter and the new minor victim were paid hundreds of dollars by EPSTEIN for each encounter. In addition, certain victim-recruiters routinely scheduled these
+
+encounters through Employee-1, who sometimes asked the recruiters to bring a specific minor girl for EPSTEIN.
+
+### The Palm Beach Residence
+
+14. In addition to recruiting and abusing minor girls in New York, JEFFREY EPSTEIN, the defendant, created a similar network of minor girls to victimize in Palm Beach, Florida, where EPSTEIN owned, possessed and controlled another large residence, i.e., the Palm Beach Residence. EPSTEIN frequently traveled from New York to Palm Beach by private jet, before which an employee or associate would ensure that minor victims were available for encounters upon his arrival in Florida.
+
+15. AL the Palm Beach Residence, JEFFREY EPSTEIN, the defendant, engaged in a similar course of abusive conduct. When a victim initially arrived at the Palm Beach Residence, she would be escorted to a room, sometimes by an employee of EPSTEIN's, including, at times, two assistants ("Employee-2" and "Employee-3") who, as described herein, were also responsible for scheduling sexual encounters with minor victims. Once inside, the victim would provide a nude or semi-nude massage for EPSTEIN, who would himself typically be naked. During these encounters, EPSTEIN would escalate the nature and scope of the physical contact to include sex acts such as groping and direct and indirect contact with the victim's genitals. EPSTEIN would also typically masturbate during these encounters, ask victims
+
+to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys.
+
+16. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, paid the victim in cash. Victims typically were paid hundreds of dollars for each encounter.
+
+17. JEFFREY EPSTEIN, the defendant, knew that certain of his victims were underage, including because certain victims told him their age. In addition, as with New York-based victims, many Florida victims, once recruited, were abused by JEFFREY EPSTEIN, the defendant, on multiple additional occasions.
+
+18. JEFFREY EPSTEIN, the defendant, who during the relevant time period was frequently in New York, would arrange for Employee-2 or other employees to contact victims by phone in advance of EPSTEIN's travel to Florida to ensure appointments were scheduled for when he arrived. In particular, in certain instances, Employee-2 placed phone calls to minor victims in Florida to schedule encounters at the Palm Beach Residence. At the time of certain of those phone calls, EPSTEIN and Employee-2 were in New York, New York. Additionally, certain of the individuals victimized at the Palm Beach Residence were contacted by phone by Employee-3 to schedule these encounters.
+
+19. Moreover, as in New York, to ensure a steady stream of minor victims, JEFFREY EPSTEIN, the defendant, asked and enticed certain victims in Florida to recruit other girls to engage in sex acts. EPSTEIN paid hundreds of dollars to victimrecruiters for each additional girl they brought to the Palm Beach Residence.
+
+#### STATUTORY ALLEGATIONS
+
+20. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York and elsewhere, JEFFREY EPSTEIN, the defendant, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to wit, sex trafficking of minors, in violation of Title 18, United States Code, Section 1591(a) and (b).
+
+21. It was a part and object of the conspiracy that JEFFREY EPSTEIN, the defendant, and others known and unknown, would and did, in and affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, and obtain, by any means a person, and to benefit, financially and by receiving anything of value, from participation in a venture which has engaged in any such act, knowing that the person had not attained the age of 18 years and would be caused to engage in a
+
+commercial sex act, in violation of Title 18, United States Code, Sections 1591(a) and (b)(2).
+
+# Overt Acts
+
+22. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere:
+
+a. In or about 2004, JEFFREY EPSTEIN, the defendant, enticed and recruited multiple minor victims, including minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3, to engage in sex acts with EPSTEIN at his residences in Manhattan, New York, and Palm Beach, Florida, after which he provided them with hundreds of dollars in cash for each encounter.
+
+b. In or about 2002, Minor Victim-1 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the New York Residence over a period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-1 to recruit other girls to engage in paid sex acts, which she did. EPSTEIN asked Minor Victim-1 how old she was, and Minor Victim-1 answered truthfully.
+
+c. In or about 2004, Employee-1, located in the Southern District of New York, and on behalf of EPSTEIN, placed
+
+a telephone call to Minor Victim-1 in order to schedule an appointment for Minor Victim-1 to engage in paid sex acts with EPSTEIN.
+
+d. In or about 2004, Minor Victim-2 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over a period of years and was paid hundreds of dollars after each encounter. EPSTEIN also encouraged and enticed Minor Victim-2 to recruit other girls to engage in paid sex acts, which she did.
+
+e. In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to Minor Victim-2 in order to schedule an appointment for Minor Victim-2 to engage in paid sex acts with EPSTEIN.
+
+f. In or about 2005, Minor Victim-3 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over a period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-3 to recruit other girls to engage in paid sex acts, which she did. EPSTEIN asked Minor Victim-3 how old she was, and Minor Victim-3 answered truthfully.
+
+g. In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to Minor Victim-3 in Florida in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN.
+
+h. In or about 2004, Employee-3 placed a telephone call to Minor Victim-3 in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN.
+
+(Title 18, United States Code, Section 371.)
+
+### COUNT TWO (Sex Trafficking)
+
+The Grand Jury further charges:
+
+23. The allegations contained in paragraphs 1 through 19 and 22 of this Indictment are repeated and realleged as if fully set forth within.
+
+24. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York, JEFFREY EPSTEIN, the defendant, willfully and knowingly, in and affecting interstate and foreign commerce, did recruit, entice, harbor, person, knowing years and would transport, provide, that the person had be caused to engage and obtain by any means a not attained the age of 18 in a commercial sex act, and did aid and abet the same, to wit, EPSTEIN recruited, enticed, harbored, transported, provided, and obtained numerous
+
+individuals•who were less than 18 years old, including but not limited to Minor Victim-1, as described above, and who were then caused to engage in at least one commercial sex act in Manhattan, New York.
+
+> (Title 18, United States Code, Sections 1591(a), (b)(2), and 2.)
+
+# FORFEITURE ALLEGATIONS
+
+25. As a result of committing the offense alleged in Count Two of this Indictment, JEFFREY EPSTEIN, the defendant, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 1594(c)(1), any property, real and personal, that was used or intended to be used to commit or to facilitate the commission of the offense alleged in Count Two, and any property, real or personal, constituting or derived from any proceeds obtained, directly or indirectly, as a result of the offense alleged in Count Two, or any property traceable to such property, and the following specific property:
+
+a. The lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 9 East 71st Street, New York, New York, with block number 1386 and lot number 10, owned by Maple, Inc.
+
+Substitute Asset Provision
+
+26. If any of the above-described forfeitable property, as a result of any act or omission of the defendant:
+
+- (a) cannot be located upon the exercise of due diligence;
+- (b) has been transferred or sold to, or deposited with, a third person;
+- (c) has been placed beyond the jurisdiction of the Court;
+- (d) has been substantially diminished in value; or
+- (e) has been commingled with other property which cannot be subdivided without difficulty;
+
+it is the intent of the United States, pursuant to 21 U.S.C. § 853(p) and 28 U.S.C. § 2461(c), to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property.
+
+(Title 18, United States Code, Section 1594; Title 21, United States Code, Section 853(p); and Title 28, United States Code, Section 2461.)
+
+![]()![]()Form No. USA-33s-274 (Ed. 9-25-58)
+
+---
+
+UNITED STATES DISTRICT COURT  
+SOUTHERN DISTRICT OF NEW YORK
+
+---
+
+UNITED STATES OF AMERICA
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+---
+
+INDICTMENT
+
+(18 U.S.C. §§ 371, 1591(a), (b)(2),  
+and 2)
+
+GEOFFREY S. BERMAN
+
+United States Attorney
+
+![]()Foreperson
+
+---

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marker2/court-us-v-epstein-cr/EFTA02824150/EFTA02824150.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK .17
+
+<1
+
+UNITED STATES OF AMERICA Unsealing Order
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+19 Cr. 490
+
+Upon the application of the United States, by the United States Attorney for the Southern District of New York, Geoffrey S. Berman, by Assistant United States Attorney Alex Rossmiller;
+
+It is found that the Indictment in the above-captioned case is currently sealed and the United States Attorney's Office has applied to have that Indictment unsealed, and it is therefore:
+
+ORDERED that the Indictment in the above-captioned action be unsealed and remain unsealed pending further order of the Court.
+
+Dated: New York, New York July 8, 2019
+
+2NORABef:HENRY PITMAN UNITED STATES MAGISTRATE JUDGE SOUTHERN DISTRICT OF NEW YORK
+
+![](_page_0_Picture_13.jpeg)

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marker2/court-us-v-epstein-cr/EFTA02824151/EFTA02824151.md

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+DOCKET No. 19 CR 490
+
+DEFENDANT Jeffrey Epstein
+
+AUSA Alex Rossmiller
+
+DEF.'S COUNSEL Martin Weinberg
+
+ INTERPRETER NEEDED
+
+ DEFENDANT WAIVES PRETRIAL REPORT
+
+ Rule 5  Rule 9  Rule 5(c)(3)  Detention Hrg.
+
+DATE OF ARREST 7-6-19  VOL. SURR.
+
+TIME OF ARREST 5:20 PM  ON WRIT
+
+ Other: \_\_\_\_\_
+
+TIME OF PRESENTMENT 7-6-19  
+1:25 PM
+
+BAIL DISPOSITION
+
+ DETENTION ON CONSENT W/O PREJUDICE
+
+ DETENTION: RISK OF FLIGHT/DANGER
+
+ DETENTION HEARING SCHEDULED FOR: 7-11-19 @ 2:00 PM
+
+ AGREED CONDITIONS OF RELEASE
+
+ DEF. RELEASED ON OWN RECOGNIZANCE
+
+ \$ \_\_\_\_\_ PRB  \_\_\_\_\_ FRP
+
+ SECURED BY \$ \_\_\_\_\_ CASH/PROPERTY: \_\_\_\_\_
+
+ TRAVEL RESTRICTED TO SDNY/EDNY/
+
+ TEMPORARY ADDITIONAL TRAVEL UPON CONSENT OF AUSA & APPROVAL OF PRETRIAL SERVICES
+
+ SURRENDER TRAVEL DOCUMENTS (& NO NEW APPLICATIONS)
+
+ PRETRIAL SUPERVISION:  REGULAR  STRICT  AS DIRECTED BY PRETRIAL SERVICES
+
+ DRUG TESTING/TREATMT AS DIRECTED BY PTS  MENTAL HEALTH EVAL/TREATMT AS DIRECTED BY PTS
+
+ DEF. TO SUBMIT TO URINALYSIS; IF POSITIVE, ADD CONDITION OF DRUG TESTING/TREATMENT
+
+ HOME INCARCERATION  HOME DETENTION  CURFEW  ELECTRONIC MONITORING  GPS
+
+ DEF. TO PAY ALL OF PART OF COST OF LOCATION MONITORING, AS DETERMINED BY PRETRIAL SERVICES
+
+ DEF. TO CONTINUE OR SEEK EMPLOYMENT [OR]  DEF. TO CONTINUE OR START EDUCATION PROGRAM
+
+ DEF. NOT TO POSSESS FIREARM/DESTRUCTIVE DEVICE/OTHER WEAPON
+
+ DEF. TO BE DETAINED UNTIL ALL CONDITIONS ARE MET
+
+ DEF. TO BE RELEASED ON OWN SIGNATURE, PLUS THE FOLLOWING CONDITIONS:
+
+\_\_\_\_\_; REMAINING CONDITIONS TO BE MET BY: \_\_\_\_\_
+
+**ADDITIONAL CONDITIONS/ADDITIONAL PROCEEDINGS/COMMENTS:**
+
+- DEF'T DESTAINED UNTIL CONTINUATION  
+OF DET'N ITERATIVE 18 U.S.C. § 3141(h)(7) UNTIL
+
+ DEF. ARRAIGNED; PLEADS NOT GUILTY
+
+ CONFERENCE BEFORE D.J. ON 7-8-19
+
+ DEF. WAIVES INDICTMENT
+
+ SPEEDY TRIAL TIME EXCLUDED UNDER 18 U.S.C. § 3161(h)(7) UNTIL \_\_\_\_\_
+
+**For Rule 5(c)(3) Cases:**
+
+ IDENTITY HEARING WAIVED
+
+ DEFENDANT TO BE REMOVED
+
+ PRELIMINARY HEARING IN SDNY WAIVED
+
+ CONTROL DATE FOR REMOVAL: \_\_\_\_\_
+
+PRELIMINARY HEARING DATE: \_\_\_\_\_
+
+ ON DEFENDANT'S CONSENT
+
+DATE: 7/8/19
+
+[Signature]  
+UNITED STATES MAGISTRATE JUDGE, S.D.N.Y.

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marker2/court-us-v-epstein-cr/EFTA02824152/EFTA02824152.md

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+# EXHIBIT 1
+
+AIPA-
+
+tN RE: INVESTIGATION OF JEFFREY EPSTEIN
+
+### NONIROSECIIIIQNAGREEMEn
+
+IT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein");
+
+IT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in violation of Florida Statutes Section 796.07;
+
+IT APPEARING that the United States Attorney's Office and the Federal Bureau of Investigation have conducted their own investigation into Epstein's background and any offense, that may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007, including:
+
+- (1) knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation of Title IS, United States Code, Section 2422(b); all in violation ofTitle 18, United States Code, Section 371;
+- (2) knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. f 2423(9, with minor females, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e);
+- (3) using a facility or moans of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2;
+- (4) traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in I8 U.S.C. § 2423(f), with minor females; in violation
+
+of Title 18, United States Code, Section 2423(b); and
+
+- (5) knowingly, in and affecting interstate and foreign commerce, recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 18, United States Code, Sections 1591(a)(1) and 2; and
+
+IT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that, in exchange for the benefits provided by this agreement, he agrees to comply with its terms, including undertaking certain actions with the State Attorney's Office;
+
+IT APPEARING, after an investigation of the offenses and Epstein's background by both State and Federal law enforcement agencies, and after due consultation with the State Attorney's Office, that the interests of the United States, the State of Florida, and the Defendant will be served by the following procedure;
+
+THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below.
+
+If the United States Attorney should determine, based on reliable evidence, that, during the period of the Agreement, Epstein willfully violated any of the conditions of this Agreement, then the United States Attorney may, within ninety (90) days following the expiration of the term of home confinement discussed below, provide Epstein with timely notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its prosecution on any offense within sixty (60) days' of giving notice of the violation. Any notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the United States learning of facts which may provide a basis for a determination of a breach of the Agreement.
+
+After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed.
+
+#### Terms of the Agreement:
+
+- 1. Epstein shall plead guilty (not nob contendae) to the Indictment 69 currently pending against him in the 15th Judicial Circuit in and for Palm Beach County (Case No. 2006-d-009495=0CW) charging one (1) count of solicitation of prostitution, in violation of Fl. Stat § 796.07. In addition, Epstein shall plead guilty to an Information filed by the State Attorney's Office charging Epstein with an offense that requires him to register as a sex offender, that is, the solicitation of minors to engage in prostitution, in violation of Florida Statutes Section 796.03;
+- 2. Epstein shall make a binding recommendation that the Court impost a thirty (30) month sentence to be divided as follows:
+  - (a) Epstein shall be sentenced to consecutive terms of twelve (12) months and six (6) months in county jail for all charges, without any opportunity for withholding adjudication or sentencing, and without probation or community control in lieu of imprisonment; and
+  - (b) Epstein shall be sentenced to a term of twelve (12) months of community control consecutive to his two terms in county jail as described in Term 2(a), supra.
+- 3. This agreement is contingent upon a Judge of the 15th Judicial Circuit accepting and executing the sentence agreed upon between the State Attorney's Office and Epstein, the details of which are set forth in this agreement.
+- 4. The terms contained in paragraphs I and 2, supra, do not foreclose Epstein and the State Attorney's Office from agreeing to recommend any additional charge(s) or any additional term(s) of probation and/or incarceration.
+- 5. Epstein shall waive all challenges to the Information filed by the State Attorney's Office and shall waive the right to appeal his conviction and sentence, except a sentence that exceeds what is set forth in paragraph (2), supra.
+- 6. Epstein shall provide to the U.S. Attorney's Office copies of all
+
+proposed agreements with the State Attorney's Office prior to entering into those agreements.
+
+1. 7. The United States shall provide Epstein's attorneys with a list of individuals whom it has identified as victims, as defined in 18 U.S.C. § 2255, after Epstein has signed this agreement and been sentenced. Upon the execution of this agreement, the United States, in consultation with and subject to the good faith approval of Epstein's counsel, shall select an attorney representative for these persons, who shall be paid for by Epstein. Epstein's counsel may contact the identified individuals through that representative.
+2. 8. If any of the individuals referred to in paragraph (7), *supra*, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between the identified individual and Epstein, so long as the identified individual elects to proceed exclusively under 18 U.S.C. § 2255, and agrees to waive any other claim for damages, whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United States, Epstein's signature on this agreement, his waivers and failures to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability.
+3. 9. Epstein's signature on this agreement also is not to be construed as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whose name does not appear on the list provided by the United States.
+4. 10. Except as to those individuals who elect to proceed exclusively under 18 U.S.C. § 2255, as set forth in paragraph (8), *supra*, neither Epstein's signature on this agreement, nor its terms, nor any resulting waivers or settlements by Epstein are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person, whether or not her name appears on the list provided by the United States.
+5. 11. Epstein shall use his best efforts to enter his guilty plea and be
+
+sentenced not later than October 26, 2007. The United States has no objection to Epstein self-reporting to begin serving his sentence not later than January 4, 2008.
+
+1. 12. Epstein agrees that he will not be afforded any benefits with respect to gain time, other than the rights, opportunities, and benefits as any other inmate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration.
+2. 13. The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure.
+
+Epstein understands that the United States Attorney has no authority to require the State Attorney's Office to abide by any terms of this agreement. Epstein understands that it is his obligation to undertake discussions with the State Attorney's Office and to use his best efforts to ensure compliance with these procedures, which compliance will be necessary to satisfy the United States' interest. Epstein also understands that it is his obligation to use his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding recommendation regarding the sentence to be imposed, and understands that the failure to do so will be a breach of the agreement.
+
+In consideration of Epstein's agreement to plead guilty and to provide compensation in the manner described above, if Epstein successfully fulfills all of the terms and conditions of this agreement, the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to [REDACTED] Lesley Groff, or [REDACTED] Further, upon execution of this agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury investigation will be suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of this agreement. The defendant likewise agrees to withdraw his pending motion to intervene and to quash certain grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence requested by or directly related to the grand jury subpoenas that have been issued, and including certain computer equipment, involate until all of the terms of this agreement have been satisfied. Upon the successful completion of the terms of this agreement, all outstanding grand jury subpoenas shall be deemed withdrawn.
+
+By signing this agreement, Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses.
+
+By signing this agreement, Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests that the United States Attorney for the Southern District of Florida defer such prosecution. Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution, as provided for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statute of limitations for a period of months equal to the period between the signing of this agreement and the breach of this agreement as to those offenses that were the subject of the grand jury's investigation. Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees and consents that, if a prosecution against him is instituted for any offense that was the subject of the grand jury's investigation, it may be by way of an Information signed and filed by the United States Attorney, and hereby waives his right to be indicted by a grand jury as to any such offense.
+
+///
+
+///
+
+///
+
+By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he tmderstands the conditions of this Non-Prosecution Agreement and agrees to comply with them.
+
+> R. ALEXANDER ACOSTA UNITED STATES ATTORNEY
+
+Dated: By;
+
+Dated: 77a),\_
+
+Dated:
+
+Dated:
+
+VILLAFARA ASSISTANT U.B. ATTORNEY
+
+GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN
+
+LILLY ANN Q. ATTORNEY FOR EPSTEIN
+
+By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non-Prosecution Agreement and agrees to comply with them.
+
+R. ALEXANDER ACOSTA  
+UNITED STATES ATTORNEY
+
+Dated: \_\_\_\_\_
+
+By: \_\_\_\_\_  
+A. [REDACTED] VILLAFAÑA  
+ASSISTANT U.S. ATTORNEY
+
+Dated: \_\_\_\_\_
+
+\_\_\_\_\_  
+JEFFREY EPSTEIN
+
+Dated: 9/24/07
+
+![]()Dated: \_\_\_\_\_
+
+\_\_\_\_\_  
+LILLY ANN [REDACTED], ESQ.  
+ATTORNEY FOR JEFFREY EPSTEIN
+
+By signing this apeeinent, Epstein asserts and certifies that the above has been read and explained to him Epstein hereby states that he understands the conditions of this Non. Prosecution Agreement and agrees to comply with than.
+
+> R. ALEXANDER ACOSTA UNITED STATES ATTORNEY
+
+Dated: By:
+
+Dated:
+
+Dated:
+
+Dated:+.etell--
+
+A. VILLAFARA ASSISTANT U.S. ATTORNEY
+
+JEFFREY EPSTEIN
+
+GERALD LEYCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN
+
+ESQ. ATTORNEY FOR JEFFREY EPSTEIN (N RE:
+
+#### INVESTIGATION OF
+
+JEFFREY EPSTEIN
+
+## ADDENDUM TO TIM NON-PROSECUTION AGREEMENT
+
+APPEARING that the parties seek to clarify certain provisions of page 4. paragraph 7 of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement is modified as fol lows:
+
+7A. The United States has the right to assign to an independem third-party the responsibility for consulting with and, subject to the good faith approval of Epstein's counsel, selecting the attorney representative for the individuals identified undo the Agreement. If the United Stites elects to assign this responsibility to an independent third-party, both the United States and Epstein retain the right to make good faith objections to the attorney representative suggested by the independent third-party prior to the final designation of the attorney representative. 7D. The parties will jointly prepare a short written submission to the Independent third•paay regarding the role of the attorney representative and regarding Epstein's Agreement to pay such enemy representative his or ha regular customer/ hourly rate for representing such victims subject to the provisions of paragraph C, infra. 7C. Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney representative selected by the independent third party. This provision, Wawa; shall not obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, if after consideration of potential settlements, an attorney 6. • v.v...ntative elects to file s contested lawsuit pursuant to IS U.S.C. s 2255 or elects to pursue any other contested remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney representative, as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney representative, shall cease.
+
+By signing this Addendum. Epstein assets sad attires the the above ha been read and explained to him. Epstein honey, sates that he understands die clarifications to the lion-Prosecution Agreement and agrees to comply with down.
+
+> R. ALEXANDER ACOSTA UNITED STATES ATTORNEY
+
+Dad
+
+Dated: /44
+
+Doted:
+
+Dated:
+
+BY
+
+A. IIIEVLU.APANA ASSISTANT U.S. ATTORNEY
+
+GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN
+
+LILLY ANN ESQ. ATTORNEY FOR JEFFREY EPSTEIN
+
+By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the clarifications to the Noe-Prosecution Agreement and agrees to comply with them.
+
+> ft. ALEXANDER ACOSTA UNITED STATES ATTORNEY
+
+Dated: By
+
+A VILLAFARA ASSISTANT U.S. ATTORNEY
+
+Dated:
+
+JEFFREY EPSTEN
+
+Dated:
+
+Dated:
+
+D LEFCOtlRT ESQ. COUNSEL TO JEF EPSTEIN
+
+LILLY ANN ESQ. ATTORNEY FOR JEFFREY EPSTEIN
+
+By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the clarifications to the Non-Prosecution Agreement and agrees to comply with than.
+
+> It. ALEXANDER ACOSTA UNITED STATES ATTORNEY
+
+Dated: By:
+
+Dated:
+
+Dated
+
+Dated: ifrafa .
+
+VILLAFAkt ASSISTANT U.S. ATTORNEY
+
+JEFFREY EPSTEIN
+
+GERALD LEFCOURT, ESQ. COUNSEL. It JEFFREY EPSTEIN
+
+Y ANNSANCHEZ. . ATTORNEY FOR JEFFREY EPSTEIN
+
+Dac-07-07 04:55pm From [REDACTED] -White Burnett
+
+3057899201
+
+T-866 P.003/004 F-976
+
+Affirmation
+
+I, Jeffrey E. Epstein do hereby re-affirm the Non-Prosecution Agreement and Addendum to same dated October 30, 2007,
+
+![]()![]()

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marker2/court-us-v-epstein-cr/EFTA02824167/EFTA02824167.md

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+# EXHIBIT 2
+
+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO. 08-80736-CIV-MARRA
+
+JANE DOE #1 AND JANE DOE #2,
+
+Petitioners,
+
+vs.
+
+UNITED STATES,
+
+Respondent.
+
+### UNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION
+
+The United States hereby requests that this Court enter an order dismissing these proceedings and the Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771 (DE I, the "Petition"), through which Petitioners Jane Doe #1 and Jane Doe #2 have advanced claims pursuant to the Crime Victims' Rights Act ("CVRA"), for lack of subject matter jurisdiction.' This Court lacks subject matter jurisdiction over the Petition because
+
+See, e.g., Grupo Dataflux v. Atlas Global Group, L.P., 541 U.S. 567, 571 (2004) ("Challenges to subject-matter jurisdiction can of course be raised at any time prior to final judgment."); United States v. Giraldo-Prado, 150 F.3d 1328, 1329 (11th Cir. 1998) (recognizing that "a party may raise jurisdiction at any time during the pendency of the proceedings"); Harrell & Sumner Contracting Co. v. Peabody Petersen Co., 546 F.2d 1227, 1229 (5th Cir. 1977) ("[U]nder Rule I 2(hX3), Fed.R.Civ.P., the defense of lack of subject matter jurisdiction may be raised at any time by motion of a party or otherwise."); see also Fed. R. Civ. P. 12(hX3). In the present motion, the United States seeks dismissal of Petitioners' claims based on both a legal and factual challenge to the Court's subject matter jurisdiction. This Court may properly consider and weigh evidence beyond Petitioners' allegations when evaluating such a challenge to the Court's subject matter jurisdiction:
+
+Factual attacks [on a Court's subject matter jurisdiction] ... "challenge subject matter jurisdiction in fact, irrespective of the pleadings." In resolving a factual attack, the district court "may consider extrinsic evidence such as testimony and affidavits." Since such a motion implicates the fundamental question of a trial
+
+Petitioners lack Article III standing and because the claims raised by Petitioners in these proceedings are not constitutionally ripe.
+
+## 1. The Claims Raised in the Petition Must Be Dismissed for Lack of Subject Matter Jurisdiction Because the Petitioners Lack Standing to Bring Those Claims.
+
+These proceedings pursuant to the CVRA must be dismissed for lack of subject matter jurisdiction because Petitioners lack standing to pursue the remedies that they are seeking for alleged CVRA violations. As the Supreme Court has explained,
+
+to satisfy Article III's standing requirements, a plaintiff must show (1) it has suffered an "injury in fact" that is (a) concrete and particularized and (b) actual or imminent, not conjectural or hypothetical; (2) the injury is fairly traceable to the challenged action of the defendant; and (3) it is likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision.
+
+Friends of the Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167, 180-81 (2000); see also, e.g., Young Apartments, Inc. v. Town of Jupiter, 529 F.3d 1027, 1038 (11th Cir. 2008) (quoting Harris v. M, 20 F.3d 1118, 1121 (11th Cir. 1994) (en banc)). Moreover, "a plaintiff must demonstrate standing separately for each form of relief sought." Friends of the Earth, 528 U.S. at 185.
+
+Here, the record incontrovertibly demonstrates that Petitioners cannot satisfy the third prong of the standing test, and the Petition and these proceedings must accordingly be dismissed for lack of subject matter jurisdiction.2 E.g., Florida Wildlife Federation, Inc. v. South Florida
+
+court's jurisdiction, a "trial court is free to weigh the evidence and satisfy itself as to the existence of its power to hear the case" without presuming the truthfulness of the plaintiff's allegations.
+
+Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 2008) (citations omitted); see also, e.g., McMaster v. United States, 177 F.3d 936, 940 (11th Cir. 1999) ("[W]e determine whether this lawsuit survives the government's factual attack [on subject matter jurisdiction] by looking to matters outside the pleadings, and we do not accord any presumptive truthfulness to the allegations in the complaint."); Scarfo v. Ginsberg, 175 F.3d 957, 960-61 (11th Cir. 1999).
+
+<sup>2</sup> Although Petitioners also fail to satisfy the first and second prongs of the standing test,
+
+Water Management Din, 647 F.3d 1296, 1302 (11th Cir. 2011) ("If at any point in the litigation the plaintiff ceases to meet all three requirements for constitutional standing, the case no longer presents a live case or controversy, and the federal court must dismiss the case for lack of subject matter jurisdiction."); Phoenix of Broward, Inc. v. McDonald's Corp., 489 F.3d 1156, 1161 (11th Cir. 2007) ("[T]he issue of constitutional standing is jurisdictional ...."); National Conservation Ass 'n v. Norton, 324 F.3d 1229, 1242 (11th Cir. 2003) ("[B]ecause the constitutional standing doctrine stems directly from Article III's 'case or controversy' requirement, this issue implicates our subject matter jurisdiction, and accordingly must be addressed as a threshold matter regardless of whether it is raised by the parties.") (citation omitted).
+
+In these proceedings, the only identified legal relief that Petitioners have sought pursuant to the CVRA is the setting aside of the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL"). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners seek "is to invalidate the non-prosecution agreement"). But even assuming arguendo that Petitioners' rights under the CVRA were violated when Epstein and the USAO-SDFL entered into the Non-Prosecution Agreement, constitutional due process guarantees do not allow either the Non-Prosecution Agreement — which by its terms induced Epstein to, inter alia, plead guilty to state criminal charges and serve an 18-month sentence of state incarcerations — or the governmental
+
+this Court need not reach or address those issues because an analysis of the third prong of the standing test incontrovertibly establishes the Petitioners' lack of standing. Nonetheless, the circumstances which demonstrate Petitioners' lack of a concrete injury traceable to government conduct are explored infra in Section II of this memorandum, which addresses how Petitioners' claims and these proceedings lack constitutional ripeness.
+
+<sup>3</sup> See also July 11, 2008 Hr'g Tr. at 20-21 (Petitioners' acknowledgement that Epstein's reliance on promises in Non-Prosecution Agreement led to his guilty plea to state charges and his
+
+obligations undertaken therein to be set aside .° See, e.g., Santobello v. New York, 404 U.S. 257, 262 (1971) ("[W]hen a plea rests in any significant degree on a promise or agreement of the prosecutor, so that it can be said to be part of the inducement or consideration, such promise must be fulfilled."); United States v. Harvey, 869 F.2d 1439, 1443 (11th Cir. 1989) ("Due process requires the government to adhere to the terms of any plea bargain or immunity agreement it makes."). Indeed, even if this Court were somehow to set aside the Non-Prosecution Agreement on the authority of the CVRA, and even if after consultation with Petitioners the United States determined that it would be proper and desirable to institute a criminal prosecution in the Southern District of Florida against Epstein on the criminal charges contemplated in the Non-Prosecution Agreement, the United States would still be constitutionally required to adhere to the negotiated terms of the Non-Prosecution Agreement. See, e.g., Santobello, 404 U.S. at 262; Harvey, 869 F.2d at 1443.
+
+Due process considerations further bar this Court from setting aside a non-prosecution agreement that grants contractual rights to a contracting party (Epstein) who has not been made a party to the proceedings before the Court. See, e.g., School Dist. of City of Pontiac v. Secretary of U.S. Dept of Educ., 584 F.3d 253, 303 (6th Cir. 2009) ("It is hornbook law that all parties to a contract are necessary in an action challenging its validity ...."); Dawavendewa v. Salt River Project Agr. Imp. & Power Dist, 276 F.3d 1150, 1157 (9th Cir. 2002) ("[A] party to a contract is necessary, and if not susceptible to joinder, indispensable to litigation seeking to decimate that
+
+subsequent 18-month state incarceration).
+
+To the extent that the Petitioners' requested invalidation of the Non-Prosecution Agreement would implicitly reject and nullify the correctness of both the state court's acceptance of Epstein's guilty plea and the resulting judgment of conviction —which were induced in part by the Non-Prosecution Agreement — suckitn: action might raise additional questions about this Court's jurisdiction under the Rooker doctrine. See, e.g., Casale v. Tillman, 558 F.3d 1258, 1260-61 (11th Cir. 2009); Powell v. Powell, 80 F.3d 464, 466-68 (I I th Cir. 1996).
+
+contract."); Lomayaktewa v. Hathaway, 520 F.2d 1324, 1325 (9th Cir. 1975) ("No procedural principle is more deeply imbedded in the common law than that, in an action to set aside a lease or a contract, all parties who may be affected by the determination of the action are indispensable."); see also National Licorice Co. v. NLRB, 309 U.S. 350, 362 (1940) ("It is elementary that it is not within the power of any tribunal to make a binding adjudication of the rights in personam of parties not brought before it by due process of law.").5
+
+Additionally, a "favorable ruling" from this Court will not provide Petitioners with anything for the alleged CVRA violations that is not already available to them. For the due process reasons already discussed above, the United States must legally abide by the terms of the Non-Prosecution Agreement even if this Court should somehow set the agreement aside for Petitioners to consult further with the government attorney handling the case. Moreover, as will be explained in greater detail below, see infra at 8-12, Petitioners already have the present ability to confer with an attorney for the government about a federal criminal case against Epstein whether or not the Non-Prosecution Agreement is set aside — because the investigation and potential federal prosecution of Epstein for crimes committed against the Petitioners and others remains a legally viable possibility.'
+
+The present proceedings under the CVRA must accordingly be dismissed for lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought
+
+<sup>5</sup> Significantly, it is Epstein 's contractual rights under the non-prosecution agreement that Petitioners seek to void through these proceedings.
+
+<sup>6</sup> Petitioners' present, as well as past, ability to confer with an attorney for the government also demonstrates that Petitioners fail to satisfy the first two prongs of the standing test: Petitioners have simply not suffered a concrete injury that is fairly traceable to the challenged government conduct.
+
+would redress claimed injury).
+
+## II. The Claims Raised in the Petition Are Not Constitutionally Ripe, and These Proceedings Must Thus Be Dismissed for Lack of Subject Matter Jurisdiction.
+
+This Court must also dismiss these proceedings for lack of subject matter jurisdiction because the Petitioners' claims are not constitutionally ripe.
+
+Ripeness, like standing, "originate[s] from the Constitution's Article III requirement that the jurisdiction of the federal courts be limited to actual cases and controversies." Elend v. Basham, 471 F.3d 1199, 1204-05 (11th Cir. 2006). "'The ripeness doctrine keeps federal courts from deciding cases prematurely,' Beaulieu v. City of Alabaster, 454 F.3d 1219, 1227 (11th Cir. 2006), and 'protects [them] from engaging in speculation or wasting their resources through the review of potential or abstract disputes,' Digital Props., Inc. v. City of Plantation, 121 F.3d 586, 589 (11th Cir.1997)." United States v. M, 613 F.3d 1046, 1050 (11th Cir. 2010); see also Pittman v. M, 267 F.3d 1269, 1278 (11th Cir. 2001) ("The ripeness doctrine prevent[s] the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements ...."') (quoting Coalition for the Abolition of Marijuana Prohibition v. City of Atlanta, 219 F.3d 1301, 1315 (11th Cir. 2000) (citations and quotations omitted))). Under the ripeness doctrine, a court must therefore determine "'whether there is sufficient injury to meet Article III's requirement of a case or controversy and, if so, whether the claim is sufficiently mature, and the issues sufficiently defined and concrete, to permit effective decisionmaking by the court."' In re Jacks, 642 F.3d 1323, 1332 (11th Cir. 2011) (quoting Cheffer v. Reno, 55 F.3d 1517, 1524 (11th Cir. 1995)).
+
+When evaluating whether a claim is ripe, a court considers: "11) the fitness of the issues for judicial decision, and (2) the hardship to the parties of withholding court consideration."' Id. (quoting Cheffer, 55 F.3d at 1524 (citing Labs. v. Gardner, 387 U.S. 136, 149 (1967))); see also, e.g., Association For Children for Enforcement of Support, Inc. v. Conger, 899 F.2d 1164, 1165 (1 1 th Cir. 1990). Under the doctrine, "[a] claim is not ripe when it is based on speculative possibilities," In re Jacks, 642 F.3d 1323, 1332 (11th Cir. 2011), such as if the claim "'rests upon contingent future events that may not occur as anticipated, or indeed may not occur at all,"' Atlanta Gas Light Co. v. FERC, 140 F.3d 1392, 1404 (11th Cir. 1998) (quoting Texas v. United States, 523U.S. 296, 300 (1998)). Indeed, "[t]he ripeness doctrine is designed to prevent federal courts from engaging in such speculation and prematurely and perhaps unnecessarily reaching constitutional issues." Pittman, 267 F.3d at 1280.
+
+In these proceedings, the Petitioners have sought to set aside the Non-Prosecution Agreement between Epstein and the USAO-SDFL so that Petitioners can "confer with the attorney for the Government" about the possible filing of federal criminal charges against Epstein and the potential disposition of any such charges. See, e.g., July 11, 2008 Hr'g Tr. at 6-7 (seeking an "[o]rder that the [non-prosecution] agreement that was negotiated is invalid" so that Petitioners can exercise the right to confer with the government); id. at 19-20, 24; 18 U.S.C. § 3771(a)(5); see also DE 1 at 2 ¶ 5 (claiming that Petitioner was "denied her rights" under the CVRA because she "received no consultation with the attorney for the government regarding the possible disposition of the charges").
+
+Notwithstanding the Non-Prosecution Agreement, Petitioners are and have been free to confer with attorneys for the government about the investigation and potential prosecution of Epstein. At least one attorney for the government (Assistant United States Attorney Villafafia from the USAO-SDFL) had spoken to Petitioners about the offenses committed against them by Epstein prior to the signing of the Non-Prosecution Agreement, see, e.g., July 11, 2008 Hr'g Tr. at 22 (acknowledging that prosecutors spoke to Petitioners "about what happened" to them); DE
+
+48 at 6 ¶ 8; see also DE 99 at 3, and government attorneys have on multiple occasions offered to confer with Petitioners, see, e.g., July I I, 2008 Hr'g Tr. at 13 ("I will always confer, sit down with Jane Doe 1 and 2, with the two agents and Ms. Villafana. We'll be happy to sit down with them."). Indeed, on December 10, 2010, the United States Attorney for the Southern District of Florida, accompanied by supervisory and line prosecutors from the USAO-SDFL, personally conferred with Petitioners' counsel and with Petitioner Jane Doe #1 and entertained discussion about Petitioners' desires to see Epstein criminally prosecuted on federal charges.' The United States Attorney and prosecutors in the USAO-SDFL have also corresponded with Petitioners' counsel on multiple occasions about Petitioners' desires to have Epstein criminally prosecuted on federal charges.8
+
+Additionally,
+
+a number of districts outside the Southern District of Florida (e.g., the Southern District of New York and the District of New Jersey) share jurisdiction and venue with the Southern District of Florida over potential federal criminal charges based on the alleged sexual acts committed by Epstein against the Petitioners. Epstein is thus subject to potential prosecution for such acts in those districts. Furthermore, because of the nature of the allegations against Epstein, the filing of such potential charges against Epstein still remains temporally viable; charges for such sexual activities involving minors are not barred by the applicable
+
+<sup>&#</sup>x27; The United States Attorney also offered to confer with Jane Doe #2, but Jane Doe #2 declined the invitation and did not attend the meeting that was scheduled with the United States Attorney.
+
+<sup>8</sup> Since that time, the USAO-SDFL has been recused by the Department of Justice from prospective responsibility for any criminal investigation or potential prosecution relating to Epstein's alleged sexual activities with minor females. The Department of Justice has reassigned responsibility for the investigation and potential prosecution of such criminal matters in the Southern District of Florida to the United States Attorney's Office for the Middle District of Florida for consideration of any prosecutorial action that may be authorized and appropriate.
+
+statutes of limitations. See 18 U.S.C. §§ 3283, 3299. Petitioners arc free to contact the United States Attorney's Office in those districts and seek to confer with government attorneys in those offices about investigating and potentially prosecuting Epstein based on the alleged federal crimes committed against them.9
+
+Petitioners nonetheless have appeared to contend throughout these proceedings that the many opportunities that they have been given to consult with the attorneys for the government about Epstein's offenses and the potential charges against Epstein — opportunities which continue to be available to Petitioners — are not meaningful under the CVRA due to the existence of the Non-Prosecution Agreement. According to Petitioners, the Non-Prosecution Agreement has given Epstein a "free pass" on federal criminal charges for the offenses he committed against Petitioners and others. See, e.g., DE 9 at 15 (characterizing Non-Prosecution Agreement as "a 'free pass' from the federal government"), 2 (contending that the Non-Prosecution Agreement "allowed [Epstein] ... to escape all federal prosecution for dozens of serious federal sex offenses against minors"), 7 ("the wealthy defendant has escaped all federal punishment"), 12 ("[T]he agreement prevents federal prosecution of the defendant for numerous sex offenses."); DE 77 at 2 (describing Non-Prosecution Agreement as "an agreement that blocked federal prosecution of Epstein for the multitude of sex offenses he committed again [sic] the victims"), 17 ("The [Non-
+
+The USAO-SDFL has no present knowledge about whether the United States Attorney's Offices in those districts have opened any investigations into the allegations that have been made against Epstein, whether those offices are even aware of those allegations or the evidence supporting them, or what investigative or prosecutorial actions, if any, those offices might take in the future. Nonetheless, should any investigation be underwa or should an investigation be initiated involving such allegations, the evidence gathered in the Southern District of Florida could be disclosed to federal prosecutors an e era gran juries in New York or New Jersey. See
+
+Prosecution Agreement] barred prosecution of the federal sexual offenses that Epstein had committed against Jane Doe #1 and Jane Doe #2 ... .").10 That is simply not so.
+
+Contrary to Petitioners' contentions, there has been no disposition by the government of any federal criminal charges against Epstein. No federal charges involving Petitioners have ever been brought against Epstein, and no such federal charges have been resolved. The Non-Prosecution Agreement about which Petitioners complain disposes of no federal criminal charges against Epstein, and that agreement does not bar the United States from bringing federal criminal charges against Epstein. Instead, when addressing potential federal criminal charges against Epstein, the USAO-SDFL merely agreed in the Non-Prosecution Agreement that:
+
+on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below.
+
+and that
+
+After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed.
+
+Non-Prosecution Agreement at 2 (emphasis added).
+
+Thus, the Non-Prosecution Agreement simply obligated the government not to prosecute Epstein in the Southern District of Florida for the offenses set forth in the Non-Prosecution
+
+I° This Court has also previously described the Non-Prosecution Agreement as "an agreement under which ... the U.S. Attorney's Office would agree not to prosecute Epstein for federal offenses." DE 99 at 2-3. That description of the Non-Prosecution Agreement, however, was not based on the Court's interpretation of the terms of the Non-Prosecution Agreement, but was instead based on "allegations" by Petitioners that the Court concluded were "not yet supported by evidence" but upon which the Court nonetheless relied "solely to provide the context for the threshold issues addressed in" its September 26, 2011 Order. Id. at 2 n.2.
+
+Agreement. The Non-Prosecution Agreement does not bar the United States from bringing federal criminal charges against Epstein for the offenses set forth in the Non-Prosecution Agreement in any other district in the nation!' See, e.g., United States v. Cain, 587 F.2d 678, 680 (5th Cir. 1979) ("Where . . . the prosecutor is not found to have made promises relating to nonprosecution of charges in another district and the [defendant] is not found to have relied on such alleged promises, this Court will affirm the trial court's denial of a motion to dismiss the subsequent prosecutions."). Neither does the Non-Prosecution Agreement bar prosecution in any district for offenses not identified in the agreement.
+
+Petitioners contend that the CVRA gives a victim the right to confer with the attorney for the government before there is a disposition of contemplated, but-not-yet-filed federal criminal charges arising from offenses against the victim. But, although the government disputes that the CVRA creates such a right," the Petitioners have never been denied any such right. The Petitioners have had and still have the ability confer to with the attorney for the government about potential federal criminal charges against Epstein and about the potential disposition of any such charges, should they be filed. In fact, Petitioners are free to approach the United States Attorney's Offices in districts such as the Southern District of New York and the District of New Jersey — whose authority to institute criminal charges against Epstein in their districts has not
+
+No district or division shall make any agreement, including any agreement not to prosecute, which purports to bind any other district(s) or division without the express written approval of the United States Attorney(s) in each affected district and/or the Assistant Attorney General of the Criminal Division.
+
+USAM 9-27.641 (Multi-District (Global) Agreement Requests).
+
+II Significantly, under the governing provision of the United States Attorney's Manual, the USAO-SDFL did not have the authority to unilaterally bar Epstein's prosecution in any other district in the country:
+
+<sup>12</sup> The government acknowledges that this Court has nonetheless ruled that "as a matter of law the CVRA can apply before formal charges are filed," DE 99 at 10; see also id. at 6-9, but has not yet determined "whether the particular rights asserted here attached," id. at 10.
+
+been curtailed by the Non-Prosecution Agreement — to discuss the possibility of pursuing federal • criminal charges against Epstem.<sup>13</sup> Nothing precludes Petitioners from doing so, and there is nothing to indicate that Petitioners' wishes to confer with government attorneys in those districts would be rebuffed in any way. Indeed, it would be rank speculation by Petitioners to contend otherwise.
+
+Here, Petitioners have acknowledged that the best relief they can hope to obtain through these proceedings is the ability to confer with the attorneys for the government. See, e.g., July II, 2008 Hr'g Tr. at 7 (agreeing that "the best [Petitioners] can get" is the "right to confer"). Yet, under the circumstances, a claim that Petitioners have been denied the opportunity to confer with the attorney for the government about the filing and disposition of criminal charges against Epstein is premature and constitutionally unripe. "This is plainly the type of hypothetical case that [a court] should avoid deciding." Association for Children for Enforcement of Support, Inc. v. Conger, 899 F.2d 1164, 1166 (11th Cir. 1990). Any speculation by Petitioners that they might prospectively be denied the opportunity to confer with the government about still-legally-viable federal charges against Epstein simply cannot ripen Petitioners' claims. See id. (recognizing that courts "do not generally decide cases based on a party's predicted conduct").
+
+For these reasons, Petitioners' claims in these proceedings should be dismissed for lack of subject matter jurisdiction. See, e.g., In re Jacks, 642 F.3d 1323, 1332 (11th Cir. 2011) (holding that claims that are "based on events that may take place in the future" are to be "dismissed for lack of jurisdiction") (citing Greenbriar, Ltd. v. City of Alabaster, 881 F.2d 1570, 1574 n.7 (1 I th Cir. 1989) ("[R]ipeness goes to whether the district court had subject matter
+
+<sup>13</sup> Petitioners could also approach the United States Attorney's Office for the Middle District of Florida, but, due to that office's recusal-based derivative prosecutorial responsibilities in the Southern District of Florida, see supra note 8, the Non-Prosecution Agreement would constrain the possible filing of federal charges by that office in the Southern District of Florida.
+
+jurisdiction to hear the case.")); Reahard v. Lee County, 30 F.3d 1412, 1415 (11th Cir. 1994) ("The question of ripeness 'goes to whether the district court had subject matter jurisdiction.') (quoting Greenbriar, 881 F.2d at 1573); see also Jacksonville Property Rights Ass'n, Inc. v. City of Jacksonville, 635 F.3d 1266, 1276 (11th Cir. 2011) (concluding that when plaintiffs ask a court "to issue a declaration on an issue that might never impact their substantive rights," they are "asking th[e] court either to issue an impermissible advisory opinion, or to decide a case that is not yet ripe for decision"), reh'g & reh'g en bane denied, Case No. 09-15629, Fed. App'x (11th Cir. Jun. 29, 2011) (Table).
+
+## Conclusion
+
+For the reasons set forth above, the United States respectfully requests that this Court enter an order dismissing the Petitioners' claims and these proceedings for lack of subject matter jurisdiction.
+
+Respectfully submitted,
+
+WIFREDO A. FERRER  
+UNITED STATES ATTORNEY
+
+![]()Dexter A. Lee  
+Assistant United States Attorney  
+Florida Bar No. 0936693  
+99 N.E. 4th Street  
+Miami, Florida 33132  
+Tel: (305) 961-9320; Fax: (305) 530-7139  
+Email: dexter.lee@usdoj.gov
+
+![]()A. [REDACTED] Villafaña  
+Assistant United States Attorney  
+Florida Bar No. 0018255  
+500 S. Australian Avenue, Suite 400  
+West Palm Beach, FL 33401  
+Tel: (561) 820-8711; Fax: (561) 820-8777  
+Email: [REDACTED]
+
+Attorneys for Respondent

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marker2/court-us-v-epstein-cr/EFTA02824182/EFTA02824182.md

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+Reid Weingarten 1114 Avenue of the Americas New York, NY 10036 212 506 3900 main 212 506 3955 direct WNW . steotoe corn rweinoarten steptoe.com
+
+July 11, 2019
+
+### VIA ECF
+
+The Honorable Richard M. Berman United States District Court Southern District of New York United States Courthouse (212) 805-6715 500 Pearl Street New York, NY 10007
+
+RE: United States it Jeffrey Epstein, Criminal No. 19-490
+
+Dear Judge Berman:
+
+![](_page_0_Picture_2.jpeg)
+
+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 any conceivable danger he's claimed to present.
+
+In essence, the government seeks to remand a self-made New York native and lifelong American resident based on dated allegations for which he was already convicted and punished conduct the relitigation of which is barred by a prior federal nonprosecution agreement (the "NPA"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States — despite a Florida federal judge's stated belief that he could void the NPA in appropriate circumstances, possibly threatening new charges there, and notwithstanding legally erroneous government assertions in ancillary litigation that Mr. Epstein was subject to potential prosecution in other federal judicial districts, including this one specifically. Indeed, Mr. Epstein feared the toxic political climate might tempt the government to try and end-run the NPA — yet continually returned home from travel abroad, fully prepared to vindicate his rights under the agreement and otherwise mount a full-throated defense. Finally, the government takes its extreme position in the teeth of Mr. Epstein's perfect compliance with onerous sex offender registration requirements — pinpointing his exact nightly whereabouts across multiple jurisdictions over a 10-year period.
+
+Nonetheless, it is fundamental that pretrial detention is reserved for “a small but identifiable group of particularly dangerous defendants as to whom neither the imposition of stri[ct] release conditions nor the prospect of revocation of release can reasonably assure the safety of the community or other persons.” S. Rep. No. 98-225, at 6-7 (1984), *reprinted in* 1984 U.S.C.C.A.N. 3182, 3189. And that’s true no matter how much rhetoric and hyperbole the government and media pile on a presumptively innocent citizen. Popular condemnation aside, compelling legal issues stand between Mr. Epstein and any possible conviction on the allegations of conduct from 14 to 17 years ago pressed in the indictment. Importantly, the Bail Reform Act, 18 U.S.C. § 3141 *et seq.*, authorizes release for even wealthy defendants facing serious charges who travel and own property abroad.
+
+The government’s indictment labels this a “Sex Trafficking” case. Yes, the government may have witnesses who will testify to participating in sexual massages – most over 18; some under; some who told the police they lied about their age to gain admission to Mr. Epstein’s residence; some who will testify that Mr. Epstein knew they were not yet 18.<sup>1</sup> But their anticipated testimony only punctuates the alleged offenses’ purely local nature. (All occurred within a single New York residence or, if the Florida conduct is ultimately ruled admissible despite the NPA, then within two residences.) There are no allegations in the indictment that Mr. Epstein trafficked anybody for commercial profit; that he forced, coerced, defrauded, or enslaved anybody; or that he engaged in any of the other paradigmatic sex trafficking activity that 18 U.S.C. § 1591 aims to eradicate. No one seeks to minimize the gravity of the alleged conduct, but it is clear that the conduct falls within the heartland of classic state or local sex offenses – and at or outside the margins of federal criminal law.
+
+Mr. Epstein, 66, is a U.S. citizen who’s lived his entire life in this country. Born and bred in Coney Island, he worked his way up from humble origins – his father was a New York City municipal employee in the ██████ Department – and earned every penny he’s made with nothing more than a high school diploma. He speaks only English and knows no other languages. He owns no foreign businesses and holds no foreign bank accounts. Five of the six residences he maintains are located here in America. His brother, niece, and nephew all live here too.
+
+Until his arrest in this case, Mr. Epstein’s only notable brush with the law resulted in the 2007 NPA (Exhibit 1) and a 2008 state-court guilty plea required by the NPA for conduct substantially overlapping the conduct charged in the pending indictment. As a result of the state guilty plea, Mr. Epstein received a 30-month sentence, 18 months of incarceration, and 12 months’ probation under conditions including home confinement. Mr. Epstein served 13 months in custody, 12 months on probation and, as a condition of the NPA and his state sentence, was required to register as a sex offender in the locations of his residences. He is currently registered
+
+---
+
+<sup>1</sup> New York’s age of consent was 17 at the time of the alleged conduct and remains so today. *See* N.Y. Penal Law § 130.05.
+
+in the U.S. Virgin Islands, his principal residence, Florida, and New York. Mr. Epstein has scrupulously fulfilled his obligations in every jurisdiction in which he was required to register throughout the 10-year hiatus between his release and present arrest. All of his travel has been meticulously reported to the registration authorities so that they have been aware of his precise location every single day for the past 10 years. Better still, the pending charges date back 14-17 years, from 2002 to 2005. Yet, tellingly, they allege no recurrence of the conduct underlying the NPA and Florida state conviction at any time in the ensuing decade and a half (2005-2019). Together, these unique factors are powerful indicia that Mr. Epstein is no longer a danger to anyone and will faithfully obey all conditions of release if ordered.
+
+In sum, Mr. Epstein has substantial grounds to challenge the allegations charged by the government in its indictment, and he has every intention of doing so in a lawful, professional, and principled manner. He intends to fight the current charges on their merits and, more, to contest their legality given the inextricable intertwining of the current investigation and his NPA which promised him immunity and a global settlement for offenses including those brought under 18 U.S.C. § 1591. Any perception that Mr. Epstein poses any conceivable danger or flight risk may be readily dispelled by a slate of highly restrictive conditions, which amply suffice to secure his release:
+
+- I. Home detention in Mr. Epstein's 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 and rear entrances to ensure compliance.
+- 2. Electronic monitoring with a Global Positioning System?
+- 3. An agreement not to seek or obtain any new passport during the pendency of this matter.3
+
+<sup>2</sup> "A radio frequency ('RF') bracelet is the more conventional 'ankle bracelet' that has been used over time. GPS monitoring is a more recent phenomenon that is distinct from RF monitoring. While both units are placed on the ankle, the former tracks an offender's movements in real time, while the latter is contingent upon proximity to a base unit connected to a landline at an offender's home. Statistically, GPS monitoring is more effective than RF monitoring at preventing recidivism." United States v. Paulin, 335 F. Supp. 3d 600, 617 n.5 (S.D.N.Y. 2018) (citations omitted).
+
+<sup>3</sup> Mr. Epstein has only one active passport permitting current travel — not three, as the government fancies. That one active U.S. passport has now been surrendered. Mr. Epstein has no foreign passports.
+
+- 4. Consent to U.S. extradition from any country and waiver of all rights against such extradition.'
+- 5. A substantial personal recognizance bond in an amount set by the Court after reviewing additional information regarding Mr. Epstein's finances, which Mr. Epstein will seek the Court's permission to provide via sealed supplemental disclosure.
+- 6. The bond shall be secured by a mortgage on the Manhattan residence, valued at roughly \$77 million. Mr. Epstein's private jet can be pledged as further collateral.
+- 7. Mr. Epstein's brother Mark will serve as a co-surety of the bond, which shall be further secured by a mortgage on Mark's home in West Palm Beach, Florida. Mr. Epstein's friend David Mitchell will also serve as a co-surety and pledge his investment interests in two properties to secure the bond.
+- 8. Mr. Epstein shall deregister or otherwise ground his private jet.5
+- 9. He shall demobilize, ground, and/or deregister all vehicles or any other means of transportation in the New York area, providing particularized information as to each vehicle's location.
+- 10. Mr. Epstein will provide Pretrial Services and/or the government random access to his residence.
+  - I. No person shall enter the residence, other than Mr. Epstein and his attorneys, without prior approval from Pretrial Services and/or the Court.
+- 12. Mr. Epstein will report daily by telephone to Pretrial Services (or on any other schedule the Court deems appropriate).
+- 13. A Trustee or Trustees will be appointed to live in Mr. Epstein's residence and report any violation to Pretrial Services and/or the Court.
+- 14. My other condition the Court deems necessary to reasonably assure Mr. Epstein's appearance.
+
+## I. Applicable law
+
+Echoing and reinforcing the presumption of innocence, our justice system's bedrock, there is a "strong presumption against [pretrial] detention." United States v. Hanson, 613 F. Supp. 2d 85, 87 (D.D.C. 2009). A person facing trial generally must be released so long as some "condition, or combination of conditions ... [can] reasonably assure the appearance of the person as required and the safety of any other person and the community." 18 U.S.C. § 3I42(c). "Only in rare circumstances should release be denied." United States v. Motamedi, 767 F.2d 1403, 1405 (9th Cir. 1985). My doubts as to the propriety of release are resolved in the defendant's favor. See United States v. Chen, 820 F. Supp. 1205, 1207 (N.D. Cal. 1992).
+
+<sup>4</sup> Mr. Epstein's lone foreign residence is in Paris; France has an extradition treaty with the United States.
+
+<sup>5</sup> Mr. Epstein owns one private jet. He sold the other jet in June 2019.
+
+Though the Bail Reform Act contains a rebuttable presumption in favor of detention based on the crimes charged, the presumption shifts only the burden of production, not persuasion. See United States v. Martir, 782 F.2d 1141, 1144 (2d Cir. 1986). Accordingly, the statutory demand on defendants "is fairly easily met." United States v. Conway, No. 4-11-70756, 2011 WL 3421321, at \*2 (N.D. Cal. Aug. 3, 2011). To rebut the presumption, a defendant need only "show that the specific nature of the crimes charged, or that something about their individual circumstances, suggests that `what is true in general is not true in the particular case . '" United States v. Dominguez, 783 F.2d 702, 707 (7th Cir. 1986) (quoting United States v. Jessup, 757 F.2d 378, 384 (1st Cir.1985)). "The quantum of evidence required to rebut the presumption is not high." United States v. Thompson, No. I6-CR-00019, 2018 WL 447331, at \*2 (M.D. Pa. Jan. 17, 2018) (citation omitted). "Any evidence favorable to a defendant that comes within a category listed in § 3I42(g) can affect the operation of [the presumption], including evidence of their marital, family and employment status, ties to and role in the community, clean criminal record and other types of evidence encompassed in § 3142(g)(3)." Dominguez, 783 F.2d at 707 (clean record plus socioeconomic stability sufficed to rebut presumption).
+
+In short, evidence that the defendant is unlikely to flee or commit crimes rebuts the presumption, forcing the government to persuade the court that detention is warranted. See Conway, 2011 WL 3421321, at \*5 (§ 1591 defendant released pending trial). While not disappearing entirely, the presumption thus recedes to one factor among many in determining whether there are sufficient conditions to "reasonably assure" both presence and safety. See Martir, 782 F.2d at 1144; see also United States v. Orta, 760 F.2d 887, 891 (8th Cir. 1985) ("[R]easonably assure" doesn't mean "guarantee."). Even in a presumption case, then, "the government retains the ultimate burden of persuasion by clear and convincing evidence that the defendant presents a danger to the community," and by a "preponderance" that he poses a flight "risk." United States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (citation and internal quotation marks omitted).
+
+## II. Mr. Epstein's 14-year record of law-abiding behavior rebuts any presumption in favor of pretrial detention
+
+In this case, any danger presumption attending the § 1591 charges evaporates against Mr. Epstein's meticulous obedience, from 2005 to date, to both the law's commands and his rigorous registration and reporting obligations as a convicted sex offender. The indictment does not allege that Mr. Epstein committed any crime in the I4-year interval between the end of the alleged conduct and the initiation of this case. The dangerousness prong of the Bail Reform Act is predictive, asking whether it's likely that Mr. Epstein will reoffend if released. A spotless 14 year record of walking the straight and narrow, complemented by an exemplary 10-year history of diligent sex offender registration and reporting, is compelling proof he was able, once the prior investigation commenced, to conform his conduct to the law's dictates. The time lag between the offenses charged and today is particularly compelling in terms of a prediction of
+
+future danger when viewed in the context of the unparalleled global media attention the case has garnered, including the creation of a website by the government requesting witnesses claiming abuse to come forward. Accordingly, any danger that Mr. Epstein may have once posed to the community has long since abated. At the very least, this enormous gap in time precludes a finding by clear and convincing evidence that no conditions of release can reasonably assure the community's safety.<sup>6</sup>
+
+The rebuttable presumption of a risk of flight is negated by the evidence that the government had stated it believed it could prosecute Mr. Epstein for the very same conduct for which he was immunized, albeit in a second jurisdiction, despite the protections conferred upon him under the NPA. Mr. Epstein's continuous presence in the United States even while he had a residence out of the country reinforces the point. As detailed below, Mr. Epstein understood the NPA as a global resolution of any charges arising from the alleged conduct at issue here, including conduct in New York. Indeed, the government, in a Southern District of Florida filing
+
+---
+
+<sup>6</sup> The government vastly overreaches in painting Mr. Epstein as dangerous based on musty plea discussions. The government's argument that Mr. Epstein's release would risk obstructive behavior, at pages 8-9 of its submission, rests primarily upon statements made between Mr. Epstein's prior counsel and an Assistant U.S. Attorney while they searched for a federal offense, at the government's behest, with a one-year statutory maximum or guideline during the give-and-take of those of plea negotiations. The communication from prior counsel about a potential proffer for a federal charge was met with the response that there was no sufficient evidence to charge such an offense. These purported facts were mere allegations that did not ultimately manifest themselves in any agreement by Mr. Epstein – nor in any agreement that probable cause existed to support any obstruction or assault charge. And the documents from the Southern District of Florida litigation referenced by the government in support of its argument on this point expressly acknowledge this lack of substantiation. *See Jane Doe #1 and Jane Doe #2 v. United States*, 08-CV-80736 (S.D. Fla.), Dkt. 361-10 (prosecutor stating, "[o]n the obstruction charges, many of the facts that I included in that first proffer were hypothesized based upon our discussions and the agents' observations of [redacted]. We will need to interview her to confirm the accuracy of those facts. . . ."), Dkt. 361-11 (prosecutor stating, "I know that someone mentioned there being activity on an airplane, I just wanted to make sure that there is factual basis for the plea that the agents can confirm"), Dkt. 361-9 (prosecutor stating, "I don't know the factual basis for the alleged [redacted] because we have no independent evidence of that"). In short, these were suggested hypotheses not facts, and the government itself ultimately did not believe there was factual support for the allegations. They do not provide a sufficiently reliable factual basis for any finding by clear and convincing evidence. As to the suggestion by the prosecutor that a charge could be predicated on a prior incident where it was alleged that an investigator forced a family member of a witness off the road, the defense is without knowledge as to the basis for this allegation and the conduct, if it occurred, was not attributable to or authorized by Mr. Epstein.
+
+that was unsealed and became public in July 2013, specifically noted that “a number of districts outside the Southern District of Florida (*e.g.*, the Southern District of New York and the District of New Jersey) share jurisdiction and venue with the Southern District of Florida over potential federal criminal charges based on the alleged sexual acts committed by Epstein against the Petitioners. Epstein is thus subject to potential prosecution for such acts in those districts.” Exhibit 2, *Jane Doe #1 and Jane Doe #2 v. United States*, 08-CV-80736 (S.D. Fla. July 5, 2013), Dkt. 205-2, at 9. The government went so far as to invite the alleged victims “to contact the United States Attorney’s Office in those districts and seek to confer with government attorneys in those offices about investigating and potentially prosecuting Epstein based on the alleged federal crimes committed against them.” *Id.* at 10. The Florida U.S. Attorney’s Office even offered to share the evidence gathered in its investigation with prosecutors and grand juries in the other relevant jurisdictions. *See id.* at 10 n.9.
+
+The defense strongly disagrees with the premise that the government can offer and execute an immunity or nonprosecution agreement with a citizen in the location of one of two venues where an interstate telephone call (or flight or any form of wire or mail communication) occurs and then circumvent the consequences of that immunity grant by having the very same prosecution office promote and motivate a prosecution by another office at the second venue of what in fact was a single criminal transaction. What is significant for bail purposes is that notwithstanding this notice of the government’s illegal position, and his knowledge of the substantial penalties that he would face if charged and convicted, Mr. Epstein made no attempt to flee in the approximately six years preceding his arrest. During that time, as noted by the government, he engaged in substantial international travel, always returning to his residences in the United States. Mr. Epstein never sought to obtain dual citizenship or took any other steps indicative of an intent to flee. This fact significantly undermines the government’s contentions regarding risk of flight and indicates Mr. Epstein’s good-faith intent to contest the charges pending against him.
+
+On September 24, 2007, after a year-long investigation, the Department of Justice, through the United States Attorney for the Southern District of Florida (“USAO-SDFL”), entered into the NPA with Mr. Epstein. The NPA immunized Mr. Epstein from five distinct potential federal charges that “may have been committed by Epstein . . . from in or around 2001 through in or around September 2007.” Exhibit 1, NPA, at 1-2. One of the federal charges was 18 U.S.C. § 1591, the statute charged in this SDNY case. The time period covered by the NPA subsumes the entire time period charged in this SDNY case. The USAO-SDFL acknowledged in the NPA that the very premise for Mr. Epstein to enter into it was “to resolve *globally* his state and federal criminal liability . . .” *Id.* at 2 (emphasis added). Senior officials at the Department of Justice reviewed the NPA and either authorized or helped negotiate the resolution of the matter. *See, e.g.*, United States’ Second Supplemental Privilege Log filed as Dkt. 329-1 in *Jane Doe #1 and Jane Doe #2 v. United States*, No. 08-CV-80736 (S.D. Fla.) (the “CVRA litigation”) (illustrating the number of prosecutors involved in the decision-making over the NPA).
+
+The NPA required Mr. Epstein to plead guilty to a state felony charge (Fla. Stat. § 796.07), then pending in the State of Florida and to an additional state felony charge (not previously charged or required by the State) of violating Fla. Stat. § 796.03 (Case No. 2008-CF-9381AXX), a charge requiring registration as a sex offender. Mr. Epstein complied with all of his obligations under the NPA.
+
+Contrary to the government's argument, the NPA was not limited to a "list of several dozen victims identified in the prior investigation . . . ." Gov't Bail Letter at 6-7. Indeed, the NPA contains no "list of several dozen victims" and regardless, the NPA immunized Mr. Epstein from prosecution "for the *offenses* set out on pages 1 and 2 of this Agreement," allegedly committed between 2001-07, as well as "any offenses that arose from the Federal Grand Jury investigation." NPA at 2 (emphasis added). Moreover, the government's interpretation that the NPA "pertained exclusively to the SDFL investigation" and "did not purport to bind any other Office or District" will be the subject of a major dispute in this case. This is especially so because Mr. Epstein's alleged conduct at his Palm Beach residence features prominently in the conspiracy count (Count 1, ¶¶ 14-19, ¶ 22.a, d, f) and is incorporated by reference in the substantive charge (Count 2, ¶ 23).
+
+Beyond that, Mr. Epstein intends to raise and litigate significant due process issues about the Department of Justice's conduct in this case. Namely, there is irrefutable evidence from the pending CVRA litigation in the Southern District of Florida that, after Mr. Epstein had fully complied with his obligations under the NPA, the USAO-SDFL affirmatively encouraged alleged victims to pursue prosecution of Mr. Epstein in other districts, in violation of the DOJ's commitment to a "global" resolution. *See* Exhibit 2, at 8-12. The United States Attorney for the Southern District of Florida, along with supervisory and line prosecutors from the USAO-SDFL, corresponded on multiple occasions with, and personally conferred with, alleged victims and their lawyers to entertain discussions about the alleged victims' desire to have Mr. Epstein prosecuted on federal charges. *See id.* at 9. Further, the Southern District of New York is likely relying upon physical evidence seized in connection with the prior investigation, *see* Gov't Bail Letter at 6 (discussing "corroborating evidence," including "contemporaneous notes, messages . . . , and call records"). In short, there will be evidence that the current New York case is not truly independent of the prior immunized conduct. The evidence will show that Mr. Epstein's reasonable expectation that the NPA would "resolve globally [Mr. Epstein's] state and federal criminal liability" in exchange for Mr. Epstein's compliance with the duties and obligations in the NPA – which he fully performed – has been unconstitutionally undermined by the government's efforts to minimize the potential consequences of a CVRA conferral violation (one that neither the government nor defense believes occurred but that was found to have occurred in the CVRA litigation which is pending a decision on remedies) by returning an inextricably intertwined second federal prosecution just as the District Court in Florida is receiving submissions on remedy.
+
+Finally, the government fails to consider the doctrine of pre-indictment delay, inasmuch as the statute of limitations does not fully define a defendant's rights with respect to delays that occurred prior to the indictment. *See generally United States v. Marion*, 404 U.S. 307 (1971). Here, the delays of 14 years from the last alleged act and 12 years since Mr. Epstein signed the NPA are extraordinary. If the government is correct that the NPA does not, and never did, preclude a prosecution in this district, then the government will have to explain why it purposefully delayed a prosecution of someone like Mr. Epstein, who registered as a sex offender 10 years ago and was certainly no stranger to law enforcement. There is no legitimate explanation for the delay.
+
+### III. The government fails to meet its burden of proving that no combination of conditions will assure Mr. Epstein's appearance and public safety
+
+An analysis of the relevant statutory factors and case law supports pretrial release. Even should the Court conclude, despite substantial evidence to the contrary, that the defendant presents a risk of flight, the foregoing combination of conditions virtually guarantees his appearance as required. Crucially, while it is always possible to hypothesize risks, the statutory standard requires only a *reasonable* assurance that the defendant, if released, will appear. The conditions proposed above, including electronic GPS monitoring, surrender of Mr. Epstein's passport, deregistration and/or grounding of Mr. Epstein's private plane, and a substantial personal bond (including posting of personal residence(s) and/or private jet as security to guarantee appearance) would extinguish any plausible risks. Mr. Epstein's current notoriety minimizes any conceivable risk of flight even further. The location where he could be detained – his residence on East 71<sup>st</sup> Street in New York has entrances (one on the street, one in the back) that can be easily monitored by video. With all of his financial resources in the United States (other than his Paris residence) and with his New York residence at risk due to the government's forfeiture allegation, Mr. Epstein would be sacrificing virtually everything he has worked for – including any collateral the Court requires he post to secure his appearance – if he were to flee and to disentitle himself to the defense of his property whether it would be at risk to forfeiture or for a bail violation.
+
+To the extent there is any doubt regarding the proposed conditions, there is tremendous moral suasion provided by the posting of real and personal property of Mr. Epstein's brother, and his close personal friend of decades, who have offered to co-sign a surety bond to ensure Mr. Epstein's appearance in Court as required. Indeed, Mr. Epstein's brother has agreed to pledge his family home, that he shares half the year with his 14-year-old daughter and 17-year-old son, in order to secure the bond. It is particularly telling that Mr. Epstein's brother, his only living immediate family member, as well as his close personal friend, are both willing to guarantee his appearance, notwithstanding the widespread negative publicity of Mr. Epstein that has dominated the news cycle since his arrest.
+
+To reiterate, the Bail Reform Act requires pretrial release on the "least restrictive" conditions that will assure both appearance and public safety. 18 U.S.C. § 3142(cX1)(B) (emphasis added). Home confinement monitored by 24-hour private security guards — a lesser restriction than pretrial detention — has proven effective in meeting those goals in many prominent cases prosecuted in our Circuit including cases against defendants as infamous as Bernie Madoff, Marc Dreier and David
+
+To be clear, defense counsel are fully confident Mr. Epstein will appear as required without resort to this measure. And we understand and appreciate Your Honor's opposition to it. See United States v. Zarrab, No. 15-CR-867, 2016 WL 3681423 (S.D.N.Y. June 16, 2016). Still, Mr. Epstein stands ready and willing to pay for 24-hour armed guards should the Court deem it necessary or appropriate.
+
+More precisely, we realize that Your Honor objects to the measure as more akin to custody than release, finding it inequitable for wealthier defendants to "buy their way out" of jail pending trial. Id. at \*2, \*9-10, \*13 (citation omitted). Nonetheless, a band of other courts in our area have endorsed the procedure,' and the Second Circuit has affirmed its use.8
+
+For reasons explained elsewhere, round-the-clock, privately funded security guards will virtually guarantee - not just reasonably assure — Mr. Epstein's presence in the circumstances of this case. Accordingly, and given the division of authority surrounding the practice, we respectfully propose it here as a fallback, asking the Court to revisit its propriety despite the reservations expressed in Zarrab. Those reservations, though admirably motivated and sincerely held, raise substantial equal protection concerns. They impair the statutory right to release on the least restrictive conditions in the circumstances presented - an inherently individualized determination — based largely on socioeconomic status, a suspect if not invidious classification. Avoiding "inequity and unequal treatment" rooted in such dubious socioeconomic distinctions doing "equal right to the poor" and "rich" alike — are imperatives that run both ways. Id. (bolding deleted) (citation, footnote and internal quotation marks omitted).
+
+<sup>&#</sup>x27; t , United States v. , 354 F. Supp. 3d 354 (S.D.N.Y. 2019); United States v. 309 F. Supp. 3d 24 (S.D.N.Y. 2018); United States v. Seng, No. 15-CR-706, 2017 WL 2693625 (S.D.N.Y. Oct. 23, 2015); United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009); United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009); United States v. Schlegel, No. 06-CR-550, 2008 WL 11338900, at \*1 (E.D.N.Y. June 13, 2008), modification denied, 2008 WL 11339654 (E.D.N.Y. July 2, 2008).
+
+See United States v. 749 F. App'x 20 (2d Cir. 2018); United States v. Sabhnani, 493 F.3d 63 (2d Cir. 2007).
+
+Other than his 2008 guilty plea predicated on conduct substantially overlapping the same conduct charged here, Mr. Epstein has no criminal history. Congress specifically listed these factors as considerations for the Court, and their absence therefore should weigh in favor of Mr. Epstein's pretrial release. Mr. Epstein comes from a stable and humble family background. All of his remaining family members, his brother, niece, and nephew, reside in the United States. Through his business and the five residences he maintains in the United States, Mr. Epstein employs people, many of whom have been with him for more than a decade, and feels personally responsible for their livelihoods. Mr. Epstein is admittedly wealthy with all of his financial resources (other than his Paris residence) in the United States (including the U.S. Virgin Islands) and will provide the Court with more specific information regarding his assets in a sealed supplemental disclosure prior to the upcoming bail hearing if the Court grants leave to file such a sealed supplement. Mr. Epstein has, to this point, not provided a complete financial disclosure on advice of counsel, motivated by a desire to ensure the accuracy of the information provided to the Court. During the years since his release from incarceration in connection with his Florida guilty plea, Mr. Epstein has been a law-abiding citizen without a single allegation of criminal misconduct during that period and has focused his efforts on business and philanthropy. At the Court's request, Mr. Epstein will provide a sealed list of his philanthropic donations.
+
+Crucially, the government has failed to proffer any evidence that Mr. Epstein has ever indicated an intent to flee from this investigation or any other criminal matter, which several courts have observed is a critical factor in evaluating whether pretrial release is appropriate. See Hanson, 613 F. Supp. 2d at 90 ("In this case, ... there is no strong circumstantial evidence indicating that Mrs. Hanson intends to flee the United States"); United States v. Vortis 785 F.2d 327 (D.C. Cir.1986) (serious intent to flee is an important factor); United States v. M, 715 F. Supp. 677, 679 (E.D. Pa.1988) (defendant told undercover agents he would flee if arrested). In fact, Mr. Epstein has displayed long-term, consistent compliance with Court orders and other legal requirements. As a result of his 2008 guilty plea and corresponding sex-offender designation, Mr. Epstein is required to (I) register for life as a sex offender; (2) regularly verify his address with Virgin Islands, Florida, and New York authorities; (3) annually update his registry photograph; and (4) provide registration authorities with detailed itineraries for all travel (both domestic and international) in which he engages. Mr. Epstein has strictly complied with these requirements, without exception, for approximately ten years.
+
+The Court inquired about the relationship of the New York State registration classification and the requirements of the Bail Reform Act. And while it is true that the New York Appellate Division held that Mr. Epstein was appropriately classified as a level-three sex offender, this inquiry was entirely backward-looking and based on the allegations contained in a Florida probable cause affidavit describing conduct ending in 2005 that were neither admitted-to nor within the scope of Mr. Epstein's guilty plea. See People v. Epstein, 89 A.D. 3d 570, 571 (N.Y. App. Div. 2011). While Mr. Epstein has made no subsequent attempt to challenge the continuing nature of his designation, his law-abiding behavior for the ensuing decade plus
+
+significantly undercuts any suggestion of current dangerousness based on any regulatory classification. Moreover, as discussed above, Mr. Epstein's strict compliance with the various monitoring requirements associated with his sex-offender registration actually decrease any danger that he might otherwise pose. It is also worth noting that Mr. Epstein is classified as a tier-one sex offender, the lowest classification available, in the U.S. Virgin Islands, where he maintains his primary residence. The defense respectfully suggests that Mr. Epstein's Virgin Islands designation is more consistent with the circumstances of the actual offenses for which he was convicted, and certainly more consistent with the predictive factor of whether there is a danger of recidivism which the defense contends there is not.
+
+Mr. Epstein's financial means and past international travel do not extinguish this Court's congressional mandate to order pretrial release in every case where reasonable conditions can assure the appearance of the defendant as required.' Indeed, numerous courts have rejected government requests for detention, and instead ordered pretrial release, in cases where the charged defendant was either a non-citizen (unlike Mr. Epstein) or a naturalized citizen with substantial if not weightier contacts with foreign jurisdictions, including the following decisions:
+
+- United States v. Sabhnani, 493 F.3d 63 (2d Cir. 2007) (reversing district court order of detention of defendants, who were natives of Indonesia, and ordering release despite defendants' "strong motive to flee" because of serious charges and "strong" evidence of guilt, despite finding that defendants faced "lengthy term of incarceration" if convicted, despite finding defendants possessed "ample means to finance flight," despite finding that defendants "maintained strong family ties to their native countries as well as personal and professional ties to various locations in Europe and the Middle East," and despite finding that defendants "could, with relatively little disruption, continue to operate their highly lucrative business from any number of overseas locations");
+- United States v. Hansen, 108 F. App'x 331 (6th Cir. 2004) (affirming district court order of pretrial release of defendant, a resident and citizen of Denmark-from where defendant could not be extradited-charged with bulk cash smuggling and forfeiture, noting that the
+
+<sup>9</sup> This Court's opinion in Zarrab stands only for the proposition that wealthy defendants should not be provided an unfair advantage. It does not, of course, suggest that wealthy defendants should bear a special disadvantage. The facts supporting the Court's ruling of pretrial detention in Zarrab are easily distinguishable. The present case does not have national security implications, Mr. Epstein is a United States citizen (and does not possess any dual citizenship), the only foreign country in which Mr. Epstein maintains a residence (France) has an extradition treaty with the United States, Mr. Epstein's assets are almost all located in the United States (with the exception of his Paris residence), and Mr. Epstein has provided only truthful information to Pretrial Services.
+
+"bail statute does not ... require that foreign defendants be detained simply because their return cannot be guaranteed through extradition");
+
+- United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004) (ordering release of defendant, an Israeli national who had resided in South Africa for the 18 years preceding his arrest when he landed in Colorado for a family ski trip based on allegations he violated the Export Administration Act and the International Economic Emergency Powers Act by acquiring products capable of triggering nuclear weapons and exported them to Pakistan, despite defendant's lack of any ties to the United States, despite finding that defendant had "no ties to the United States or the Washington, D.C. area," despite finding that "no evidence [was] presented establishing that Defendant has ever lived in this country, owned property here, or that he has any family or community ties in the United States," despite finding that defendant "was only in this country in order to participate in a ski vacation with his wife and daughter," and despite finding that "the weight of the evidence against Defendant is substantial");
+- United States v. Hanson, 613 F. Supp. 2d 85 (D.D.C. 2009) (ordering release of defendant, a naturalized citizen of the United States, despite finding defendant "has strong ties to [her home country of] China," finding that the defendant owned property in China, that the defendant spent almost all of her ten years of marriage living abroad with her husband, that during 2008 the defendant spent only 22 days in the United States, that the charges against the defendant (violations of International Emergency Economic Powers Act and the Export Administration Regulations) "were serious and carried a potential for a significant period of incarceration" and that the "government has strong evidence against" the defendant "including her own statement to investigators that she smuggled the UAV autopilot components out of the United States and knew there were licensing requirements for such items").
+
+The fact that the government will potentially seek a significant sentence if Mr. Epstein is convicted on all counts similarly does not preclude pretrial release in this case — several courts have ordered pretrial release despite finding that the defendant faced serious charges carrying significant potential sentences. See, e.g., Sabhnani, 493 F.3d 63 (reversing district court order of detention despite finding that defendants, natives of Indonesia, faced "lengthy term of incarceration" and "strong" evidence of guilt existed); Karni, 298 F. Supp. 2d 129 (ordering release of defendant, an Israeli national who had resided in South Africa for the 18 years preceding his arrest, despite finding that "the weight of the evidence against Defendant is substantial"); Hanson, 613 F. Supp. 2d 85 (noting that charges "were serious and carried a potential for a significant period of incarceration" and that the "government has strong evidence against" the defendant "including her own statement to investigators that she smuggled the UAV autopilot components out of the United States and knew there were licensing requirements for such items"). As the government concedes, the increases in sentencing exposure enacted after
+
+the alleged conduct at issue here do not apply retroactively to Mr. Epstein's case (including a maximum sentence of life imprisonment and a mandatory minimum sentence of 10 years). Mr. Epstein would, moreover, be subject to prosecution if he fled, which he now knows carries a maximum penalty of up to 10 additional years of imprisonment, 18 U.S.C. § 3146(b)(1)(A)(1), and/or the real risk of an enhanced sentence by the Court in this matter if not acquitted.
+
+It must further be emphasized that the allegations outlined within the indictment are just that – allegations – and the defendant anticipates substantial factual and legal challenges to the government case. For one thing, Epstein has potent legal defenses to prosecution under 18 U.S.C. § 1591, the sex trafficking statute driving the pending indictment. We front and briefly outline one of those defenses for the limited purpose of seeking bail. We will amplify it later, along with various other arguments, in full-blown dismissal motions.
+
+Section 1591 was passed as part of the Trafficking Victims Protection Act of 2000 (“TVPA”), Pub. L. No. 106-386, 114 Stat. 1464 (October 28, 2000). In enacting the TVPA, Congress recognized that human trafficking, particularly of women and children in the sex industry, “is a modern form of slavery, and it is the largest manifestation of slavery today.” 22 U.S.C. § 7101(b)(1); *see also id.* at § 7101(b)(2), (4). “The TVPA criminalizes and attempts to prevent slavery, involuntary servitude, and human trafficking for commercial gain.” *United States v. [REDACTED]*, 476 F.3d 1176, 1179 (11th Cir. 2007). Importantly, “the entire language and design of the statute as a whole indicates that it is meant to punish those who are the providers or pimps of children, *not the purchasers or the johns*.” *Fierro v. Taylor*, No. 11-CV8573, 2012 WL 13042630, at \*3 (S.D.N.Y. July 2, 2012) (quoting *United States v. Bonestroo*, No. 11-CR-40016, 2012 WL 13704, at \*4 (D.S.D. Jan. 4, 2012)) (emphasis added). In *Fierro*, the district court found § 1591 inapplicable to consumers or purchasers of sex acts. Here, the principal conduct underlying the indictment is Mr. Epstein's payment of money for massages that purportedly escalated to alleged sex acts. Mr. Epstein's conduct, however, is akin to consumer or purchaser behavior and should be outside the ambit of 18 U.S.C. § 1591. *See Fierro*, 2012 WL 13042630, at \*4 (“[T]he TVPA is inapplicable to individual purchasers of sex from trafficking victims...”).<sup>10</sup>
+
+---
+
+<sup>10</sup> While *Fierro* represents the law in this district, Mr. Epstein notes that there is a division of authority on the scope of § 1591. *See United States v. Jungers*, 702 F.3d 1066, 1068 (8th Cir. 2013). The defense respectfully submits that the *Fierro* court's approach to this issue is more persuasive and more consistent with the Congressional purpose to target commercial sex trafficking.
+
+### IV. Sixth Amendment
+
+Finally, in a case such as this one, which will likely involve voluminous discovery and is predicated on events allegedly occurring 14 or more years ago, it is critical to counsel's ability to provide effective assistance, as well as the defendant's ability to meaningfully contribute to his defense, that Mr. Epstein be permitted pretrial release. The Sixth Amendment "does not provide merely that a defense shall be made for the accused; it grants to the accused personally the right to make his defense. It is the accused, not counsel, who must be 'informed of the nature and cause of the accusation,' and who must be 'confronted with the witnesses against him,' and who must be accorded 'compulsory process for obtaining witnesses in his favor.'" Faretta v. California, 422 U.S. 806, 819 (1975). Given the unique circumstances of this case, Mr. Epstein's exercise of these important Constitutional rights would be materially impaired by his pretrial detention.
+
+# V. Conclusion
+
+Wherefore, for all of the foregoing reasons, Mr. Epstein respectfully submits that his conduct over the past 14 years proves that he poses no risk of flight or threat to the safety of the community. Even if the Court should have concerns to the contrary, there clearly exist a combination of conditions that would be sufficient to assure his presence as required and/or the safety of the community, including but not limited to some or all of the conditions proposed supra, or any other conditions the Court deems necessary and appropriate.
+
+Yours truly,
+
+Reid Weingars Steptoe & LLP (NYC) 1114 Avenue of the Americas New York, NY 10036 (202)-506-3900 Fax: (212)-506-3950 rweingarten@steptoe.com
+
+G. Weinberg (application for admission pro hac vice forthcoming) G. Weinberg, P.C. 20 Park Plaza, Suite 1000 Boston,. 02116 (617) 227-3700 Fax: (617) 338-9538 owlmgw@att.net
+
+Marc Allan Femich Law Office of Marc Femich 810 Seventh Ave Suite 620 New York, NY 10019 (212) 446-2346 Fax: (212) 446 2330 maf@fernichlaw.com

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marker2/court-us-v-epstein-cr/EFTA02824198/EFTA02824198.md

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+## UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+) ) UNITED STATES OF AMERICA ) ) v. ) ) JEFFREY EPSTEIN, ) Defendant ) ) ) CRIMINAL NO. 19-CR-490
+
+## DEFENDANT JEFFREY EPSTEIN'S MOTION FOR LEAVE TO FILE SUPPLEMENTAL FINANCIAL DISCLOSURE UNDER SEAL
+
+Defendant Jeffrey Epstein, by and through undersigned counsel, hereby respectfully moves this Honorable Court for leave to file under seal his supplemental financial disclosure. As noted in Mr. Epstein's bail submission, on advice of counsel, he has not yet provided a complete financial disclosure. Counsel's advice on this point was motivated by a desire to ensure the accuracy and completeness of the information provided to the Court. Mr. Epstein seeks leave to file his forthcoming supplemental disclosure under seal. As grounds and reasons therefor, Mr. Epstein relies on the exceptional amount of publicity that has been generated by this case, much of which relates specifically to his finances. Under the Bail Reform Act, financial information provided by a defendant to a pretrial services officer "shall be used only for the purposes of a bail determination and shall otherwise be confidential." 18 U.S.C. § 3153(cX1). Here, in the event Mr. Epstein is required to publicly file his financial statement, the information contained therein will inevitably be widely disseminated in the news media, contravening the statutory requirement of confidentiality.
+
+WHEREFORE, Mr. Epstein respectfully requests that this Honorable Court allow him leave to file his supplemental financial disclosure under seal.
+
+> Respectfully Submitted, Jeffrey Epstein By His Attorneys,
+
+/s/ Reid Weinestrten Reid Weinzars Steptoe & LLP (NYC) 1114 Avenue of the Americas New York, NY 10036 (202)-506-3900 rweingarten@steptoe.com
+
+Dated: July 11, 2019
+
+/s/ G. Weinbe G. Weinberg (application for admission pro hoc vice forthcoming) 20 Park Plaza, Suite 1000 Boston, El 02116 (617) 227-3700 owlmgw@att.net
+
+is/ Nlarc Allan lernich Marc Allan Femich Law Office of Marc Fernich 810 Seventh Ave., Suite 620 New York, NY 10019 (212) 446-2346 mafigfemichlaw.com
+
+## CERTIFICATE OF SERVICE
+
+I, Reid Weingarten, hereby certify that on this date, July 11, 2019, a copy of the foregoing document has been served via Electronic Court Filing system on all registered participants.
+
+/s/ Reid Weingarten

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marker2/court-us-v-epstein-cr/EFTA02824201/EFTA02824201.md

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+![](_page_0_Picture_1.jpeg)
+
+United States Attorney Southern District of New York
+
+The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007
+
+July 11, 2019
+
+## VIA ECF
+
+The Honorable Richard M. Berman United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007
+
+Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)
+
+Dear Judge Berman:
+
+The Government respectfully submits this letter in response to the defendant's motion for leave to file a supplemental financial disclosure under seal (the "Sealing Motion") in connection with his motion for pretrial release (the "Bail Motion").
+
+The Government takes no position on the defendant's application, but notes that as of this filing the Government still has not yet received any financial disclosure or information from the defense in connection with the defendant's application for bail. It is now more than three days following the defendant's initial presentment, more than seven hours after the defendant's deadline to file his Motion, and less than 24 hours before the Government's deadline to reply. There is no reason that the defendant need have waited until this evening to submit his Sealing Motion, and the Government cannot meaningfully respond to a Bail Motion that contains no material financial information, either under seal or otherwise.
+
+Accordingly, the Government respectfully requests that its deadline to respond to the defendant's Bail Motion be extended to at least 24 hours following the defendant's disclosure of any financial information upon which he intends to rely in connection with the Motion. Should
+
+Honorable Richard M. Berman United States District Judge July 11, 2019 Page 2
+
+that require adjourning the bail hearing, the Government respectfully requests that the hearing be moved to a date and time convenient for the Court and sufficient to permit the Court to review the Government's reply.
+
+Very truly yours,
+
+GEOFFjREY S. BERMAN Unite States Attorney
+
+By:
+
+Alex Rossmiller / Alison Moe / Maurene Comey Assistant United States Attorney Southern District of New York Tel: (212) 637-2415 / 2225 / 2324
+
+Cc: Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant

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marker2/court-us-v-epstein-cr/EFTA02824203/EFTA02824203.md

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+USDC SDNY  
+DOCUMENT  
+ELECTRONICALLY FILED  
+DOC #: \_\_\_\_\_ FOR THE  
+DATE FILED: 7/11/19
+
+ITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+> ) )
+
+UNITED STATES OF AMERICA )
+
+)
+
+v. )
+
+)
+
+JEFFREY EPSTEIN, ) Defendant )
+
+) ) MEMO ENDORSED
+
+## DEFENDANT JEFFREY EPSTEIN'S MOTION FOR LEAVE TO FILE SUPPLEMENTAL FINANCIAL DISCLOSURE UNDER SEAL
+
+Defendant Jeffrey Epstein, by and through undersigned counsel, hereby respectfully moves this Honorable Court for leave to file under seal his supplemental financial disclosure. As noted in Mr. Epstein's bail submission, on advice of counsel, he has not yet provided a complete financial disclosure. Counsel's advice on this point was motivated by a desire to ensure the accuracy and completeness of the information provided to the Court. Mr. Epstein seeks leave to file his forthcoming supplemental disclosure under seal. As grounds and reasons therefor, Mr. Epstein relies on the exceptional amount of publicity that has been generated by this case, much of which relates specifically to his finances. Under the Bail Reform Act, financial information provided by a defendant to a pretrial services officer "shall be used only for the purposes of a bail determination and shall otherwise be confidential." 18 U.S.C. § 3153(c)(1). Here, in the event Mr. Epstein is required to publicly file his financial statement, the information contained therein will inevitably be widely disseminated in the news media, contravening the statutory requirement of confidentiality.
+
+WHEREFORE, Mr. Epstein respectfully requests that this Honorable Court allow him leave to file his supplemental financial disclosure under seal.
+
+> Respectfully Submitted, Jeffrey Epstein By His Attorneys,
+
+/s/ Reid Weingarten Reid Weingarten Steptoe & LIT (NYC) 1114 AveniMe Americas New York, NY 10036 (202)-506-3900 rweingarten@steptoe.corn
+
+/s/ G. Weinber einberg (application for admission pro hew vice forthcoming) 20 Park Plaza, Suite 1000 Boston, pill02116 (617)22 00 owlmgw@att.net
+
+/s/ Marc Allan Fernich Marc Allan Fernich Law Office of Marc Fernich 810 Seventh Ave., Suite 620 New York, NY 10019 (212)446-2346 mafigfernichlaw.com
+
+Dated: July 11, 2019
+
+7
+
+CetAta mo r attAtok tot ctiort "pi to 4t. Komi "etre-444 do 6,4).4.4rs (\*.id \*pone? cov•tal) y 1:oo A Minty MI atti,
+
+SO OR D E
+
+Date: 7 n/ ' 494dt ib reteitiaM Richard M. Berman, U.S.D.J.

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marker2/court-us-v-epstein-cr/EFTA02824205/EFTA02824205.md

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+![](_page_0_Picture_2.jpeg)
+
+United States Attorney Southern District of New York
+
+VIA ECF
+
+tilea0 EV1DOPSED f
+
+The Honorable Richard M. Berman United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007
+
+The Silvio J. Mulls Building One Saint Andrew's Maw New York. New York 10007
+
+July 11, 2019
+
+Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)
+
+USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED:
+
+Dear Judge Berman:
+
+The Government respectfully submits this letter in response to the defendant's motion for leave to file a supplemental financial disclosure under seal (the "Scaling Motion") in connection with his motion for pretrial release (the "Bail Motion").
+
+The Government takes no position on the defendant's application, but notes that as of this filing the Government still has not yet received any financial disclosure or information from the defense in connection with the defendant's application for bail. It is now more than three days following the defendant's initial presentment, more than seven hours after the defendant's deadline to file his Motion, and less than 24 hours before the Government's deadline to reply. There is no reason that the defendant need have waited until this evening to submit his Sealing Motion, and the Government cannot meaningfully respond to a Bail Motion that contains no material financial information, either under seal or otherwise.
+
+Accordingly, the Government respectfully requests that its deadline to respond to the defendant's Bail Motion be extended to at least 24 hours following the defendant's disclosure of any financial information upon which he intends to rely in connection with the Motion. Should
+
+Honorable Richard M. Berman United States District Judge July 11, 2019 Page 2
+
+that require adjourning the bail hearing, the Government respectfully requests that the hearing be moved to a date and time convenient for the Court and sufficient to permit the Court to review the Government's reply.
+
+Very truly yours,
+
+GEOFTjREY S. BERMAN United tates Attorney
+
+By:
+
+Alex Rossmiller / Alison Moe / Maurene Comey Assistant United States Attorney Southern District of New York Tel: (212) 637-2415 / 2225 / 2324
+
+Cc: = Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant
+
+| <p>Application for extension of time denied. (Hard to imagine it would take the Govt anticipations to review submission.)</p> |                                                         |
+|-------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------|
+| <p>SO ORDERED: _____</p>                                                                                                      |                                                         |
+| Date: <u>7/12/19</u>                                                                                                          | <u>Richard M. Berman</u><br>Richard M. Berman, U.S.D.J. |

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marker2/court-us-v-epstein-cr/EFTA02824207/EFTA02824207.md

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+![](_page_0_Picture_1.jpeg)
+
+United States Attorney Southern District of New York
+
+The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007
+
+July 8, 2019
+
+#### VIA ECF
+
+The Honorable Henry Pitman United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007
+
+Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)
+
+Dear Judge Pitman:
+
+The Government respectfully submits this letter in advance of the bail hearing scheduled for July 8, 2019, in the above-captioned case. For the reasons set forth herein, the Court should order that the defendant be detained pending trial; he cannot meet his burden of overcoming the presumption that there is no combination of conditions that would reasonably assure his continued appearance in this case or protect the safety of the community were he to be released.
+
+As set forth below, the charges in this case are exceptionally serious: the defendant is alleged to be a serial sexual predator who preyed on dozens of minor girls over a period of years, and he now faces a potentially massive prison sentence predicated on substantial and multifaceted evidence of his guilt. In light of the strength of the Government's evidence and the substantial incarcemtory term the defendant would face upon conviction, there is an extraordinary risk of flight, particularly given the defendant's exorbitant wealth, his ownership of and access to private planes capable of international travel, and his significant international ties. Indeed, the arrest of the defendant occurred when he arrived in the United States on his private jet after having returned from a multi-week stay abroad.
+
+Finally, and as detailed herein, the Government has real concerns—grounded in past experience with this defendant—that if allowed to remain out on bail, the defendant could attempt to pressure and intimidate witnesses and potential witnesses in this case, including victims and their families, and otherwise attempt to obstruct justice. As a result, he poses both an acute danger to the community, including some of its most vulnerable members, and a significant risk of flight. The defendant thus cannot overcome the statutory presumption that detention is appropriate in this case, and the Court should order that he be detained pending trial.
+
+# BACKGROUND
+
+## A. Overview
+
+On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed indictment (the "Indictment") charging the defendant with one count of sex trafficking of minors, in violation of 18 U.S.C. § 1591, and one count of conspiracy to commit sex trafficking of minors, in violation of 18 U.S.C. § 371.
+
+As charged by the grand jury, the facts underlying the charges in the Indictment arise from a years-long scheme to sexually abuse underage girls. In particular, beginning in at least 2002, the defendant enticed and recruited dozens of minor girls to engage in sex acts with him, for which he paid the victims hundreds of dollars in cash.
+
+He undertook this activity in at least two different locations, including his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residence"). In both New York and Florida, the defendant perpetuated this abuse in similar ways. Victims were initially recruited to provide "massages" to the defendant, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts, including groping and direct or indirect contact with victims' genitals. The defendant paid his victims hundreds of dollars in cash for each separate encounter.
+
+Moreover, the defendant actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. He incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each additional girl they brought to him. In this fashion, the defendant created a vast network of underage victims for him to exploit, in locations including New York and Palm Beach.
+
+The defendant's victims were as young as 14 years old when he abused them. Many of his victims were, for various reasons, often particularly vulnerable to exploitation. The defendant intentionally sought out—and knew that he was abusing—minors. Indeed, in some instances, his victims expressly told him they were underage before or during the period in which he abused them.
+
+In creating and maintaining a network of minor victims whom he abused, the defendant worked with others, including employees and associates who facilitated his exploitation of minors by, among other things, contacting victims and scheduling their sexual encounters with the defendant, both in New York and in Florida.
+
+# B. The Defendant
+
+Jeffrey Epstein designed, financed, and perpetrated this scheme, both as its main participant and through his direction of others, including certain of his employees, to further facilitate his rampant abuse of underage girls.
+
+As has been widely reported, the defendant is extraordinarily wealthy, and he owns and maintains luxury properties and residences around the world, including in Manhattan, New York; Palm Beach, Florida; Stanley, New Mexico; and Paris, France. Additionally, Epstein owns a private island in the U.S. Virgin Islands which, as noted above, is believed to be his primary residence in the United States. His mansion in Manhattan alone—a multi-story townhouse reported to be one of the largest single residences in all of Manhattan, which previously housed a school and which he owns through an LLC—has been valued at approximately \$77 million. Entities controlled by the defendant also own at least two private jets in active service, at least one of which is capable of intercontinental travel.
+
+As described further below, the defendant possesses three active United States passports, and his international connections and travels are extensive. For example, in addition to maintaining a residence in Paris, France, as described above, in the past 18 months alone, the defendant has traveled abroad, via private jet, either into or out of the country on approximately more than 20 occasions.
+
+# C. The Prior Florida Investigation
+
+In or about 2005, the defendant was investigated by local police in Palm Beach, Florida, in connection with allegations that he had committed similar sex offenses against minor girls. The investigation ultimately also involved federal authorities, namely the U.S. Attorney's Office for the Southern District of Florida ("SDFL") and the FBI's Miami Office, and included interviews with victims based in the Palm Beach area, including some of the alleged victims relevant to Count One of the instant Indictment.'
+
+In fall 2007, the defendant entered into a non-prosecution agreement with the SDFL in connection with the conduct at issue in that investigation, which the non-prosecution agreement identified as including investigations into the defendant's abuse of minor girls in the Palm Beach area. The Southern District of New York was not a signatory to that agreement, and the defendant was never charged federally? In June 2008, the defendant pled guilty in state court to one count of procuring a person under the age of 18 for prostitution, a felony, and one count of solicitation of prostitution, a felony. As a result, the defendant was designated as a sex offender with registration requirements under the national Sex Offender Registration and Notification Act.
+
+The non-prosecution agreement, further discussed below, was entered into at the conclusion of the SDFL investigation and did not purport to cover any victims outside of the State of Florida. As noted above, the instant Indictment expressly alleges the existence of dozens of victims who were abused in this District in addition to dozens of victims who were abused in Florida.
+
+<sup>2</sup> While beyond the scope of a bail hearing, as discussed further below, it is well-established in the Second Circuit that absent an express provision to the contrary in the agreement, one District is not bound by the terms of an agreement entered into between a defendant and a U.S. Attorney's Office in another district. See page 6, infra.
+
+#### ARGUMENT
+
+#### I. Applicable Law
+
+Under the Bail Reform Act, 18 U.S.C. §§ 3141 et seq., federal courts are empowered to order a defendant's detention pending trial upon a determination that the defendant is either a danger to the community or a risk of flight. 18 U.S.C. § 3142(e) ("no condition or combination of conditions would reasonably assure the appearance of the person as required and the safety of any other person and the community"). A finding of risk of flight must be supported by a preponderance of the evidence. See, e.g., United States v. , 823 F.2d 4, 5 (2d Cir. 1987); United States v. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by clear and convincing evidence. See, e.g., United States v. Ferranti, 66 F.3d 540, 542 (2d Cir. 1995); Chimurenga, 760 F.2d at 405. In addition, a court may also order detention if there is "a serious risk that the [defendant] will. . . attempt to obstruct justice, or . . . to threaten, injure, or intimidate, a prospective witness or juror." 18 U.S.C. § 3142(f)(2XB); see also United States v. 837 F.2d 48 (2d Cir. 1988).
+
+The Bail Reform Act lists four factors to be considered in the detention analysis: (1) the nature and circumstances of the crimes charged; (2) the weight of the evidence against the person; (3) the history and characteristics of the defendant, including the person's "character . . . [and] financial resources"; and (4) the seriousness of the danger posed by the defendant's release. See 18 U.S.C. § 3142(g). Evidentiary rules do not apply at detention hearings and the government is entitled to present evidence by way of proffer, among other means. See 18 U.S.C. § 3142(f)(2); see also United States v. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000) (government entitled to proceed by proffer in detention hearings); Ferranti, 66 F.3d at 542 (same); United States v. Martir, 782 F.2d 1141, 1145 (2d Cir. 1986) (same).
+
+Where a judicial officer concludes after a hearing that "no condition or combination of conditions will reasonably assure the appearance of the person as required and the safety of any other person and the community, such judicial officer shall order the detention of the person before trial." 18 U.S.C. § 3142(e)(1). Additionally, where, as here, a defendant is charged with committing an offense involving a minor victim under 18 U.S.C. § 1591, it shall be presumed, subject to rebuttal, that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community. 18 U.S.C. § 3 I42(e)(3XE).
+
+### II. Discussion
+
+The defendant should be detained pending trial. For the reasons set forth below, it is difficult to overstate the risk of flight and danger to the community if the defendant is released, and for those reasons, the defendant cannot overcome the statutory presumption in favor of detention in this case.
+
+# A. The Defendant Poses an Extreme Flight Risk
+
+Each of the relevant factors to be considered as to flight risk — the nature and circumstances of the offense, the strength of the evidence, and the history and characteristics of the defendant counsel strongly in favor of detention.
+
+# I. The Nature and Circumstances of the Offense and the Strength of the Evidence
+
+The "nature and circumstances" of this offense plainly favor detention. 18 U.S.C. § 3142(g)(1) (specifically enumerating "whether the offense. . . involves a minor victim" as a factor in bail applications). Indeed, the crime of sex trafficking of a minor is so serious that for a defendant charged with that offense, there is a presumption that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community. 18 U.S.C. § 3142 (e)(3)(E). Here, as specified in the Indictment, the defendant's conduct was committed serially, over a period of years, and affected dozens of victims.
+
+The seriousness of the charge is also reflected in the penalties the defendant faces, which include up to 45 years of incarceration for Counts One and Two of the Indictment.' As the Second Circuit has noted the possibility of a severe sentence is a significant factor in assessing the risk of flight. See 823 F.2d at 7; see also United States v. Cisneros, 328 F.3d 610, 618 (10th Cir. 2003) (defendant was a flight risk because her knowledge of the seriousness of the charges against her gave her a strong incentive to abscond); United States v. Townsend, 897 F.2d 989, 995 (9th Cir. 1990) ("Facing the much graver penalties possible under the present indictment, the defendants have an even greater incentive to consider flight."). Here, the defendant is facing a statutory maximum of decades in prison. Even in the absence of means—which, as discussed in detail below, the defendant has in abundance—this fact alone would provide a compelling incentive for anyone to fail to appear. It is particularly compelling for a defendant who is 66 years old and therefore faces the very real prospect of spending the rest of his life in prison if convicted.
+
+The likelihood of a substantial period of incarceration is buttressed by the strength of the evidence. As set forth in the Indictment, the evidence in this case is strong. The Indictment alleges that the defendant sexually abused dozens of minor victims, and the conspiracy count lists numerous overt acts committed in furtherance of the defendant's crimes.'
+
+<sup>3</sup> The current penalties for violations of 18 U.S.C. § 1591 include a 10 year mandatory minimum sentence. However, that punishment was created through an amendment to the statute in 2006. The penalty for a violation of Section 1591 during the period charged in the Indictment, and therefore relevant here, was a maximum of 40 years' imprisonment.
+
+<sup>4</sup> With respect to the evidence in this case, the Court should start its analysis by accepting that the Indictment is sufficient, on its own, to establish probable cause that the defendant committed the crimes of sex trafficking and sex trafficking conspiracy. Contreras, 776 F.2d at 54. ("Were an evidentiary hearing addressing the existence of probable cause required in every § 3142(e) case in which an indictment had been filed, the court would spend scarce judicial resources considering that which a grand jury had already determined, and have less time to focus on the application of
+
+Multiple victims, including several specified in the Indictment, have provided information against the defendant. That information is detailed, credible, and corroborated, in many instances, by other witnesses and contemporaneous documents, records and other evidence—including, as further detailed below, evidence from a search of the New York Residence on the night of the defendant's arrest that reflects an extraordinary volume of photographs of nude and partially-nude young women or girls. Such corroborating evidence also includes documents and other materials, such as contemporaneous notes, messages recovered from the defendant's residence that include names and contact information for certain victims, and call records that confirm the defendant and his agents were repeatedly in contact with various victims during the charged period. Put simply, all of this evidence — the voluminous and credible testimony of individuals who were sexually abused by the defendant as minors, each of whom are backed up by other evidence — will be devastating evidence of guilt at any trial in this case and weighs heavily in favor of detention.
+
+Finally, it bears noting that neither the age of the conduct nor the defendant's previous nonprosecution agreement ("NPA") with a different federal district pose any impediment to his conviction. As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. § 3283, which was amended in 2003 to extend the limitations period for conduct that was timely as of the date of the amendment, to any time during the lifetime of the minor victim. See United States v. Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because Congress extended the statute of limitations for sex offenses involving minors during the time the previous statute was still running, the extension was permissible); United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL 4043140, at "1 (S.D.N.Y. Aug. 9, 2018) (same).
+
+Moreover, with respect to the NPA, that agreement, to which the Southern District of New York was not a party, which by its express language pertained exclusively to the SDFL investigation, and which did not purport to bind any other Office or District, does not preclude prosecution in this District for at least two reasons. First, it is well settled in the Second Circuit that "a plea agreement in one U.S. Attorney's office does not, unless otherwise stated, bind another." United States v. Frisco, 391 F. App'x 920, 921 (2d Cir. 2010) ("A plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.") (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). This is true even if the text of the agreement purports to bind "the Government." See Annabi, 771 F.2d at 672. This analysis similarly extends to a non-prosecution agreement. See United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) ("Defendant's argument, in effect, is that unless there is an explicit statement to the contrary, it is presumed that a non-prosecution agreement binds offices of the United States Attorney that are not parties to the agreement. This position is at odds with the law in this Circuit, which presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively establish that a more expansive interpretation was contemplated.") (citing Annabi, 771 F.2d at 672). Second, the Indictment charges conduct not covered by the NPA, namely
+
+the presumptions and the § 3142(g) factors in deciding whether the defendant should be detained.").
+
+conduct that occurred in New York. The prior NPA included a list of several dozen victims identified in the prior investigation, all of whom were abused in the State of Florida, and none of whom are a part of the conduct charged in Count Two of the instant Indictment.
+
+Each of these factors—the seriousness of the allegations, the strength of the evidence, and the possibility of lengthy incarceration—creates an extraordinary incentive to flee. And as further described below, the defendant has the means and money to do so.
+
+### 2. The Characteristics of the Defendant
+
+The history and characteristics of the defendant also strongly support detention. The defendant is extraordinarily wealthy and has access to vast financial resources to fund any attempt to flee. Indeed, his potential avenues of flight from justice are practically limitless.
+
+As the defendant acknowledged in his most recent New York State sex offender registration, he has six residences, including two in the U.S. Virgin Islands (including his own private island), and one each in Palm Beach, Florida; Paris, France; New York, New York; and Stanley, New Mexico. The most recent estimated value of the defendant's New York City mansion alone is more than \$77 million. The most recent tax-assessed value of the defendant's Palm Beach estate is more than \$12 million. The defendant's primary residence is a private island in the U.S. Virgin Islands, a place where any sort of meaningful supervision would be all but impossible.
+
+Moreover, the defendant has access to innumerable means to flee. His sex registration documentation of "current vehicles" lists no fewer than 15 motor vehicles, including seven Chevrolet Suburbans, a cargo van, a Range Rover, a Mercedez-Benz sedan, a Cadillac Escalade, and a Hummer II. These cars are registered in various states and territories including the Virgin Islands, New York, Florida, and New Mexico. The defendant also has access to two private jets, giving him the ability to leave the country secretly and on a moment's notice and to go virtually anywhere he wants to travel. He is a very frequent international traveler and regularly travels to and from the United States by private plane. In particular, between January 1, 2018, and the present, U.S. Customs and Border Patrol has logged approximately more than 20 flights in which Epstein was traveling to or from a foreign country. Indeed, he was arrested at Teterboro Airport arriving on just such a private international flight after having spent approximately three weeks abroad. Extensive international travel of this nature further demonstrates a significant risk of flight. See, e.g., United States v. , 384 F. Supp. 2d 32, 36 (D.D.C. 2005). There can be no assurance that, upon release, the defendant would suddenly lack access to such means of travel.
+
+Finally, the defendant has no meaningful ties that would keep him in this country. The defendant has no known immediate family. He is not married and has no children. He has friends and associates worldwide, as demonstrated by his extensive international travel, and his professional obligations, if any, can and seemingly are plainly capable of being handled by the defendant remotely. Simply put, there would be no meaningful reason for the defendant to remain in the country, while he would have every incentive (and every resource needed) to flee.
+
+Nor would home confinement with electronic monitoring reasonably assure the defendant's presence as required. At best, home confinement with electronic monitoring would
+
+merely reduce his head start should he decide to flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at •1 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application for bail in part because home detention with electronic monitoring "at best . . . limits a fleeing defendant's head start"); see also United States v. Casteneda No. 18 Cr. 047, 2018 WL 888744, at \*9 (N.D. Cal. Feb. 2018) (same); United States v. 384 F.Supp.2d 32, 41 (D.D.C. 2005) (same); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at •3 (E.D.N.Y. Oct. 10, 2002) (same).
+
+Finally, there can be little doubt that the defendant is in a position to abandon millions of dollars in cash and property securing any potential bond and still live comfortably for the rest of his life. These resources, and the ease with which the defendant could flee and live outside the reach of law enforcement—particularly considering his vast wealth and lack of meaningful ties to this District—make the risk of flight exceptionally high in this case, particularly when considered in conjunction with the strength of the government's case and the lengthy sentence the defendant could receive if convicted.
+
+### B. The Defendant Poses a Risk of Danger to the Community and of Engaging in Obstruction of Justice
+
+The release of the defendant, under any conditions, would pose a significant threat to the community and to the ongoing investigation.
+
+As described above, where there is probable cause to believe that an individual has committed an offense under 18 U.S.C. § 1591, it is presumed that no condition or combination of conditions can reasonably assure the safety of the community. 18 U.S.C. § 3142(eX3). Here, not only is the defendant charged with very serious sex crimes against minors, he has already previously admitted to—and been convicted of—engaging in related conduct. Specifically, in June 2008, the defendant pled guilty in state court to one count of procuring a person under the age of 18 for prostitution, a felony, and he currently is a registered sex offender, under classification level three in New York—defined as presenting a "high" risk of committing another sex crime and harm to the community. While the conduct presently alleged does not post-date the 2008 conviction, it nevertheless underscores the risk he poses to the community if released.
+
+Additionally, and in connection with the investigation of the defendant's offense in Florida, there were credible allegations that the defendant engaged in witness tampering, harassment, or other obstructive behaviors. In fact, according to publicly-filed court documents, there were discussions between prosecutors and the defendant's then-counsel about the possibility of the defendant pleading guilty to counts relating to "obstruction," as well as "harassment," with reference to 18 U.S.C. § 1512, which criminalizes "[t]ampering with a witness, victim, or informant." For example, in a communication from the defendant's then-counsel to prosecutors in SDFL, his counsel set forth a possible factual proffer that included statements that the defendant had "attempted to harass both [redacted] delay and hinder their receipt of a [redacted] to attend an official proceeding" and that the defendant "in particular, changed travel plans and flew with both [redacted] to the United States Virgin Islands rather than to an airport in New Jersey in order to attempt to delay their receipt of what Mr. Epstein expected to be a [redacted]" and "further verbally
+
+harassed both [redacted] in connection to this attempt to delay their voluntary receipt of process all in violation of 18 USC 1512(d)(1)."5 Doe v. United States, 08 Civ. 80736 (S.D. Fla.), Dkts. 361 at 3-4, 361-7 through 361-11. In addition to 18 U.S.C. § 1512(d), prosecutors also proposed that the defendant could plead guilty to 18 U.S.C. § 403, that is, a knowing or intentional violation of the privacy protection of child victims and child witnesses, to which the defendant's thencounsel replied: "Already thinking about the same statutes." Id. Dkt. 361-11. They also discussed a possible obstruction plea that "could rely on the incident where Mr. Epstein's private investigators followed [redacted] father, forcing off the road." Id. Dkt. 361-10.
+
+The defendant's apparent previous willingness to obstruct a federal investigation, harass or tamper with witnesses, and hire private investigators that loreled] off the road" the father of an individual relevant in the investigation is alarming. It should especially weigh on the Court's consideration here because the defendant was apparently willing to take those steps before even being charged and thus facing federal indictment; the incentive to interfere in the Government's case here, where an Indictment has been returned, is exponentially greater. And as discussed above, the defendant has nearly limitless means to do so.
+
+Finally, despite having been previously convicted of a sex offense involving an underage victim, the defendant has continued to maintain a vast trove of lewd photographs of young-looking women or girls in his Manhattan mansion. In a search of the New York Residence on the night of his arrest, on July 6-7, 2019, pursuant to judicially-authorized warrants, law enforcement officers discovered not only specific evidence consistent with victim recollections of the inside of the mansion, further strengthening the evidence of the conduct charged in the Indictment, but also at least hundreds—and perhaps thousands-of sexually suggestive photographs of fully- or partiallynude females. While these items were only seized this weekend and are still being reviewed, some of the nude or partially-nude photographs appear to be of underage girls, including at least one girl who, according to her counsel, was underage at the time the relevant photographs were taken. Additionally, some of the photographs referenced herein were discovered in a locked safe, in which law enforcement officers also found compact discs with hand-written labels including the following: "Young [Name] + [Name]," "Mist nudes 1," and "Girl pics nude." The defendant, a registered sex offender, is not reformed, he is not chastened, he is not repentant,' rather, he is a continuing danger to the community and an individual who faces devastating evidence supporting deeply serious charges.
+
+<sup>5</sup> The redactions above are contained in the publicly filed version of the quoted document.
+
+<sup>6</sup> See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, N.Y. Post (2011) ("I'm not a sexual predator, I'm an "offender," the financier told The Post yesterday. 'It's the difference between a murderer and a person who steals a bagel."); Philip Weiss, The Fantasist, New York Magazine (2007) ("'It's the Icarus story, someone who flies too close to the sun,' I said. 'Did Icarus like massages?' Epstein asked.").
+
+#### CONCLUSION
+
+As set forth above, in this case, the risk of flight in this case is extraordinarily real. The defendant is extremely wealthy, has extensive foreign contacts, and is charged with serious offenses that carry a potential statutory sentence of up to 45 years' imprisonment—even a fraction of which could result in the defendant, who is 66 years old, spending the rest of his life in jail. In sum, the defendant's transient lifestyle, his lack of family or community ties, his extensive international travel and ties outside the country, and his vast wealth, including his access to and ownership of private planes, all provide the defendant with the motive and means to become a successful fugitive. Further, the nature of the offenses he is alleged to have perpetrated—the abuse dozens of underage, vulnerable girls—along with his demonstrated willingness to harass, intimidate and otherwise tamper with victims and other potential witnesses against him, render his dangerousness readily apparent.
+
+Accordingly, the Government respectfully submits that the defendant cannot and will not be able to meet his burden of overcoming the strong presumption in favor of detention, that there are no conditions of bail that would assure the defendant's presence in court proceedings in this case or protect the safety of the community, and that any application for bail should be denied.
+
+Very truly yours,
+
+GEOF REY S. BERMAN United States Attorney
+
+By:
+
+Alex Rossmiller / Alison Moe / Maurene Comey Assistant United States Attorney Southern District of New York Tel: (212) 637-2415 / 2225 / 2324
+
+Cc: Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant Hon. Richard M. Berman, United States District Judge

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marker2/court-us-v-epstein-cr/EFTA02824217/EFTA02824217.md

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+The vehicle is registered to IIIIIIII I received other phone calls from MIN and who advised they were able to acquire the private investigators license plate information. The subject following them was again driving very aggressively and caused to run off the road. stated the vehicle is a IIIII Chevy bearing Florida tag of Florida. is employed with Investigations from Florida. is a licensed Private Investigator in the state of Florida.
+
+Case No
+
+Entered By.:
+
+(Continued
+
+On 2006, I received several phone calls throughout the day from who stated he had been followed aggressively by a private investigator. stated that as he drove to and from work and running errands throughout the county, the same vehicle was behind him running other vehicles off the road in an attempt not to lose sight of 's vehicle.
+
+I explained to him as Mr. Epstein had retained new legal council it was possible it would be new private investigators following him to observe his daily activities. I also ex lained to him that there was a meeting scheduled with and at scheduled on I attempted to call to inform private investigators following however;
+
+Since the discovery of the threat made against one of the victims in this case , I re ested subpoenas for all calls made to and received from 13 during the month of March 2006 for her cell hone and home phone. I had confirmed with Florida State he exact dates of Spring Break — The Spring Break was from March 4, 2006 through March 12, 2006. I received a subpoena from with all calls made during the month of . I reviewed the 989 calls made and received during the month of March 2006. I observed oal, 2006, made and received thirty five calls during that day.
+
+| Ili.               | Time        | Seconds | In/Out To/From |
+|--------------------|-------------|---------|----------------|
+|                    | 06 11:03 AM | 492     | Outbound       |
+| IIIIII-06 11:16 AM |             | 6       | Inbound        |
+| IIIIII-06 11:22 AM |             | 887.2   | Inbound        |
+| IIIII-06           | 11:37 AM    | 48      | Outbound       |
+| IIIIIII-06         | 11:39 AM    | 28.2    | Inbound        |
+| IIIIIE06 12:02 PM  |             | 727.2   | Inbound        |
+
+The table reflects the date of the calls, time of day (SST), duration
+
+Case No. : [REDACTED] (Continued)  
+of call in seconds, inbound or outbound calls and calls made to or from [REDACTED] phone. On [REDACTED], 2006, at 11:03 am, [REDACTED] made a call to the victim [REDACTED] which lasted 492 seconds (8 minutes and 2 seconds). The victim then returned the call at 11:16 am which lasted 6 seconds. The victim then made contact with [REDACTED] at 11:22 am for 877.2 seconds (14 minutes and 6 seconds). These sequences of calls were consistent with what the victim had described to me on the date of the intimidation. Immediately after speaking with the victim, [REDACTED] makes a call to [REDACTED], Epstein's assistant, which lasts for forty-eight seconds. A call is then immediately received, a telephone number registered to a Corporation affiliated with Jeffrey Epstein located at 457 Madison Ave in New York. An extensive computer check revealed 457 Madison Ave is a business address in which Epstein has his corporations assigned to. Epstein had corporation attorney, [REDACTED], register the businesses and register himself as an agent. I also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Financial Strategy Group registered to this same address. Finally, a third call is received by [REDACTED] at 12:02 pm from the same corporate number which lasts 12 minutes and 1 second. It should be noted that there is no further contact with either the victim during the month of [REDACTED] of 2006. I also noted that there was no further contact with [REDACTED] or Jeffrey Epstein during the remainder of the month of [REDACTED] 2006.
+
+On [REDACTED], 2006, [REDACTED] telephoned me to inform me of the meeting that occurred with Atty. [REDACTED] and [REDACTED] reference this case. [REDACTED]
+
+Inv Continues.
+
+![](_page_1_Picture_17.jpeg)

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marker2/court-us-v-epstein-cr/EFTA02824219/EFTA02824219.md

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+ate: 7/19/06  
+ime: 15:01:37
+
+PALM BEACH POLICE DEPARTMENT  
+Incident Report
+
+Page: 82  
+Program: CMS301L
+
+![](_page_0_Picture_117.jpeg)
+
+\*\*\*\*\* N A R R A T I V E # 42 \*\*\*\*\*  
+Reported By: RECAREY, [REDACTED] 4/14/06  
+Entered By.: ALTOMARO, NICKIE A. 4/18/06
+
+The Grand Jury Subpoenas were personally served to the individuals they were issued to. On April 5, 2006, at approximately 7:30 p.m., I personally served the parents of [REDACTED] who had informed me that the private investigators were still photographing the family. On April
+
+Date: 7/19/06  
+Ime: 15:01:37
+
+PALM BEACH POLICE DEPARTMENT  
+Incident Report
+
+Page: 83  
+Program: CMS301L
+
+Date No. : 1-05-000368
+
+(Continued)
+
+10, 2006, at approximately 2:30 p.m., I served [REDACTED] at her residence in [REDACTED]. The subpoena was given to her mother, [REDACTED].
+
+I learned through one of the victims [REDACTED] that she was personally contacted through a source that has maintained contact with Epstein. The source assured [REDACTED] she would receive monetary compensation for her assistance in not cooperating with law enforcement. [REDACTED] also stated she was told, "Those who help him will be compensated and those who hurt him will be dealt with." I told [REDACTED] that tampering with a witness/victim is an arrestable offense and very serious. I asked her who approached her during this encounter. [REDACTED] originally was reluctant to provide the name of the person who approached her to offer her not to testify because she felt they were still friends.
+
+On April 11, 2006, Det Dawson and I traveled to Tallahassee, Florida and met with the victim, [REDACTED] identified [REDACTED] W/F, [REDACTED], as the person who approached her in [REDACTED]. Palm Beach while she was home during Spring Break in March 2006. [REDACTED] also stated she did not want to pursue the intimidation charges on [REDACTED] was concerned that the defense attorney was given a copy of the report as certain things she had told me in confidence were repeated to her by [REDACTED]
+
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marker2/court-us-v-epstein-cr/EFTA02824221/EFTA02824221.md

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+
+United States Attorney Southern District of New York
+
+The Silvio J. Motto Building One Saint Andrew's Pla:a New York. New York 10007
+
+July 12, 2019
+
+#### VIA ECF
+
+The Honorable Richard M. Berman United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007
+
+Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)
+
+Dear Judge Berman:
+
+The Government respectfully submits this letter in response to the defendant's Motion for Pretrial Release (the "Release Motion"), dated July 11, 2019 (Dkt. 6), and in further support of its Memorandum in Support of Detention (the "Detention Memo"), submitted to Magistrate Judge Pitman on July 8, 2019, which is attached hereto and incorporated herein (Ex. A).
+
+### PRELIMINARY STATEMENT
+
+The defendant is a serial sexual predator who is charged with abusing underage girls for years. A grand jury has returned an indictment alleging that he sexually exploited dozens of minors, including girls as young as 14 years old, in New York and Florida. To this day, he is a registered sex offender designated by New York State in the highest category of risk to reoffend, despite unsuccessfully attempting to have that classification lowered. And any doubt that the defendant is unrepentant and unreformed was eliminated when law enforcement agents discovered hundreds or thousands of nude and seminude photographs of young females in his Manhattan mansion on the night of his arrest, more than a decade after he was first convicted of a sex crime involving a juvenile.
+
+The defendant also faces substantial evidence of his guilt, founded on the corroborated testimony of numerous victims, and this case presents the very real possibility that he will go to prison for the rest of his life. The defendant has at his disposal a vast fortune, the details of which remain largely concealed from the Court. He also has a history of obstruction and manipulation of witnesses, including, as detailed herein, as recently as within the past year, when media reports about his conduct reemerged. And he continues to show a shocking lack of understanding of the gravity of the harm he has perpetrated, including through the minimization of his conduct and casual disparagement of victims in his arguments.
+
+Against this backdrop of significant—and rapidly-expanding—evidence, serious charges, and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant
+
+law, seeks to diminish and demean the harm caused to the many victims of the defendant's appalling sexual abuse, and utterly fails to meet its burden of rebutting the presumption that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community. Rather than even attempting to address the grave risks of releasing a defendant with extraordinary financial resources and a history of abusing minors, the defendant instead proposes a bail package that amounts to little more than a barely-secured bond masquerading as a 14-point plan. The Court should reject the defendant's application and order him detained pending trial.
+
+Among other things, the proposed bail package contemplates the defendant pledging as the principal security a property that has already been identified by the Government as subject to forfeiture upon the defendant's conviction, and which therefore is of no value as collateral. His proposed global waiver of extradition is unenforceable, and even if enforceable would be little comfort to victims forced to wait additional years while the defendant is located and returned to this country. The promise to "deregister or otherwise ground" his private jet is meaningless given his wealth and ability to easily secure other means of travel. The two co-signers he proposes only further highlight his minimal community ties, including his lack of any family in or near the District. Electronic monitoring would merely give the defendant less of a head start in fleeing and does not guard against the risk of him endangering victims in the very home where he has continued to hoard nude images of young women and girls. And the private security force he proposes to guard his gilded cage, a proposal already rejected by this Court in similar circumstances, simply reinforces the obvious fact that the defendant should be housed where he can be secured at all times: a federal correctional center.
+
+The defendant faces a presumption of detention, Pretrial Services has recommended detention, and victims of the defendant seek his detention. Because there are no set of conditions short of incarceration that can reasonably assure the appearance of the defendant or reasonably protect the community from the dangers he poses if released, the Court should order him detained.
+
+# BACKGROUND
+
+As previously set forth, a federal grand jury in this District returned an indictment (the "Indictment") charging the defendant with violating Title 18, United States Code Section 1519, and conspiracy to commit the same.
+
+As charged by the grand jury, the facts giving rise to those counts involve a years-long scheme to sexually abuse underage girls. Specifically, the defendant enticed and recruited dozens of minor girls to engage in sex acts with him, for which he paid the victims hundreds of dollars in cash, in at least two different states. Victims were initially recruited to provide "massages" to the defendant, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts, including groping and direct or indirect contact with victims' genitals. To perpetuate this exploitation of underage girls, the defendant actively encouraged certain victims to recruit additional girls to be similarly sexually abused. He paid these victim-recruiters hundreds of dollars for each additional girl they brought to him, creating a network of underage victims for him to exploit in New York and Palm Beach.
+
+The defendant, through counsel, continues to evidence a complete lack of appreciation for the gravity of the offenses with which he is charged.' As an initial matter, there can be no plausible suggestion that the allegations against the defendant involve isolated or aberrational conduct; they involve repeated, regular acts of sexual abuse committed over a period of many years. And following the defendant's prior conviction, as described previously by the Government, the defendant continued to maintain at least hundreds and possibly thousands of nude photos of young subjects. The defendant's victims in this case, often particularly vulnerable girls, were as young as 14 years old when he abused them. The defendant knew he was abusing minors, including because victims told him directly they were underage. And he preyed on his victims habitually and repeatedly—day after day, month after month, year after year.
+
+The defense calls these disturbing alleged acts "simple prostitution."' Mag. Tr. 12:12; see also D. Tr. at 6:15-19 ("This is basically the Feds today . . . redoing the same conduct that was investigated 10 years ago and calling it, instead of prostitution, calling it sex trafficking"). That characterization is not only offensive but also utterly irrelevant given that federal law does not recognize the concept of a child prostitute—there are only trafficking victims—because a child cannot legally consent to being exploited. Defense counsel's repeated assertion that the Government's case is infirm because no threats or coercion are alleged—e.g., Mag. Tr. at 12 ("There was no coercion. There were no threats. There was no violence."), 17 ("there was no coercion. There was no intimidation. There is no deception."); Release Motion at 2 ("There are no allegations . . . that he forced, coerced, defrauded, or enslaved anybody . . . .")—is equally irrelevant because the offense with which the defendant has been charged requires no such proof. See, e.g., United States v. Afyare, 632 F. App'x 272, 278 (6th Cir. 2016) ("We hold that § 1591(a) criminalizes the sex trafficking of children (less than 18 years old) with or without any force, fraud, or coercion, and it also criminalizes the sex trafficking of adults (18 or older), but only if done by force, fraud, or coercion.").
+
+Far more important, the defense has already effectively conceded that the Government will be able to present evidence of the actual primary elements of the charged offense—i.e., that the defendant engaged in sex acts for money with girls he knew were underage. See Release Motion at 2. On this record, the Government agrees with Pretrial Services that the defendant should be detained pending trial. He poses a tremendous risk of flight and a danger to the community, and he cannot overcome the statutory presumption in favor of detention in this case.
+
+<sup>&#</sup>x27; Such arguments are unsurprising from a defendant who previously compared himself to a "person who steals a bagel" or a tragic mythical figure. See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, N.Y. Post (2011) ("`I'm not a sexual predator, I'm an "offender," the financier told The Post yesterday. `It's the difference between a murderer and a person who steals a bagel.'"); Philip Weiss, The Fantasist, NY Magazine (2007) ("It's the Icarus story, someone who flies too close to the sun,' I said. `Did Icarus like massages?' Epstein asked.").
+
+<sup>2</sup> "Mag. Tr." refers to the transcript of the hearing before Magistrate Judge Pitman on July 8, 2019; "D. Tr." refers to the transcript of the hearing before this Court on July 8, 2019.
+
+#### ARGUMENT
+
+The Government respectfully submits that the defendant cannot overcome the statutory presumption in favor of detention in this case for the following reasons, among others:
+
+## I. Victims Seek Detention
+
+Pursuant to the Crime Victims' Rights Act ("CVRA"), a crime victim has the right to be reasonably heard at certain public proceedings in the district court, including proceedings involving release. 18 U.S.C. § 3771(a)(4). Consistent with that requirement, the Government has been in contact with victims and counsel identified through this investigation in connection with the argument regarding bail.
+
+Multiple victims and/or their counsel have asked the Government to seek detention (and to inform the Court of their views in that respect) for multiple reasons. First, they believe that the defendant's continued detention is necessary under the CVRA's right to be reasonably protected from the accused. 18 U.S.C. § 3771(aX1). They have specifically conveyed to the Government that they would be fearful for their safety if the defendant were released. For the reasons articulated herein, the Government believes those concerns to be well-founded.
+
+Additionally, certain victims have asked the Government to advise the Court that they are specifically concerned about the defendant's proposal to be released even if under conditions that included home detention and full-time private guards. They believe it would be unfair to victims of a wealthy defendant, like Epstein, if he were to be given greater freedoms than others would be in similar circumstances, and that such an arrangement would be inconsistent with their rights. They specifically asked the Government to advise the Court that they believed such an arrangement could result in harassment and abuse by the defendant. 3
+
+# II. The Defendant's Proposal Does Nothing to Mitigate His Flight Risk
+
+Each of the relevant factors to be considered as to flight risk—the nature and circumstances of the offense, the strength of the evidence, and the history and characteristics of the defendant counsel strongly in favor of detention, and the defendant's proposed package would do nothing whatsoever to mitigate those risks.
+
+# A. Defendant Proposes No Infringement Upon His Ability to Use his Vast Wealth to Flee
+
+It might not be immediately apparent to a reader of the Release Motion that the defendant is extravagantly wealthy and worth, according to records relating to the defendant recently obtained by the Government from a financial institution ("Institution-1"), more than \$500 million.
+
+<sup>3</sup> The Government is aware of at least one additional attorney for a victim who has publicly stated that her client supports the pretrial detention of the defendant. The Government is unaware of any victim who has expressed support for the defendant being granted pretrial release on bail.
+
+Indeed, while the defendant has still not filled out a financial affidavit, under penalty of perjury, in connection with his application for bail, his token effort to account for his finances makes painfully clear the need for detention. The defendant reports having an extraordinary amount of money in both total assets and cash or cash-equivalent holdings. And while the defendant repeatedly represents in his Release Motion that his assets are "in the United States," there is absolutely nothing in the defendant's minimal financial submission to verify that.
+
+Indeed, and as discussed further below, even assuming the defendant's assets are presently in the United States, nothing in the proposed package would prevent the defendant from transferring liquid assets out of the country quickly and in anticipation of flight or relocation. The defendant is an incredibly sophisticated financial actor with decades of experience in the industry and significant ties to financial institutions and actors around the world. He could easily transfer funds and holdings on a moment's to places where the Government would never find them so as to ensure he could live comfortably while a fugitive.
+
+But perhaps most important, even were the defendant to sacrifice literally all of his current assets, there is every indication that he would immediately be able to resume making millions or tens of millions of dollars per year outside of the United States. He already earns at least \$10,000,000 per year, according to records from Institution-1, while living in the U.S. Virgin Islands, traveling extensively abroad, and residing in part in Paris, France; there would be little to stop the defendant from fleeing, transferring his unknown assets abroad, and then continuing to do whatever it is he does to earn his vast wealth from a computer terminal beyond the reach of extradition .°
+
+That the defendant faces up to 45 years of incarceration on the current counts with which he is charged provides the motive for him do so and is another significant factor in assessing the risk of flight. See United States v. , 823 F.2d 4, 7 (2d Cir. 1987). So too is the strength of the evidence, detailed above and in the Government's Detention Memo. Indeed, that evidence, already robust less than a week ago when the Indictment was unsealed, is growing stronger by the day. Just since the Indictment was unsealed, several additional women, in multiple jurisdictions, have identified themselves to the Government as having been victimized by the defendant when they were minors. Moreover, pursuant to judicially-authorized search warrants, the Government has discovered and seized a significant volume of photographs of nude and seminude young women and girls in the defendant's Manhattan residence, and is in the process of reviewing dozens of electronic discs that contain still more such photos.5 And dozens of individuals have called the Government in recent days to convey information regarding the defendant and the allegations
+
+<sup>4</sup> As noted in the Government's Detention Memo, the defendant is a frequent traveler and regularly travels to and from the United States, including approximately more than 20 flights in which he traveled to or from a foreign country since 2018 alone. Extensive international travel of this nature further demonstrates a significant risk of flight. See, e.g., United States v. 384 F. Supp. 2d 32, 36 (D.D.C. 2005).
+
+<sup>5</sup> The Government's review of these materials, seized earlier this week, remains ongoing.
+
+contained in the Indictment. All this in less than a week, and all in addition to an Indictment that already alleges the existence of dozens of victims in New York and dozens of victims in Florida.
+
+### B. The Proposed Bond is Inadequate to Overcome the Presumption of Detention
+
+The defendant's "slate of highly restrictive" measures which purportedly "amply suffice to secure his release" are neither highly restrictive nor amply sufficient. Rather, they are effectively standard conditions of home confinement, monitoring, and bond unsecured by the defendant's assets—broken out into 14 pieces. The Government will address the most concerning and salient elements of the defendant's proposal below.
+
+# I. Lack of Meaningful Bond Security
+
+The defendant proposes that the Court accept his Manhattan mansion as the primary security for a personal recognizance bond of an indeterminate amount, to be co-signed by the defendant's brother and a friend. Release Motion at 4. This is plainly insufficient.
+
+As an initial matter, and as noted above, the defendant's Manhattan mansion has been identified in the Indictment as subject to forfeiture because it is alleged to have been used to commit or facilitate the commission of the sex trafficking offenses charged there. See 18 U.S.C. § 1594(c)(1). Because the defendant would thus be likely to lose that property following a conviction, it provides no value whatsoever as collateral. See 18 U.S.C. § 3142(g)(4) ("In considering the conditions of release described . . . the judicial officer . . . shall decline to accept the designation, or the use as collateral, of property that, because of its source, will not reasonably assure the appearance of the person as required."). And while the defendant offers to also pledge his private jet as additional collateral, there is absolutely no reason to assume that the defendant would not readily trade his private plane for his freedom. Indeed, the defendant, who has a net worth of more than \$500 million, by his own admission recently sold a second plane and thus presumably has cash on hand to replace the posted aircraft without difficulty if need be.
+
+Nor does the proposed security of properties owned by two identified co-signers meaningfully change the calculus. As further described below, the defendant provides no information about the value or equity of the property of his brother, Mark (the "Palm Beach Property"), or the significance of that property in the context of his brother's own net worth.' Similarly, the defendant provides no details regarding the "investment interests" of his friend Mr. Mitchell, nor any reason to believe the loss of those "interests" would be meaningful to Mr. Mitchell, let alone the defendant. More generally, given the defendant's proffered net worth, the defendant could easily make his co-signers whole — and even reward them — were he to flee.
+
+The proposed security, in sum, should give the Court little comfort the defendant would appear in Court if released on bail.
+
+<sup>6</sup> In fact, the defendant's own submission makes clear that the Palm Beach Property is not his brother's exclusive residence and that his brother lives elsewhere for half of the year.
+
+#### 2. Co-Signers, Moral Suasion, and Ties to the Community
+
+The dearth of detailed financial information about the defendant himself, much less his brother or friend, further shows the hollowness of the proposal. The Court cannot possibly evaluate whether there would be any incentive whatsoever for those the two proposed co-signers to exercise moral suasion over the defendant—or whether, as noted above, the defendant could easily compensate them, perhaps many times over, for any loss they incurred through the defendant's flight from justice. The defendant provides no information about his brother other than that he lives half the year in the home he purportedly would pledge, and even less information about Mr. Mitchell, other than that he is "Mr. Epstein's friend," his "close personal friend of decades," and his "close personal friend." Release Motion at 4, 9. Their willingness to "guarantee" his appearance, Release Motion at 9, is meaningless in the absence of such information.
+
+Moreover, the notion that any individual co-signer could meaningfully secure a bond for this defendant strains credulity. Given the defendant's wealth and his extraordinary risk of flight, any bond for this defendant would assuredly have to be in the hundreds of millions of dollars to even be claimed to be sufficient to guard against the risks posed by the defendant's release. The defendant offers no reason to believe any co-signers could meaningfully sign such a bond, much less these two particular individuals, which is yet another reason the proposed package is patently insufficient.
+
+# 3. The Defendant's "Consent" to Extradition is Unenforceable and Impractical
+
+The defendant's offer to sign a so-called "consent" to extradition provides no additional reassurance whatsoever. As an initial matter, the Government would need to find and re-arrest the defendant before such a waiver would even come into play. Moreover, even assuming the Government could locate and apprehend the defendant, numerous courts have recognized that such purported waivers are unenforceable and effectively meaningless because any defendant who signs such a purported waiver and then flees will assuredly contest the validity and/or voluntariness of the waiver, and will get to do so in ..d ,diction of his choosing (i.e., the one to which he chose to flee). See, e.g., United States v. No. 16-MR-118, 2016 WL 7421924, at \*4 (W.D.N.Y. Dec. 23, 2016); United States v. Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at \*3 (D. Or. Aug. 3, 2015); United States v. Young, Nos. 12 Cr. 502, 12 Cr. 645, 2013 WL 12131300, at \*7 (D. Utah Aug. 27, 2013); United States v. No. C 10-00547, 2010 WL 5387757, at \*9 n.11 (N.D. Cal. Dec. 20, 2010); United States v. Bohn, 330 F. Supp. 2d 960, 961 (W.D. Tenn. 2004); United States v. Stroh, No. 396 Cr. 139, 2000 WL 1832956, at \*5 (D. Conn. Nov. 3, 2000); United States v. Botero, 604 F. Supp. 1028, 1035 (S.D. Fla. 1985). . The Department of Justice's Office of International Affairs is unaware of any country anywhere in the world that would consider an anticipatory extradition waiver binding. And, of course, the defendant could choose to flee to a jurisdiction with which the United States does not have an extradition treaty.
+
+Beyond being impossible to guarantee, extradition is typically a lengthy, complicated and expensive process, and the possibility that it would be successful neither provides any real deterrent to the defendant's incentive to flee nor any measure of justice to the victims who would be required to wait years for his return.
+
+## 4. Home Confinement and Electronic Monitoring Provide No Assurance
+
+The defendant's proposal of ankle-bracelet monitoring should be of no comfort to the Court. In particular, the defendant's endorsement of a GPS monitoring bracelet rather than a radio frequency bracelet is farcical because neither one is useful or effective after it has been removed. At best, home confinement and electronic monitoring would reduce his head start should he decide to cut the bracelet and flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at \*1 (E.D.N.Y. Aug. 4, 2000) (rejecting defendant's application for bail in part because home detention with electronic monitoring "at best . . . limits a fleeing defendant's head start"); see also United States v. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at \*9 (N.D. Cal. Feb. 2018) (same); United States v. , 384 F. Supp.2d 32, 41 (D.D.C. 2005) (same); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at \*3 (E.D.N.Y. Oct. 10, 2002) (same).
+
+# 5. Private Security is Inadequate, Unfair, and Impractical Here
+
+The defendant also proposes the use of a private security force to march him to and from court under the threat of deadly force. This proposal should be rejected.
+
+At the outset, it is far from clear that private jail, which seeks to replicate the conditions of a government-run detention facility in the defendant's home, is a condition of "release" that implicates the Bail Reform Act. "Mhere is a debate within the judiciary over whether a defendant, if she is able to perfectly replicate a private jail in her own home at her own cost, has a right to do so under the Bail Reform Act and the United States Constitution." United States v. Valerio, 9 F. Supp. 3d 283, 292 (E.D.N.Y. 2014) (Bianco, J.) (collecting cases). The Second Circuit has never directly addressed this issue. See United States v. Sabhnani, 493 F.3d 63, 78 n.18 (2d Cir. 2007) ("The government has not argued and, therefore, we have no occasion to consider whether it would be `contrary to the principles of detention and release on bail' to allow wealthy defendants `to buy their way out by constructing a private jail." (citations omitted)). Indeed, a decision by this Court reasoned that "the very severe restrictions" in the private jail proposal presented to him did "not appear to contemplate `release' so much as it describes a very expensive form of private jail or detention." United States v. Zarrab, 2016 WL 3681423, at \*10 (S.D.N.Y. June 16, 2016).
+
+Courts have long been troubled by private jail proposals like the defendant's which, "at best 'elaborately replicate a detention facility without the confidence of security such a facility instills.'" United States v. Orena, 986 F.2d 628, 632 (2d Cir. 1993) (quoting United States v. Gotti, 776 F. Supp. 666, 672 (E.D.N.Y. 1991) (rejecting private jail proposal)); see also Valerio, 9 F. Supp. 3d at 295 ("The questions about the legal authorization for the private security firm to use force against defendant should he violate the terms of his release, and the questions over whether the guards can or should be armed, underscore the legal and practical uncertainties—indeed, the imperfections—of the private jail-like concept envisioned by defendant, as compared to the more secure option of an actual jail."). A private security firm simply cannot replicate the controlled environment of a federal correctional facility, in which, typically, all of the needs to the prisoner can be attended to without placing the prisoner in the community at large; the defendant's proposed private jail arrangement would have the effect of permanently placing him in just such a highflight-risk circumstance. The risk of a public escape attempt while in the community and involving
+
+armed private guards attempting to stop the defendant, potentially by force—rather than the defendant being in the environment of a federal facility—also greatly magnifies the danger of the defendant's flight to the public. See United States v. Boustani, 356 F. Supp. 3d 246, 257 (E.D.N.Y. 2019). "This is why, as the Government correctly notes, federal prisoners should be detained in facilities run by trained personnel from federal correctional facilities." Id. at 258 (citing Sabhnani, 493 F.3d at 74 n.13 ("To the extent [armed private guards] implies an expectation that deadly force may need to be used to assure defendant['s] presence at trial... [s]uch a conclusion would, in fact, demand a defendant's detention")).
+
+The Second Circuit has held it is not legal error "for a district court to decline to accept," as "a substitute for detention," a defendant hiring private security guards to monitor him. United States v. Banki, 369 Fed. App'x 152, 153-54 (2d Cir. 2010). In the same decision, the Second Circuit noted that it was "troubled" by the possibility of "allow[ing] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at •3 (S.D.N.Y. July 19, 2013) ("'it is contrary to underlying principles of detention and release on bail that individuals otherwise ineligible for release should be able to buy their way out by constructing a private jail, policed by security guards not trained or ultimately accountable to the Government, even if carefully selected' (quoting Borodin v. Ashcroft, 136 F. Supp. 2d 125, 134 (E.D.N.Y. 2001))); Valerie), 9 F. Supp. 3d at 293-94 (E.D.N.Y. 2014) ("There is nothing in the Bail Reform Act that would suggest that a defendant (or even, hypothetically, a group of defendants with private funding) has a statutory right to replicate or construct a private jail in a home or some other location.").
+
+The defendant's payment of his guards also raises the conflict of interest inherent in having the defendant having extraordinary influence over a private security company tasked with guarding him, leaving the company's incentives entirely aligned with the defendant. See, e.g., Boustani, 356 F. Supp. 3d at 257 (in finding that private armed guards would not reasonably assure the appearance of a defendant, noting a "clear conflict of interest—private prison guards paid by an inmate" and noting that in a recent S.D.N.Y. case involving private security guards the defendant "was outside of his apartment virtually all day, every weekday; was visited by a masseuse for a total of 160 hours in a 30-day period; and went on an unauthorized visit to a restaurant in Chinatown with his private guards in tow"); see also United States v. Tajideen, 17 Cr. 046, 2018 WL 1342475, at •5-6 (D.D.C. Mar. 15, 2018) (finding Zarrab "particularly instructive" and further noting: "While the Court has no reason to believe that the individuals selected for the defendant's security detail would intentionally violate federal law and assist the defendant in fleeing the Court's jurisdiction, it nonetheless is mindful of the power of money and its potential to corrupt or undermine laudable objectives. And although these realities cannot control the Court's ruling, they also cannot be absolutely discounted or ignored.").
+
+Finally, in Zarrab this Court found that "the Defendant's privately funded armed guard proposal is unreasonable because it helps to inequity and unequal treatment in favor of a very small cohort of criminal defendants who are extremely wealthy, such as Mr. Zarrab." 2016 WL 3681423, at \*13; see also Boustani, 356 F. Supp. 3d at 258 ("although this Defendant has vast financial resources to construct his own `private prison,' the Court is not convinced 'disparate treatment based on wealth is permissible under the Bail Reform Act"') (quoting United States v.
+
+[REDACTED], 89 F. Supp. 3d 425, 432 (E.D.N.Y. 2015) ("Even if Defendant had the financial capacity to replicate a private jail within his own home, this Court is not convinced that such a set of conditions would be sufficiently effective in this case to protect the community from Defendant, or that such disparate treatment based on wealth is permissible under the Bail Act."); *Borodin*, 136 F. Supp. 2d at 134 (E.D.N.Y. 2001) (Nickerson, J.) ("It is contrary to underlying principles of detention and release on bail that individuals otherwise ineligible for release should be able to buy their way out by constructing a private jail, policed by security guards not trained or ultimately accountable to the government, even if carefully selected.").
+
+If the defendant's appearance can only be assured through use of round-the-clock guards, the defendant belongs in a federal detention center, not released under bail conditions that effectively create a private prison of one, using guards to be paid by the defendant himself. It is frankly outrageous for the defendant to suggest that preventing him from using his vast wealth to duplicate a private prison that cannot control, monitor, and contain him consistent with the requirements of the Bail Act would cause him to somehow "bear a *special disadvantage*." Release Motion at 12 n.9. Indeed: "What more compelling case for an order of detention is there than a case in which only an armed guard and the threat of deadly force is sufficient to assure the defendant's appearance?" *Zarrab*, 2016 WL 3681432, at \*12 (quoting *United States v. Valerio*, 9 F. Supp. 3d at 295).
+
+### **III. The Defendant Provides No Assurance He is Not a Danger to the Community and a Risk to Obstruct Justice**
+
+#### **A. Danger to the Community**
+
+In the first instance, the defendant's argument that 14 years without a criminal conviction eliminates "any danger presumption" should be rejected. Were that the case—which is certainly is not—a lack of criminal record for any defendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. *See United States v. Artis*, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to manifest clear error in the district court's determination that no combination of release conditions . . . could reasonably assure against dangerousness and the risk of flight"). Moreover, here, the defendant not only has a criminal record, but has been convicted of a sex crime involving a minor.
+
+But the ongoing and forward-looking danger posed by the defendant is further demonstrated by the defendant's maintenance of a substantial collection of photographic trophies of his victims and other young females in his mansion, as discovered by the Government through its search warrants. As indicated in the Detention Memo, the many discs found in the defendant's residence included those with hand-written labels including the following: "Young [Name] + [Name]," "Misc nudes 1," and "Girl pics nude." Not surprisingly, the Government has found that such discs contain photographs of sexually suggestive photographs of fully- or partially-nude females appearing to be underage.
+
+#### B. Danger to Obstruct Justice
+
+The defendant has also already demonstrated a willingness to use intimidation and aggressive tactics in connection with a criminal investigation. Far from being "musty," Release Motion at 6 n.6, the defendant's past behavior in connection with being investigated for sexually abusing children is the best predictor of his likely incentives and activities in connection with being charged with sexually abusing children. For example, in the incident the defendant now claims was not attributable to or authorized by him, the contemporaneous police report indicates that pressure tactics were at the very least coordinated closely with individuals in the defendant's orbit. See Palm Beach Police Report (the "Police Report") (Ex. B). According to the Police Report, the parent of one of the defendant's victims was driven off the road by a private investigator. The Police Report provides further information regarding victim and witness threats and intimidation reported against an individual who was directly in contact with an assistant of the defendant, followed "immediately" by a call to that same individual from a phone number associated with the defendant's businesses and associates.
+
+Separately, and in addition, there are also extensive allegations of obstruction and tampering in connection with civil lawsuits brought against the defendant following his 2008 conviction. See Doe v. United States, 08 Civ. 80736 (S.D. Fla.), Dkt. 291-15 at 21-23, 31. Moreover, police reports suggest that an associate of Epstein's was offering to buy victims' silence during the course of the prior investigation. Specifically, one victim reported that "she was personally contacted through a source that has maintained contact with Epstein," who "assured [the victim] that she would receive monetary compensation for her assistance in not cooperating with law enforcement." Indeed, the victim reported having been told: "Those who help him will be compensated and those who hurt him will be dealt with." See Palm Beach Police Report (Ex. C).
+
+And Epstein's efforts to influence witnesses continue to this day. As in the past, within recent months. he paid significant amounts of money to influence individuals who were close to him during the time period charged in this case and who might be witnesses against him at a trial. By way of background, on or about November 28, 2018, the Miami Herald began publishing a series of articles relating to the defendant, his conduct, and the circumstances of his prior conviction and the non-prosecution agreement ("NPA"). Records obtained by the Government from Institution-1 appear to show that just two days later, on or about November 30, 2018, the defendant wired \$100,000 from a trust account he controlled to an individual named as a possible co-conspirator in the NPA. The same records appear to show that just three days after that, on or about December 3, 2018, the defendant wired \$250,000 from the same trust account to another individual named as a possible co-conspirator in the NPA and also identified as one of the defendant's employees in the Indictment. Neither of these payments appears to be recurring or repeating during the approximately five years of bank records presently available to the Government. This course of action, and in particular its timing, suggests the defendant was attempting to further influence co-conspirators who might provide information against him in light of the recently re-emerging allegations
+
+## IV. The Defendant Raises Legal Arguments Not Relevant Here
+
+Finally, the defendant raises certain legal arguments he contends he will litigate at the appropriate stage and which he further suggests mitigate in favor of bail. None is meritorious, and certainly none should give the Court any comfort whatsoever that the defendant would, if granted bail, refrain from fleeing so he could attempt to vindicate himself via dubious legal strategies. Nevertheless, the Government will address the defendant's arguments briefly in turn.
+
+## A. The Non-Prosecution Agreement Does Not Preclude Prosecution
+
+As an initial matter, as the Court itself noted at the parties' initial appearance earlier this week, and as the defendant appears to concede, the instant Indictment charges conduct well beyond the scope of the NPA — that is, alleged conduct that occurred here in New York and involving New York based victims. D. Tr. 6-8; Release Motion at 2. For present purposes, that alone is sufficient to put this issue to rest, because even assuming the defendant were to mount a meritorious challenge to the NPA, he would still have to stand trial on Count Two of the Indictment and additional charges brought based on New York conduct.
+
+But more generally, the reasons the defendant can be prosecuted in the Southern District of New York—or anywhere else outside the SDFL—are manifold. The language of the NPA overwhelmingly refers to the SDFL, and the core terms and text of the agreement are limited to the SDFL. The prefatory language states: "THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida."7 The final paragraph of the prefatory language also states, among other things, that after fulfilling the terms of the agreement, "no prosecution for the [sex abuse] offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District."
+
+In its terms section, the NPA further states that Epstein's signature "is not to be construed as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense" as to any victim whose identity was not disclosed by SDFL to Epstein, as provided for in the NPA, and additionally states that neither Epstein's signature nor any resulting waivers or civil settlements "are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person." These provisions show the parties contemplated possible criminal prosecutions in other jurisdictions and/or based on victims not initially identified in the Florida investigations (whether in Florida or elsewhere). The final substantive paragraph of the NPA states that "Epstein hereby requests that the United States Attorney for the Southern District of Florida defer [...] prosecution."
+
+It is well settled in the Second Circuit that "a plea agreement in one U.S. Attorney's office does not, unless otherwise stated, bind another." United States v. Prisco, 391 F. App'x 920, 921
+
+<sup>7</sup> All emphases relating to the NPA are added unless otherwise specified.
+
+(2d Cir. 2010) ("A plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.") (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). Moreover, any references in an NPA to the "Government" or the "United States" do not abrogate these principles. Annabi, 771 F.2d at 672 ("[A] plea agreement whereby a federal prosecutor agrees that `the Government' will dismiss counts of an indictment ... might be thought to bar the United States from reprosecuting the dismissed charges in any judicial district unless the agreement expressly limits the scope of the agreement . . . . However, the law has evolved to the contrary."). "The mere use of the term `government' in the plea agreement does not create an affirmative appearance that the agreement contemplated barring districts other than the particular district entering into the agreement." United States v. Salameh, 152 F.3d 817\_120 (2d Cir. 1998) (citations and internal quotation marks omitted); see also United States v. M, No. 99-1230, 2002 WL 34244994, at \*2 (2d Cir. Apr. 26, 2002) (in analyzing an SDFL plea agreement, reiterating the holding of Annabi and noting that it applies "even if the plea agreement to bind 'the Government' or the "United States") (summary order); United States v. , 159 F. Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the phrase 'United States' shows an intent to bind all United States Attorney's Offices. Rather, the plea agreement covers only Defendant's liability in the SDFL.").8
+
+In sum, this issue is a distraction that has little relevance to the bail determination and does nothing to address the defendant's risk of flight or mitigate the danger he poses to the community.
+
+# B. The Defendant Wrongly Argues the Statute Does Not Apply to His Sex Trafficking
+
+Next, the defendant wrongly argues that the "principal conduct" giving rise to the charges is his payment of underage girls for sex acts, and that such conduct could not possibly fall under the charged statutes. As the defendant implicitly concedes, Release Motion at 14, this is an issue for a motion to dismiss. Nevertheless, the defendant's argument is incorrect for two reasons.
+
+First, although the defendant undoubtedly participated on the demand side of the crime, he was also instrumental on the supply side given his role in recruiting and causing others to recruit additional victims. He organized, funded, and perpetuated a sex trafficking scheme in two states, including with co-conspirators. The fact that he did so for his own eventual and frequent sexual gratification does not vitiate his role in enticing and recruiting victims, consistent with the elements of the offense with which he is charged. The defendant was the leader of a sex-trafficking enterprise, not a mere consumer.
+
+<sup>8</sup> This analysis similarly extends to a non-prosecution agreement. See United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) ("Defendant's argument, in effect, is that unless there is an explicit statement to the contrary, it is presumed that a non-prosecution agreement binds offices of the United States Attorney that are not parties to the agreement. This position is at odds with the law in this Circuit, which presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively establish that a more expansive interpretation was contemplated.") (citing Annabi, 771 F.2d at 672).
+
+Second, he is also wrong on the law. Courts have found that Section 1591 applied to both suppliers and consumers of commercial sex acts. See, e.g., United States v. Jungers, 702 F.3d 1066, 1069 (8th Cir. 2013) (upholding the conviction of a defendant who attempted to pay for oral sex from an underage girl and explaining: "The sole issue raised on appeal is whether 'Mlle plain and unambiguous provisions of 18 U.S.C. § 1591 apply to both suppliers and consumers of commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the defendant, Fierro v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied heavily on the statutory interpretation undertaken by two district courts in the District of South Dakota, United States v. Bonestroo, No. 11 Cr. 40016, 2012 WL 13704 (D.S.D. Jan. 4, 2012), and United States v. Jungers, 11 Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven years since Fierro has been decided, it does not appear to have been cited by a single other court. Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or customers. See United States v. , 650 F.3d 839 (2d Cir. 2011) (upholding convictions under Section 1591 of both the buyer and seller of a child); United States v. 782 F.3d 983 (8th Cir. 2015) (rejecting a constitutional challenge that Section 1591 would be void for vagueness if applied to purchasers); United States v. Mikoloyck, No. 09 Cr. 036, 2009 WL 4798900 (W.D. Mo. Dec. 7, 2009) ("contrary to defendant's argument, 18 U.S.C. § 1591 clearly applies to those who attempt to purchase underage sex, not merely the pimps of actual exploited children") (citing United States v. . 174 F. App's 475 (I I th Cir. 2006) (in which defendant was convicted under sections 1591(a) and 1594(a) even though no actual children were involved)).
+
+# CONCLUSION
+
+As set forth above, the defendant's proposed bail package is insufficient and insubstantial. Pretrial Services, victims, and the Government all recommend pretrial detention due to the unusual and concerning confluence of factors in this case, including the defendant's extraordinary wealth, demonstrated willingness to interfere with victims and witnesses, continued possession of lewd photographs of young females, and both the incentive and means to flee prosecution.
+
+Very truly yours,
+
+GEOF REY S. BERMAN United States Attorney
+
+By:
+
+Alex Rossmiller / Alison Moe / Maurene Comey Assistant United States Attorney Southern District of New York Tel: (212) 637-2415 / 2225 / 2324
+
+Cc: Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant

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marker2/court-us-v-epstein-cr/EFTA02824235/EFTA02824235.md

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+## COMMONWEALTH OF MASSACHUSETTS
+
+SUFFOLK, SS.
+
+---
+
+BE IT REMEMBERED, that at the Supreme Judicial Court holden at Boston within and for said County of Suffolk, on the **twenty-fourth** day of **April** A.D. **1972**, said Court being the highest Court of Record in said Commonwealth:
+
+![]()being found duly qualified in that behalf, and having taken and subscribed the oaths required by law, was admitted to practice as an Attorney, and, by virtue thereof, as a Counsellor at Law, in any of the Courts of the said Commonwealth: that said Attorney is at present a member of the Bar, and is in good standing according to the records of this Court\*.
+
+In testimony whereof, I have hereunto set my hand and affixed the seal of said Court, this **eleventh** day of **July** in the year of our Lord **two thousand and nineteen**.
+
+![](_page_0_Picture_90.jpeg)
+
+![]()\* Records of private discipline, if any, such as a private reprimand imposed by the Board of Bar Overseers or by any court, are not covered by this certification. X3116

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marker2/court-us-v-epstein-cr/EFTA02824236/EFTA02824236.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA, v. JEFFREY EPSTEIN, Defendant ) ) ) ) Criminal No. 19 Cr 490 (RMB) ) )
+
+## Order For Admission Pro Hac Vice
+
+The motion of G. Weinberg, for admission to practice Pro Hac Vice in the above captioned matter, is granted.
+
+Applicant has declared he is a member in good standing of the bar of the Commonwealth of Massachusetts and his contact information is as follows:
+
+**G. Weinberg, Esq. G. Weinberg, P.C. 20 Park Plaza, Suite 1000 Boston,. 02116 Telephone: (617) 227-3700 Facsimile: (617) 338-9538 owlmgw@att.net** 
+
+**Applicant having requested admission Pro Hac Vice to appear as co- counsel for Jeffrey Epstein in the above-captioned matter;** 
+
+**IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above-captioned matter in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the rules governing discipline of attorneys.** 
+
+**Dated: Richard M. Berman** 
+
+**United States District Court Judge**

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marker2/court-us-v-epstein-cr/EFTA02824237/EFTA02824237.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA, )
+
+)
+
+)
+
+v. ) Criminal No. 19 Cr 490 (RMB)
+
+)
+
+JEFFREY EPSTEIN, )
+
+Defendant
+
+## Notion I or inn Pro Ilac icc
+
+Pursuant to Rule 1.3 of the Local Rules for the United States District Court for the Southern District of New York, I G. Weinberg, hereby move this Court for an Order for admission Pro Hac Vice to appear as co-counsel for Jeffrey Epstein in the above-captioned matter.
+
+Counsel states that he is a member in good standing of the bar of the Commonwealth of Massachusetts and there are no pending disciplinary proceedings against counsel in any state or federal court.
+
+Respectfully submitted,
+
+illreer lthillfa therg, Esq. Mass. Bar No. 519480 20 Park Plaza, Suite 1000 Boston, 02116 Telephone: (617) 227-3700 Facsimile: (617) 338-9538 owlmizwOatt.net
+
+Dated: July 15, 2019
+
+## Certificate of Service
+
+1, G. Weinberg, hereby certify that on this date, July 15, 2019, a copy of the foregoing document has been served via CM/ECF on Assistant U.S. Attorney Alex Rossmiller and all other counsel of record.
+
+ilirel3rthag nillrg

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marker2/court-us-v-epstein-cr/EFTA02824239/EFTA02824239.md

@@ -0,0 +1,19 @@
+## COMMONWEALTH OF MASSACHUSETTS
+
+SUFFOLK, SS.
+
+BE IT REMEMBERED, that at the Supreme Judicial Court holden at Boston within and for said County of Suffolk, on the twenty-fourth day of April A.D. 1972 , said Court being the highest Court of Record in said Commonwealth:
+
+G. Weinberg
+
+being found duly qualified in that behalf, and having taken and subscribed the oaths required by law, was admitted to practice as an Attorney, and, by virtue thereof, as a Counsellor at Law, in any of the Courts of the said Commonwealth: that said Attorney is at present a member of the Bar, and is in good standing according to the records of this Court\*.
+
+In testimony whereof, I have hereunto set my hand and affixed the seal of said Court, this eleventh day of July
+
+in the year of our Lord two thousand and nineteen.
+
+![](_page_0_Picture_8.jpeg)
+
+MAURA S. Clerk
+
+<sup>•</sup> Records of private chserphne. if any, such as a private reprimand imposed by the Board of Bar Overseers or by any court. are nor covered by thy. eauficatum XIII6

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marker2/court-us-v-epstein-cr/EFTA02824240/EFTA02824240.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA, v. JEFFREY EPSTEIN, Defendant ) ) ) ) Criminal No. 19 Cr 490 (RMB) ) )
+
+## Order For Admission Pro Hac Vict
+
+The motion of G. Weinberg, for admission to practice Pro Hac Vice in the above captioned matter, is granted.
+
+Applicant has declared he is a member in good standing of the bar of the Commonwealth of Massachusetts and his contact information is as follows:
+
+**G. Weinberg, Esq. G. Weinberg, P.C. 20 Park Plaza, Suite 1000 Boston,. 02116 Telephone: (617) 227-3700 Facsimile: (617) 338-9538 owlmgw@att.net** 
+
+**Applicant having requested admission Pro Hac Vice to appear as co- counsel for Jeffrey Epstein in the above-captioned matter;** 
+
+**IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above-captioned matter in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the rules governing discipline of attorneys.** 
+
+**Dated: Richard M. Berman** 
+
+**United States District Court Judge**

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marker2/court-us-v-epstein-cr/EFTA02824241/EFTA02824241.md

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+## UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+) ) UNITED STATES OF AMERICA ) ) v. ) ) JEFFREY EPSTEIN, ) Defendant ) ) )
+
+CRIMINAL NO. 19-CR-490
+
+## AFFIDAVIT IN SUPPORT OF MOTION FOR ADMISSION PRO RAC VICE
+
+- G. Weinberg, state and affirm that:
+- 1. I have never been convicted of a felony.
+- 2. I have never been censured, suspended, disbarred, or denied admission or readmission by any court.
+- 3. There are no disciplinary proceedings pending presently against me.
+
+Signed under the pains and penalties of perjury.
+
+a l asset," G. Weinberg 20 ParkLigr.a, Suite 1000 Boston, M 02116 (617) 227-3700 owlmgw@att.net
+
+Dated: July 15, 2019