diff --git a/marker2/court-us-v-epstein-cr/EFTA02824136/EFTA02824136.md b/marker2/court-us-v-epstein-cr/EFTA02824136/EFTA02824136.md new file mode 100644 index 0000000000000000000000000000000000000000..6852177e8032fd45c76d0b2e6ededdf4e58e2af0 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824136/EFTA02824136.md @@ -0,0 +1,175 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA + +JEFFREY EPSTEIN, + +Defendant. + +(Sex COUNT ONE A in Trafficking Conspiracy '-, ,01- • l + +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 + +--- \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824136/EFTA02824136.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824136/EFTA02824136.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8bfb7cf31a55b3041e4c9c580373d1fc788ef2e6 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824136/EFTA02824136.metadata.json @@ -0,0 +1,798 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824136.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 14, + "chars": 16433, + "elapsed_seconds": 5.28, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "OVERVIEW", + "heading_level": null, 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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) \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824150/EFTA02824150.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824150/EFTA02824150.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e4e2f2c56160b68ecffa54c55e2d5ee40f7176dc --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824150/EFTA02824150.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824150.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 808, + "elapsed_seconds": 0.97, + "image_assets": [ + "_page_0_Picture_13.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK \n.17", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 85.68, + 94.77000000000001 + ], + [ + 300.2743835449219, + 94.77000000000001 + ], + [ + 300.2743835449219, + 124.050537109375 + ], + [ + 85.68, + 124.050537109375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 52 + ], + [ + "Line", + 26 + ], + [ + "Text", + 12 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824150" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824150/_page_0_Picture_13.jpeg b/marker2/court-us-v-epstein-cr/EFTA02824150/_page_0_Picture_13.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..ceb2378418e8485eab4a94a63114de48f0a75338 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824150/_page_0_Picture_13.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:4472191081d7217be6bf39d962a988a1a74b44755d00f88f365d9e1bf3977449 +size 18730 diff --git a/marker2/court-us-v-epstein-cr/EFTA02824151/EFTA02824151.md b/marker2/court-us-v-epstein-cr/EFTA02824151/EFTA02824151.md new file mode 100644 index 0000000000000000000000000000000000000000..8b6c946a0b731286c8b7d62ccd5e83d50a115e5b --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824151/EFTA02824151.md @@ -0,0 +1,96 @@ +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. \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824151/EFTA02824151.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824151/EFTA02824151.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d1580557c204c8acd88c97696cb24d355a2ec055 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824151/EFTA02824151.metadata.json @@ -0,0 +1,124 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824151.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 2154, + "elapsed_seconds": 12.44, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "BAIL DISPOSITION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 250.92000000000002, + 188.73000000000002 + ], + [ + 343.944, + 188.73000000000002 + ], + [ + 343.944, + 200.88 + ], + [ + 250.92000000000002, + 200.88 + ] + ] + }, + { + "title": "ADDITIONAL CONDITIONS/ADDITIONAL PROCEEDINGS/COMMENTS:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 36.72, + 468.18 + ], + [ + 367.2, + 468.18 + ], + [ + 367.2, + 481.95000000000005 + ], + [ + 36.72, + 481.95000000000005 + ] + ] + }, + { + "title": "For Rule 5(c)(3) Cases:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 36.72, + 627.75 + ], + [ + 140.76, + 627.75 + ], + [ + 140.76, + 639.9000000000001 + ], + [ + 36.72, + 639.9000000000001 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 96 + ], + [ + "PageFooter", + 6 + ], + [ + "SectionHeader", + 5 + ], + [ + "PageHeader", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824151" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824152/EFTA02824152.md b/marker2/court-us-v-epstein-cr/EFTA02824152/EFTA02824152.md new file mode 100644 index 0000000000000000000000000000000000000000..ae499d219bb4bff184c70e57927be96d2313ef5a --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824152/EFTA02824152.md @@ -0,0 +1,214 @@ +# 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. 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b/marker2/court-us-v-epstein-cr/EFTA02824167/EFTA02824167.md @@ -0,0 +1,162 @@ +# 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). + +2 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. + +3 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 + +5 Significantly, it is Epstein 's contractual rights under the non-prosecution agreement that Petitioners seek to void through these proceedings. + +6 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 + +&#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. + +8 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: + +12 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.13 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 + +13 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. 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a/marker2/court-us-v-epstein-cr/EFTA02824182/EFTA02824182.md b/marker2/court-us-v-epstein-cr/EFTA02824182/EFTA02824182.md new file mode 100644 index 0000000000000000000000000000000000000000..16823033359723ced720e62c0501695cf3f92da0 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824182/EFTA02824182.md @@ -0,0 +1,157 @@ +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 18.1 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 + +--- + +1 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 + +2 "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). + +3 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). + +4 Mr. Epstein's lone foreign residence is in Paris; France has an extradition treaty with the United States. + +5 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.6 + +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 + +--- + +6 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 71st 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). + +&#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 + +9 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...”).10 + +--- + +10 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 \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824182/EFTA02824182.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824182/EFTA02824182.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5627396ae5a75a29e9debb930b85cc85a41d56e4 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824182/EFTA02824182.metadata.json @@ -0,0 +1,745 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824182.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 16, + "chars": 45794, + "elapsed_seconds": 14.04, + "image_assets": [ + "_page_0_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 182.25 + ], + [ + 124.17080688476562, + 182.25 + ], + [ + 124.17080688476562, + 196.10302734375 + ], + [ + 68.544, + 196.10302734375 + ] + ] + }, + { + "title": "I. 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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 \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824198/EFTA02824198.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824198/EFTA02824198.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7b4f480a7cdf02094f2e682a51fd6348d9f2a7ee --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824198/EFTA02824198.metadata.json @@ -0,0 +1,204 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824198.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 2346, + "elapsed_seconds": 0.58, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nFOR THE SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 173.19599999999997, + 72.9 + ], + [ + 438.5491638183594, + 72.9 + ], + [ + 438.5491638183594, + 100.10302734375 + ], + [ + 173.19599999999997, + 100.10302734375 + ] + ] + }, + { + "title": "DEFENDANT JEFFREY EPSTEIN'S MOTION FOR LEAVE TO FILE \nSUPPLEMENTAL FINANCIAL DISCLOSURE UNDER SEAL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 115.66799999999999, + 278.64 + ], + [ + 497.7448425292969, + 278.64 + ], + [ + 497.7448425292969, + 307.1835632324219 + ], + [ + 115.66799999999999, + 307.1835632324219 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 222.15599999999998, + 71.28 + ], + [ + 388.520263671875, + 71.28 + ], + [ + 388.520263671875, + 86.60302734375 + ], + [ + 222.15599999999998, + 86.60302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 60 + ], + [ + "Line", + 30 + ], + [ + "SectionHeader", + 2 + ], + [ + "Text", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 30 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 15 + ], + [ + "Line", + 8 + ], + [ + "Text", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824198" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824201/EFTA02824201.md b/marker2/court-us-v-epstein-cr/EFTA02824201/EFTA02824201.md new file mode 100644 index 0000000000000000000000000000000000000000..5912b1ba222e3a9a3c5a2e715dbd3c9528d2cba4 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824201/EFTA02824201.md @@ -0,0 +1,35 @@ +![](_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 \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824201/EFTA02824201.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824201/EFTA02824201.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9f8fd480a89a72bda6a5f46b9171ade8dc32cfd9 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824201/EFTA02824201.metadata.json @@ -0,0 +1,149 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824201.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2247, + "elapsed_seconds": 0.77, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 318.85200000000003, + 25.92 + ], + [ + 463.6654968261719, + 25.92 + ], + [ + 463.6654968261719, + 41.2330322265625 + ], + [ + 318.85200000000003, + 41.2330322265625 + ] + ] + }, + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 168.48 + ], + [ + 124.12138366699219, + 168.48 + ], + [ + 124.12138366699219, + 182.9830322265625 + ], + [ + 68.544, + 182.9830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 32 + ], + [ + "Text", + 9 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 18 + ], + [ + "Text", + 7 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824201" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824201/_page_0_Picture_1.jpeg b/marker2/court-us-v-epstein-cr/EFTA02824201/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..4ef3b264f9eba950d9016cab562068a740e236f8 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824201/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:0d44a76f3e8cdc467e22f04a7b864f80d5d4ae553a5bd960b18cd013a1f890fb +size 3342 diff --git a/marker2/court-us-v-epstein-cr/EFTA02824203/EFTA02824203.md b/marker2/court-us-v-epstein-cr/EFTA02824203/EFTA02824203.md new file mode 100644 index 0000000000000000000000000000000000000000..6ed2127151f013cec94955c9a8778f9d624c22ca --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824203/EFTA02824203.md @@ -0,0 +1,45 @@ +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. \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824203/EFTA02824203.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824203/EFTA02824203.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2ce86fc09174d2f4fb7b193ccd8ee35c6bb12401 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824203/EFTA02824203.metadata.json @@ -0,0 +1,124 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824203.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2379, + "elapsed_seconds": 1.02, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "DEFENDANT JEFFREY EPSTEIN'S MOTION FOR LEAVE TO FILE \nSUPPLEMENTAL FINANCIAL DISCLOSURE UNDER SEAL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 120.56400000000001, + 282.68999999999994 + ], + [ + 487.4988098144531, + 282.68999999999994 + ], + [ + 487.4988098144531, + 310.4830322265625 + ], + [ + 120.56400000000001, + 310.4830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 35 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Form", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 94 + ], + [ + "Line", + 38 + ], + [ + "Text", + 11 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824203" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824205/EFTA02824205.md b/marker2/court-us-v-epstein-cr/EFTA02824205/EFTA02824205.md new file mode 100644 index 0000000000000000000000000000000000000000..c7f07002b8b5d1eb340ed3779d8de02e31ce329c --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824205/EFTA02824205.md @@ -0,0 +1,44 @@ +![](_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 + +|

Application for extension of time denied. (Hard to imagine it would take the Govt anticipations to review submission.)

| | +|-------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------| +|

SO ORDERED: _____

| | +| Date: 7/12/19 | Richard M. Berman
Richard M. Berman, U.S.D.J. | \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824205/EFTA02824205.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824205/EFTA02824205.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..921a7827f9d17f7b81b58da6f6c2912291594586 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824205/EFTA02824205.metadata.json @@ -0,0 +1,102 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824205.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3077, + "elapsed_seconds": 1.56, + "image_assets": [ + "_page_0_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 40 + ], + [ + "Text", + 12 + ], + [ + "PageHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 54 + ], + [ + "Line", + 24 + ], + [ + "Text", + 7 + ], + [ + "PageHeader", + 2 + ], + [ + "Form", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824205" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824205/_page_0_Picture_2.jpeg b/marker2/court-us-v-epstein-cr/EFTA02824205/_page_0_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..6b0facc291fc04a6c12acf75cd196e1b31b46e58 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824205/_page_0_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:856664c0700cfea1845570029636a7fdde525b4378059cbe708cf6f6e79f4d3f +size 3610 diff --git a/marker2/court-us-v-epstein-cr/EFTA02824207/EFTA02824207.md b/marker2/court-us-v-epstein-cr/EFTA02824207/EFTA02824207.md new file mode 100644 index 0000000000000000000000000000000000000000..aeae9de947ce0d4996716f9b84cdc152060a6393 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824207/EFTA02824207.md @@ -0,0 +1,147 @@ +![](_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. + +2 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.' + +3 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. + +4 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. + +5 The redactions above are contained in the publicly filed version of the quoted document. + +6 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. 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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. 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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. 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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. + +&#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."). + +2 "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. + +3 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 + +4 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). + +5 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. + +6 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 + +7 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. + +8 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 \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824221/EFTA02824221.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824221/EFTA02824221.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3bbd836858ab735356216995aae50e6be0614e09 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824221/EFTA02824221.metadata.json @@ -0,0 +1,1050 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824221.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 14, + "chars": 47409, + "elapsed_seconds": 12.52, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.464, + 26.73 + ], + [ + 463.6324768066406, + 26.73 + ], + [ + 463.6324768066406, + 40.93353271484375 + ], + [ + 319.464, + 40.93353271484375 + ] + ] + }, + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 169.1015625 + ], + [ + 124.12138366699219, + 169.1015625 + ], + [ + 124.12138366699219, + 182.9830322265625 + ], + [ + 68.544, + 182.9830322265625 + ] + ] + }, + { + "title": "PRELIMINARY STATEMENT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 219.70799999999997, + 409.86 + ], + [ + 391.8983154296875, + 409.86 + ], + [ + 391.8983154296875, + 424.10302734375 + ], + [ + 219.70799999999997, + 424.10302734375 + ] + ] + }, + { + "title": "BACKGROUND", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 258.264, + 506.25 + ], + [ + 353.03448486328125, + 506.25 + ], + [ + 353.03448486328125, + 521.60302734375 + ], + [ + 258.264, + 521.60302734375 + ] + ] + }, + { + "title": "ARGUMENT", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 267.44399999999996, + 113.4 + ], + [ + 344.61444091796875, + 113.4 + ], + [ + 344.61444091796875, + 127.10302734375 + ], + [ + 267.44399999999996, + 127.10302734375 + ] + ] + }, + { + "title": "I. 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https://git-lfs.github.com/spec/v1 +oid sha256:49a87d80d3c5d2a922b7c77da86fc220049e68118f37c43df55534ba958170d5 +size 3349 diff --git a/marker2/court-us-v-epstein-cr/EFTA02824235/EFTA02824235.md b/marker2/court-us-v-epstein-cr/EFTA02824235/EFTA02824235.md new file mode 100644 index 0000000000000000000000000000000000000000..8d9644c97c67d6acd78717084eb013b3e1ffce4c --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824235/EFTA02824235.md @@ -0,0 +1,15 @@ +## 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. 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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** \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824236/EFTA02824236.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824236/EFTA02824236.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..86f73de460e901ac5798f2c474c58ffeff9a8846 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824236/EFTA02824236.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824236.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1133, + "elapsed_seconds": 0.58, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 182.988, + 78.57000000000001 + ], + [ + 394.27838134765625, + 78.57000000000001 + ], + [ + 394.27838134765625, + 110.9830322265625 + ], + [ + 182.988, + 110.9830322265625 + ] + ] + }, + { + "title": "Order For Admission Pro Hac Vice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 212.97599999999997, + 234.09 + ], + [ + 400.50714111328125, + 234.09 + ], + [ + 400.50714111328125, + 249.363037109375 + ], + [ + 212.97599999999997, + 249.363037109375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 34 + ], + [ + "Text", + 8 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824236" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824237/EFTA02824237.md b/marker2/court-us-v-epstein-cr/EFTA02824237/EFTA02824237.md new file mode 100644 index 0000000000000000000000000000000000000000..c4c9bf514eee98ec57f9e97292b270569a89e62a --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824237/EFTA02824237.md @@ -0,0 +1,33 @@ +## 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 \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824237/EFTA02824237.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824237/EFTA02824237.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..799f57c32f279ea7c0d75b160b2479b223c8d4a9 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824237/EFTA02824237.metadata.json @@ -0,0 +1,170 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824237.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1122, + "elapsed_seconds": 0.91, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 199.512, + 71.17889404296875 + ], + [ + 412.5726013183594, + 71.17889404296875 + ], + [ + 412.5726013183594, + 98.68353271484375 + ], + [ + 199.512, + 98.68353271484375 + ] + ] + }, + { + "title": "Notion I or inn Pro Ilac icc", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 209.304, + 241.05889892578125 + ], + [ + 402.5928649902344, + 241.05889892578125 + ], + [ + 402.5928649902344, + 255.43353271484375 + ], + [ + 209.304, + 255.43353271484375 + ] + ] + }, + { + "title": "Certificate of Service", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 248.47200000000004, + 83.42999999999999 + ], + [ + 363.08050537109375, + 83.42999999999999 + ], + [ + 363.08050537109375, + 98.9830322265625 + ], + [ + 248.47200000000004, + 98.9830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 62 + ], + [ + "Line", + 28 + ], + [ + "Text", + 15 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 14 + ], + [ + "Line", + 7 + ], + [ + "Text", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824237" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824239/EFTA02824239.md b/marker2/court-us-v-epstein-cr/EFTA02824239/EFTA02824239.md new file mode 100644 index 0000000000000000000000000000000000000000..4d1ce0ae5fa9a7d246cc92eb6880d1c25b38642f --- /dev/null +++ b/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 + +• 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 \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824239/EFTA02824239.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824239/EFTA02824239.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..72281dc077a38bafcc75dd15392a8db8bd790a41 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824239/EFTA02824239.metadata.json @@ -0,0 +1,96 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824239.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1027, + "elapsed_seconds": 0.67, + "image_assets": [ + "_page_0_Picture_8.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "COMMONWEALTH OF MASSACHUSETTS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 134.64000000000001, + 69.66 + ], + [ + 462.3560791015625, + 69.66 + ], + [ + 462.3560791015625, + 88.639404296875 + ], + [ + 134.64000000000001, + 88.639404296875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 48 + ], + [ + "Line", + 19 + ], + [ + "Text", + 8 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "Footnote", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824239" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824239/_page_0_Picture_8.jpeg b/marker2/court-us-v-epstein-cr/EFTA02824239/_page_0_Picture_8.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..1ae4e4721485b47e1a70f3e69803d7e0ccc5e9b5 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824239/_page_0_Picture_8.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:065cd1b1ef3d421ae18f4cff95b4c14f557077a40118dddc5de9a7109e882b8f +size 19008 diff --git a/marker2/court-us-v-epstein-cr/EFTA02824240/EFTA02824240.md b/marker2/court-us-v-epstein-cr/EFTA02824240/EFTA02824240.md new file mode 100644 index 0000000000000000000000000000000000000000..1d1aa67da841cb14d7c39a046cbc004887fd7a6e --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824240/EFTA02824240.md @@ -0,0 +1,19 @@ +## 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** \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824240/EFTA02824240.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824240/EFTA02824240.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6592d7331eec473bbab861eff18ce4acdbe4ceb0 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824240/EFTA02824240.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824240.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1133, + "elapsed_seconds": 0.58, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 182.988, + 78.57000000000001 + ], + [ + 394.27838134765625, + 78.57000000000001 + ], + [ + 394.27838134765625, + 110.9830322265625 + ], + [ + 182.988, + 110.9830322265625 + ] + ] + }, + { + "title": "Order For Admission Pro Hac Vict", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 212.97599999999997, + 234.09 + ], + [ + 400.4678955078125, + 234.09 + ], + [ + 400.4678955078125, + 249.363037109375 + ], + [ + 212.97599999999997, + 249.363037109375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "Text", + 8 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824240" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824241/EFTA02824241.md b/marker2/court-us-v-epstein-cr/EFTA02824241/EFTA02824241.md new file mode 100644 index 0000000000000000000000000000000000000000..c27d600a8ae0337fa02272ed05c9de40b2349152 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824241/EFTA02824241.md @@ -0,0 +1,18 @@ +## 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. 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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, + +r eerr erg, ibtaEsq. Mass. Bar No. 519480 20 Park Plaza, Suite 1000 Boston, IN 02116 Telephone: (617) 227-3700 Facsimile: (617) 338-9538 owlmawQatt.net + +Dated: July 15, 2019 + +## Certificate of Service + +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. + +G. 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BERMAN U.S.D.J. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +q + +12 + +f• , 1:4 + +14 + +15 + +1,6 + +17 + +18 + +19 + +"" 20 + +21 + +22 + +2p + +24 + +25 + +SORA HEARING page 1 + +SUPREME COURT NEW YORK COUNTY + +TRIAL TERM PART 66 + +x THE PEOPLE OF THE STATE OF NEW YORK: INDICTMENT # : Mr2D-720-TO-- + +AGAINST JEFFREY EPSTEIN Defendant. .x SORA HEARING + +BEFORE: HONORABLE RUTH PICKHOLZ Justice of the Supreme Court + +111 Centre Street New York, New York 10013 January 18, 2011 + +APPEARANCES: + +For the People: CYRUS R. VANCE, JR., ESQ., New York County District Attorney One Hogan Place New York, New York 10013 BY: JENNIFER GAFFNEY, ESQ. Assistant District Attorney + +For the Defense: KIRKLAND & ELLI, LLP 153 East 53rd Street New York, New York 10022 BY: JAY LEFKOWITZ, ESQ. SANDRA MUSUMECI, ESQ. + +> Vikki J. Benkel Senior Court Reporter + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +## SORP HEARING page 2 + +COURT CLERK: This is number two on the calendar, matter of Jeffrey Epstein. + +Your appearances please. + +MS. GAFFNEY: Jennifer Gaffney for the People. + +Good afternoon, Your Honor. + +MR. LEFKOWITZ: Jay LefKowitz and Sandra Musumeci for Mr. Epstein. + +THE COURT: Mr. Epstein is not here. + +MR. LEFKOWITZ: That's correct. + +THE COURT: Are you waiving his appearance? + +MR. LEXWOWITZ: Yes. + +MS. GAFFNEY: Your Honor, this case is on for a SORA hearing this afternoon. + +The People did receive the board's recommendation of aLevel Three. However, we received the underlying information, from them and also had some contact with Florida, and we don't believe that we can rely on the entire probable cause affidavit. + +I don't know if the board sent that to you as well. + +THE COURT: I don't know why you cannot rely on it. + +MS. GAFFNEY: Because in Florida of all of the victims in that probable cause affidavit, they actually only went forward on one case. There was only an indictment for + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +### SORP HEARING page 3 + +one victim and that is what the defendant plead to. + +So it is unlike asituation where everything was indicted and then we get to sort of assess points for all of the victims, if it was part of a plea bargain. They did not actually choose to go forward on any except for the one victim. + +So under the board guidelines, the risk assessment interim guidelines, it actually says, you know, by way of contrast if an offender is not indicted for an offense, it is strong evidence that the offense did not occur and I don't think -- + +THE COURT: Do you find that if somebody is not indicted it is strong evidence that it did not occur? + +MS. GAFFNEY: I don't know that we can rely on it as clear and convincing evidence if the prosecutor's office never went forward on it. The prosecution said that the victims, although they spoke to the police early on, did not cooperate with them. So we don't have any follow up information. + +THE COURT: But the board found aLevel Three. + +Ihave to tell you, I am alittle overwhelmed because I have never seen the prosecutor's office do anything like this. I have never seen it. I had a case with one instance it was amarine who went to a bar, and I wish I had the case before me, but he went to a bar and a17 + +#### SORP HEARING page 4 + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +year old, he was an adult obviously, he was aMarine, a17 year old came up to him and one thing lead to another and he had sex with her and the People would not agree to a downward modification on that. + +So I am alittle overwhelmed here because I see -- Imean I read everything here, I am just alittle overwhelmed that the People are making this application, + +Icould cite many many, I have done many SORAs much less troubling than this one where the People would never make adownward argument like this. + +MS. GAFFNEY: I agree with Your Honor, it is incredibly unusual for us to make adownward argument. But the problem is the one thing that we have from the board is it seems to be in contradiction to their own guidelines which if something was not indicted, you are not supposed to rely on it. + +THE COURT: They obviously took that into consideration. + +MS. GAFFNEY: And I tried to reach -- I reached the authorities in Florida to try to see if they had all the interview notes or other things that we can then subsequently rely on that might be considered clear and convincing evidence, if they had interviewed these women on their own, and they never did. No one was cooperative and they did not go forward on any of the cases and none of them + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +SORP HEARING + +were indicted. So I don't know. + +THE COURT: And you spoke to the prosecutor? + +MS. GAFFNEY: The actual prosecutor left the office. I spoke to the prosecutor that took over the case. + +THE COURT: Maybe you can find the prosecutor that left the office. + +You have done more in other cases looking into it. Ihave never seen the prosecutor's office do this. I have to tell you, I am shocked. + +MS. GAFFNEY: Right, but I spoke to the prosecutor that took over the case and they don't have anything, any affidavits, any statements, any notes. + +THE COURT: Why don't you speak to the prosecutor that did do the case, I am sure you could find that prosecutor. + +MS. GAFFNEY: I can find her, but based upon what the other prosecutor said, they did not speak to that prosecutor either. + +THE COURT: You did not speak to the prosecutor yourself, you did not speak to them, that is hearsay. You did not speak to the prosecutor that handled the case. + +MS. GAFFNEY: That's right. + +THE COURT: I don't think you did much of an investigation here. + +MS. GAFFNEY: I mean I called the prosecutor. + +page 5 + +## SORAHEARING + +Even though the first prosecutor left, presumably the prosecutor's office has the file. + +THE COURT: I would still call the prosecutor. + +MS. GAFFNEY: Anything from these women they would have forwarded it to us. + +THE COURT: I don't know that, I think you have to speak to the prosecutor. + +But be that as it may, I hear your argument. + +Anything else? + +MS. GAFFNEY: I mean that is why I don't think we can, I don't think we are entitled to rely on this because they did not go forward. + +THE COURT: The board made arecommendation. + +MS. GAFNEY: Correct. + +III I speak, Your Honor? + +THE COURT: Yes. + +MS. MUSUMECI: Good afternoon. + +Iwould like to bring afew additional points to Your Honor's attention that don't come across in the board recommendation. + +The first is that Mr. Epstein is not aresident of New York, unlike most of these out of state, he has not changed his address and moved to New. York, he maintains a vacation home in New York. His primary residence is the U.S. Virgin Islands. + +page 6 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +## SORP HEARING page 7 + +He is registered in the U.S. Virgin Islands, he has been since his release from jail. He notifies the Virgin Island authorities every time he leaves that jurisdiction. Virgin Island authorities rated him at the lowest level of registration. + +He also registered in Florida, which is the state of this particular offense, and the only reason that this conviction is even before Your Honor. + +The offense for which he was convicted is not a registrable offense in New York. He is only registrable here arguably because based on the provision of SORA that says if acrime is registrable in the state of conviction, then it is registrable here in New York. And the Florida authorities that considered that rated him at the lowest level of their SORA statute. + +He additionally has avacation home in New Mexico and is registered in New Mexico. The New Mexican authorities when they considered his offenses, determined he need not register at all. Nevertheless, he has voluntarily registered with New Mexico and maintains that registration. + +Additionally, because of his possession of a vacation home in New York, he has been voluntarily registered with New York SOMU, the Sex Offender Monitoring Unit since May of this year. He notifies them whenever he comes to travel to New York. He never comes to New York for + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +### SORA HEARING page 8 + +more than seven days or at least he has not since he has been registered. He has no intention to ever be here for longer than a period of ten days. + +Like I said, he does notify the authorities when he is here. He fully understands the reason for voluntary registration, he wants to be compliant with the Federal SORA law which requires wherever you own aproperty to register. + +To require Mr. Epstein to register as aLevel Three offender in New York would actually require him to come to New York more than he does normally, it would require him to come every 90 days and renew his registration. + +He is very diligent in registering with New York authorities. + +All of the other jurisdictions that have considered his case have determined that he either not register at all or register at the lowest level, and he has been more than compliant with all of those requirements. + +Your Honor, we would join in the prosecutor's application. + +THE COURT: I am sure you would. + +MS. MUSUMECI: By way of background, we have been in contact with the prosecutor's office on this matter since Ibelieve certainly since Mr. Epstein got his notification, which I believe was in August. We have met with the + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +### SORA HEARING + +prosecutor and provided numerous materials for the prosecutor to consider. We have included in that a deposition from the detective who headed this investigation who acknowledged in asworn deposition that the lead prosecutor who originally had the case, whose name I cannot pronounce, Lanna Belohlavek, I apologize for the mispronunciation, said to the detective after her investigation, there are no real victims here. + +All of the alleged conduct that is cited in the board's write up was commercial conduct. All of the alleged conduct the women went voluntarily, there are no allegations of force certainly none. + +THE COURT: There was no allegation of force in the marine either, who met a girl in a bar, a young girl 17, there was no force there. + +MS. MUSUMECI: It is our understanding that the prosecutor in Florida conducted afull investigation, as full as she was able with the cooperation afforded by these complainants, and determined that the only case that she could present to the grand jury was this indictment for a non registrable offense then -- + +THE COURT: But it is registrable here. + +Idon't know what you mean non registrable offense. + +MS. MUSUMECI: Let me explain, Your- Honor. + +page 9 + +# SORA HEARING page 10 + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 ?5 + +Mr. Epstein plead to two charges, one was an indictment which is an offense that is not registrable, it is aFlorida indictment for -- + +THE COURT: Then why does he have to register here? + +MS. MUSUMECI: It was asecond offense that he plead to -- + +THE COURT: That is registrable. + +MS. MUSUMECI: That is registrable. + +That offense was by information and that is the only registrable offense, that is what the DA's office is considering in doing their scoring. + +The indictment which was the only case that the prosecutor even prosecuted through grand jury is not even a registrable offense. + +THE COURT: He plead guilty to a registrable offense. + +MS. MUSUMECI: Yes. + +THE COURT: What did he plead guilty to? + +MS. GAFFNEY: He plead guilty to the procuring a person under 18 for prostitution. + +THE COURT: Procuring a person under 18 for prostitution. + +MS. GAFFNEY: Right. + +THE COURT: How old was she? + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +## SORA HEARING page 11 + +MS. GAFFNEY: It appears the first time they met she was either 16 or 17, then for the remainder of their relationship she was probably 17. + +THE COURT: How long was their relationship? + +MS. GAFFNEY: She met, she gave him approximately 15 massages, including with sexual contact, and ultimately when she is 17 had intercourse with him. + +THE COURT: She is a child. + +MS. MUSUMECI: Your Honor, I would note that under SORA it is clear that prostitution offenses are only registrable when in fact by clear and convincing evidence the women or victim is 17, is under 17. + +THE COURT: Well, she met him at 16, he procured her at 16 from what I read. + +MS. MUSUMECI: There is evidence we challenged. + +THE COURT: He plead guilty to that, didn't he? + +MS. MUSUMECI: He plead guilty to under 18, which is the law in Florida, which is adifferent standard than what the law is in New York. And there is no evidence, there is no clear and convincing evidence as to her specific age at the time of the specific conduct. + +THE COURT: Well, the DA just told me she was most likely 17, she just said it on the record. + +MS. MUSUMECI: Your Honor, we agree that the evidence is that she was 17 on the one occasion she had + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +## SORP HEARING page 12 + +consensual intercourse with him and 17 is not registrable or criminal under New York law. + +And the prostitution aspect of having intercourse with a17 year old is not registrable conduct. + +THE COURT: Why does he have to register here? + +MS. GAFFNEY: Because it is aregister able offense in Florida, New York State board of examiners -- + +THE COURT: Recognizes it. + +MS. GAFFNEY: Recognizes it, yes. + +THE COURT: I have had many cases like that where it was not registrable here but it was in the state where the person came from and New York recognized that. + +MS. MUSUMECI: Your Honor, we are not saying that he should not register. Mr. Epstein has already registered and recognizes his duty to register. + +THE COURT: I am glad of that, very glad of that. + +Iam sorry he may have to come here every 90 days. + +He can give up his New York home if he does not want to come every 90 days. + +Anything else? + +Irely on the board. + +MS. MUSUMECI: Your Honor, we would reserve our right to appeal Your Honor's ruling. + +THE COURT: Of course, do so. + +MS. GAFFNEY: For the record, Your Honor, he is + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +# SORP HEARING + +going to be deemed aLevel Three sex offender with no designation, correct? + +THE COURT: Correct. + +MS. MUSUMECI: For purposes of the appeal I believe that Your Honor -- + +THE COURT: Give me the board's scoring. + +The board has scored use of violence the least, 10. + +page 13 + +Sexual contact with victim, 25. I agree. + +Number of victims, three or more. He only plead guilty to one, but apparently there were more than one and I think the People concede that although they say it was not reliable. + +Duration of offense, conduct with victim, continuing course of sexual misconduct, the People have told me it was continuing for 20 points. + +Age of victim 11 through 16, he got 20 points for that, and she was 16 at the time. + +Other victim characteristics, there was no mental disable or helplessness. I agree. + +Relationship with victim stranger, 20 points. + +Age at first act of sexual misconduct, 20 or less. They scored him zero on that. + +Number and nature of prior crimes, no history, they scored him five on that. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +## SOFtfi HEARING page 14 + +Recency of prior offense less than three years, they gave him zero. + +Drug or alcohol abuse history, they gave him zero. + +Acceptance of responsibility, they gave him zero. + +Conduct while confined, they gave him zero. + +And supervision, they gave him zero. + +Living employment situation, zero. + +They gave him 130 points, which is the highest level, and I agree with that. + +MR. LEFKOWITZ: If I could be heard for one moment. + +It appears that the state board made its determination based on access to a police report in Florida. + +The prosecutor, the lead prosecutor, the lead sex crimes prosecutor in Palm Beach made adetermination that the complainants and the police report itself was not credible and decided not to prosecute on the basis of all of that. + +In addition, there has been through the course of the last few years some civil litigation, as you might imagine, involving these matters and we now have sworn testimony in evidence from the complainants themselves disclaiming much of what appears in the police report. + +So, Your Honor, we would submit and this is not to make light in any way of the conduct what Mr. Epstein did or + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +### SORP HEARING + +what Mr. Epstein plead guilty to, but with respect to everything and that is why Mr. Epstein voluntarily registered in New York even though there is a question about whether he has any obligation just as ajurisdictional matter, but Your Honor, with respect to the appropriate level for him to register, we would submit Your Honor that the evidence simply does not support the foundation of the state's determination. + +THE COURT: You have made a very clear record and you have your right to appeal. + +Ifeel the board looked into all of this, made their recommendation, found him to have 130 points and I see no reason to disturb that. + +Thank you. + +page 15 + +I, Vikki J. Benkel, aSenior Court Reporter in and for the State of New York, do hereby certify that the foregoing transcript is true and accurate to the best of my knowledge, skill and ability. + +Vikki J. Benkel + +%rake J. Henkel Se Rio; Cowl Reporter + +![](_page_16_Picture_24.jpeg) + +**SMART** +Office of Sex Offender Sentencing, Monitoring, +Apprehending, Registering, and Tracking + +**SEX OFFENDER MANAGEMENT +ASSESSMENT AND PLANNING INITIATIVE** +*smart.gov/SOMAPI* + +## SOMAPI Report Highlights Adult Sex Offender Recidivism + +**Observed recidivism rates of sex offenders are underestimates of actual reoffending.** + +Sex crimes are one of the most underreported crimes and are often unseen by anyone other than the victim and perpetrator. Low reporting levels make it extremely difficult to estimate actual sexual recidivism rates. Additionally, only a small portion of sex offenses reported to law enforcement result in the offender's arrest. Therefore, it's generally recognized that observed recidivism rates are underestimates of the true reoffense rates of sex offenders. + +*Measuring sex offender recidivism is difficult due to underreporting and different methods used in research studies. Studies with longer follow-up periods show that recidivism increases over time. Furthermore, different "types" of sex offenders have different recidivism rates.* + +**Sex offender recidivism is difficult to measure.** + +Recidivism rates are measured differently from one study to the next, with different results. Studies differ in how recidivism is defined (i.e., rearrest vs. reconviction), how long offenders are followed and what types of offenders are included (i.e., rapists vs. child molesters). + +**Recidivism rates of sex offenders range from 5 percent after 3 years to 24 percent after 15 years.** + +Relatively low rates are reported in studies using observed sexual recidivism rates over follow-up periods shorter than 5 years. For example, a 2003 study (Langan, P., Schmitt, E., & Durose, M., "Recidivism of Sex Offenders Released From Prison in 1994," Bureau of Justice Statistics) found a sexual recidivism rate of about 5 percent using a 3-year follow-up period for a large sample of sex offenders released from prison. Studies employing longer follow-up periods consistently report higher rates of recidivism. For example, a 2004 study (Harris, A.J.R., & Hanson, R.K., "Sex Offender Recidivism: A Simple Question," Public Safety and Emergency Preparedness Canada) reported sexual recidivism rates of 20 percent and 24 percent for a sample of sex offenders based on a 10-year and 15-year follow-up period, respectively. + +**Sex offenders — regardless of type — have higher rates of general recidivism than sexual recidivism.** + +Recidivism studies have consistently found that adult sex offenders have much higher rates of general reoffending than sexual reoffending. A 2004 study (Hanson, R.K., & Morton-Bourgon, K., "Predictors of Sexual Recidivism: An Updated Meta-Analysis," Public Safety and Emergency + +Preparedness Canada) analyzed findings from 95 studies and found that sex offenders had an average overall recidivism rate of 37 percent compared to an average sexual recidivism rate of 14 percent, based on follow-up periods of 5 to 6 years. This suggests that policies aimed at protecting the public from sex offender reoffense should be concerned with the likelihood of any form of serious recidivism, not just sexual recidivism. + +**Female sex offenders reoffend at significantly lower rates than male offenders.** + +Five- to six-year rates of sexual recidivism for female sex offenders may be as low as 1 to 3 percent. The empirical evidence regarding the different recidivism rates of female and male sex offenders suggests that intervention and management practices need to differentiate between female and male sex offenders, and that methods for assessing risk of male sex offenders are unlikely to be accurate when applied to female sex offenders (Cortoni, F., Hanson, R.K., & Coache, M.È., "The recidivism rates of female sex offenders are low: A Meta-Analysis," Sexual Abuse: A Journal of Research and Treatment, 22; 2010). + +**Different types of sex offenders have different recidivism rates.** + +Research examining the recidivism of rapists and child molesters indicates that the highest observed recidivism rates are found among child molesters who offend against boys. Comparatively lower recidivism rates are found for rapists, child molesters who victimize girls and incest offenders. + +*The opinions, findings and conclusions or recommendations expressed in this summary are those of the authors and contributors and do not necessarily represent the official position or policies of the SMART Office or the U.S. Department of Justice. For more information about SOMAPI and this topic, visit [www.smart.gov/SOMAPI](http://www.smart.gov/SOMAPI).* + +| I | ASSET SUMMARY - JUNE 30, 2019 | | +|---------------------------------------------------------------|---------------------------------------------------------------------|--------------| +| Asset | | Value | +| Cash | \$ | 56,547,773 | +| * Fixed Income | \$ | 14,304,679 I | +| * Equities | \$ | 112,679,138 | +| * Hedge Funds & Private Equity | \$ | 194,986,301 | +| *** 9 East 71st Street, New York, NY 10021 | \$ | 55,931 000 | +| 49 Zorro Ranch Road, Stanley New Mexico 87056 | \$ | 17,246,208 | +| 358 El Brillo Way, Palm Beach, FL 33480 | \$ | 12,380,209 | +| 22 Avenue Foch, Paris France 75116 | \$ | 8,672,823 | +| Great St James Island No. 6A USVI 00802 (parcels A,B,C) | \$ | 22,498,600 | +| **** Little St James Island No. 6B USVI 00802 (parcels A,B,C) | \$ | 63,874,223 | +| Total Assets | \$ | 559,120,954 | +| * Values reflect gross numbers that are not net of tax | 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Mollo Building One Saint Andrew's Plaza New York. New York 10007 + +July 15, 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 submits this letter respectfully to request the exclusion of speedy trial time between July 15, 2019, and July 18, 2019, the date of the next conference in the abovecaptioned case, in the interests of justice and pursuant to 18 U.S.C. § 3161(h)(7)(A) and a). have conferred with defense counsel, who consent to this request. + +By: + +Alex Rossmiller / Alison Moe / Maurene Comey Assistant United States Attorney Southern District of New York Tel: (212) 637-2415 / 2225 / 2324 + +Very truly yours, + +GEOFI FtEY S. 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Berman United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 + +The SiMo Moll\* Building One Saint Andrew's Plaza New York, New York 10007 + +July 15, 2019 + +MEMO ENDORSED + +Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) + +Dear Judge Berman: + +SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED:-/ .lr - + +The Government submits this letter respectfully to request the exclusion of speedy trial time between July 15, 2019, and July 18, 2019, the date of the next conference in the a ovecaptioned case, in the interests of justice and pursuant to 18 U.S.C. § 3161(h)(7XA) and g). I have conferred with defense counsel, who consent to this request. + +By: + +Alex Rossmiller / Alison Moe / Maurene Comey Assistant United States Attorney Southern District of New York Tel: (212) 637-2415 / 2225 / 2324 + +Very truly yours, + +GEOFFREY S. 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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: + +[REDACTED] G. Weinberg, Esq. +G. Weinberg, P.C. +20 Park Plaza, Suite 1000 +Boston, [REDACTED] 02116 +Telephone: (617) 227-3700 +Facsimile: (617) 338-9538 +[owlmgw@att.net](mailto: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: 7/16/19 + +RMB +Richard M. 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Conference + +7 8 x New York, N.Y. July 8, 2019 2:00 p.m. + +9 Before: + +10 11 HON. RICHARD M. BERMAN District Judge + +12 + +13 + +14 + +15 16 17 18 GEOFFREY S. BERMAN United States Attorney for the Southern District of New York ALEXANDER ROSSMILLER MAURENE R. COMEY ALISON G. MOE Assistant United States Attorneys + +19 + +20 21 REID H. WEINGARTEN G. WEINBERG MARC FERNICH Attorneys for Defendant + +22 Also Present: + +23 + +24 25 AMANDA YOUNG - Special Agent FBI PAUL BYRNE - NYPD KEYANA POMPEY - Probation Officer LEA HARMON - Probation Officer + +APPEARANCES + +2 THE COURT: Good afternoon. + +3 4 5 6 7 I think I'm pretty much up to speed as to where you are in the sense that I am aware that you have been before Magistrate Judge Pitman earlier this morning and up to some few minutes ago for purposes of presentment, arraignment, and some preliminary discussion of bail. Is that accurate? + +8 9 10 11 12 13 MR. ROSSMILLER: That's correct, your Honor. I don't want to speak for defense counsel, but my understanding is they expect to put in some sort of written submission and return to argue the rest of the bail hearing on Thursday before Judge Pitman at 2:00. That is, if your Honor refers the bail hearing to Judge Pitman on that basis as well. + +14 15 16 THE COURT: I might just take that bail application before me. We'll figure out a time when that would be comfortable for all of you. How is that? + +17 18 MR. WEINGARTEN: That's fine with the government, your Honor. + +19 20 21 22 23 24 25 THE COURT: I have a few items on my list. I want to make mention, I'm sure Magistrate Judge Pitman did, of our presumption of innocence. Even though in some of these discussions, and probably more so when we get to bail, it may sound like we are talking about merits of the case, it's important that we underscore that the presumption of innocence pertains to Mr. Epstein, now and until such time, if it comes, + +1 2 that there is a guilty determination by a jury or by the Court, that he is presumed to be innocent. + +3 4 5 6 7 I did have these questions. One has to do with persons who are categorized as victims. I want to get some assurance from the U.S. Attorney's office that they have been notified about this case and that you will keep them abreast of developments in this case. + +8 9 10 11 MR. ROSSMILLER: Yes, your Honor, we are acutely aware of our obligations to the victims in this case. We have notified them and we expect to continue to do so as the case moves forward. + +12 13 14 15 16 17 18 THE COURT: Second, for my background, I am aware that there are certain conditions that attach to Mr. Epstein's sex offender status resulting from his Florida state prosecution in or about 2008. One result is that under New York law - correct me if I'm wrong about any of this -- he is considered to be at high risk of committing another sex crime with minors. Is that a fair characterization of his sex offender status? + +19 20 21 22 23 MR. ROSSMILLER: Your Honor, as the government set forth in its submission to Judge Pitman, and we copied this Court, it is our understanding that the defendant is a tier 3 sex offender in New York and that that is characterized as high-risk individual. + +24 25 THE COURT: The question that I have is what are the implications, if any, of the search conducted by the U.S. + +1 2 3 4 5 Attorney's office over the weekend of Mr. Epstein's residence on East 71st Street for the terms and conditions of his sex offender status, if any? Are there any consequences or relationship between what was uncovered and what he is obliged to do? + +6 MR. ROSSMILLER: May I have one moment, your Honor? + +7 THE COURT: Yes. + +8 9 10 11 12 13 14 15 16 MR. ROSSMILLER: Your Honor, in response to that question, at the outset I should say that we don't have particular interaction with state authorities with respect to those types of notifications. We are, I would say, in the early stages of reviewing those materials. With respect to the defendant's obligations or potential consequences in the New York State system, we certainly will notify whichever authorities are appropriate. I don't think that we have a role other than that. + +17 18 19 20 I will say that they are extremely concerning with respect to bail here, with respect to the conduct here, and I expect we will get into that more in our submissions and bail argument. + +21 22 THE COURT: By the way, if defense counsel wants to jump in at any point, feel free to do that? + +23 24 MR. WEINGARTEN: On that, we have not seen the pictures. + +25 THE COURT: I haven't either. + +1 2 3 4 MR. WEINGARTEN: I understand. It is our expectation that they are ancient, that they are pre his spending time in prison, and/or they are erotic pictures of adults who voluntarily engaged in that conduct. + +5 6 7 THE COURT: I have a question about the Southern District of Florida nonprosecution agreement dated probably in 2008 -- is that correct? + +8 MR. ROSSMILLER: It's dated in 2007, your Honor. + +9 THE COURT: Is that a public document? + +10 11 MR. WEINGARTEN: It is, your Honor. It's been publicly filed in connection with other civil litigation. + +12 13 14 THE COURT: Does that agreement bear on in any way the search and results of the search that were conducted at Mr. Epstein's townhouse over the weekend? + +15 16 17 18 MR. ROSSMILLER: Not in ways that I am aware of now, your Honor. Again, we are very much in progress on the search. We will continue to consider any other implications beyond this case as we continue to review those materials. + +19 20 21 22 23 24 25 On a separate note, your Honor, I want to add the government noted it is aware of its victim obligations. In terms of notification, we have made notification to individuals that we are in particular aware of. We also have listed a phone number for victims to be in touch with the FBI, with the U.S. Attorney's office. We have also put a website up and have asked victims to be in touch with us through those sources as + +1 2 well. That is just to round out the notification that the U.S. Attorney's office has made. + +3 MR. WEINGARTEN: May I be heard briefly on that? + +4 THE COURT: Sure. + +5 6 7 8 9 10 11 12 MR. WEINGARTEN: For us, your Honor, the NPA is the center of the universe for everything, search included, because the NPA was the result of an extensive 3-year investigation by law enforcement in Florida. In essence, the Feds made Mr. Epstein plead to a state offense and they declined prosecution federally, and that is translated in the NPA Mr. Epstein did his time, Mr. Epstein is on the registration list, and Mr. Epstein paid the alleged victims. + +13 14 15 16 17 18 19 20 21 As I am sure you have noted from the indictment, that conduct too is an ancient history. That conduct is 2002 to 2005. It is our belief that this is basically a re-do. This is basically the Feds today, not happy with what happened in the decision that led to the NPA, redoing the same conduct that was investigated 10 years ago and calling it, instead of prostitution, calling it sex trafficking. We think that is the heart of everything, and that will be the centerpiece of our defense, at least legally. + +22 23 24 25 THE COURT: My understanding of what the government is asserting is that the episodes that occurred in Manhattan were not included in the nonprosecution agreement in Florida and that there is a separate basis not only for a sex trafficking + +2 3 4 5 6 7 8 MR. WEINGARTEN: We have had good conversations with the prosecutors, and we like and respect them. We are looking forward to getting discovery. We are interested to see whether the prosecutors in Florida, who are now under severe criticism 10 years later, steered the alleged victims to New York, whether or not they violated their responsibilities under the NPA. + +9 10 THE COURT: Whether the federal prosecutors in Florida violated their terms and conditions? + +11 MR. WEINGARTEN: That will certainly be germane. + +12 THE COURT: Is that the point? + +13 MR. WEINGARTEN: Yes. + +14 THE COURT: Got it. + +15 16 MR. ROSSMILLER: Your Honor, if I could very briefly respond to those points? + +17 THE COURT: Sure. + +18 19 20 21 22 23 MR. ROSSMILLER: I expect this will be briefed and argued on Thursday. I don't intend to go into extensive details about that. I just want to flag for the Court that defense counsel is saying that this conduct is ancient. What he is not saying is it is beyond the statute of limitations, because it is not. + +24 25 Second, the allegation that this is some kind of a conspiracy within the Department of Justice is just false. + +1 2 3 There is no evidence to support that. The investigation was begun and conducted entirely separate from any other district. It began in the Southern District of New York. + +4 5 6 7 8 9 10 Certainly there is evidence that was gathered that is consistent with and even overlapping with the prior investigation. But as the Court noted, in particular an entire count of this indictment is with respect to New York victims. And that is before we even get to the fact that the nonprosecution agreement does not bind the Southern District of New York. + +11 12 THE COURT: I was going to ask you about that too. Now that you have mentioned the topic, explain that, would you. + +13 14 15 16 17 18 MR. ROSSMILLER: Yes, your Honor. I do expect that we can brief this, but the short version is that this prosecution is not precluded by the nonprosecution agreement entered into by the defendant in the Southern District of Florida. That agreement expressly referred to that federal district. It didn't purport to bind any other office or district. + +19 20 21 22 23 24 25 It is well-settled in the Second Circuit that a plea agreement in one U.S. Attorney's office does not bind another unless otherwise stated. That is even if, based on case law, the agreement refers generally to "the government." Again, additionally, as set forth in the indictment returned by the grand jury, the substantive count alleges acts occurring in New York and alleges New York-based victims. + +1 2 3 4 5 That is in spite of the fact that the Southern District is not bound, is not a signatory to, and otherwise has no connection to the NPA. And there is no evidence that we have come across that the Southern District of New York was consulted, asked, involved, notified as far as we have seen. + +6 7 For those reasons and others I'm sure we will brief, we don't think the NPA applies to us. + +8 MR. WEINBERG: If I may reply briefly, your Honor? + +9 THE COURT: Yes. + +10 11 12 13 14 15 16 17 MR. WEINBERG: I have been one of Mr. Epstein's counsel through the CVRA litigation which started in 2008 and continues. In fact, our briefing is today. The NPA provided him with immunity for any offenses arising from a joint FBI/grand jury/U.S. Attorney investigation that led to a decision by Mr. Epstein to plead to a higher state offense than the state prosecutors contemplated. He went to jail, signed an agreement, and has lived up to its terms 100 percent. + +18 19 20 21 22 23 24 25 We have seen in the paperwork of the CVRA, in the Southern District of Florida, in writing at docket 205-2 the government's motion to dismiss CVRA, urging that the witnesses there go to the Southern District of New York and essentially try to motivate them to prosecute for the very same conduct, in other words, the conduct that Mr. Epstein was immunized, including travel between two states, telephonic communications between two states. Florida immunized him for the same travel + +2 3 4 5 6 7 8 9 In addition, the Department of Justice reviewed the NPA on several occasions in 2008 and essentially confirmed that the exercise of discretion shown in Florida was appropriate. But the most important thing is that there was communication between the prosecutors in Florida, perhaps through prosecutors in Georgia that took over the case because the Florida prosecutors were recused as a result of Judge Marrah's decisions in the CVRA case. + +10 11 12 13 14 15 16 17 We know the government is relying in part on evidence that was generated by the Southern District of Florida case back in 2007. They have talked about message pads, telephone records. They are the same message pads and telephone records that reflect conduct that was exclusively 15, 16, 17 years ago. So we do have a principal position that we will put to the Court at the appropriate time regarding the legality of this prosecution and whether or not it is appropriately barred. + +18 19 20 21 22 23 24 25 I can say as a criminal defense lawyer of 45 years, when there is an interstate wire, mailing, travel, and there is one district that is conducting an investigation, you negotiate with that district and count on the Department of Justice to what it does every day decade after decade after decade, which is not to go to the second jurisdiction that received the mail that was sent from the immunizing jurisdiction and have a prosecution on the very same conduct. We will be briefing + +2 3 THE COURT: Do you anticipate that there is going to be any discussion here about the legality of the NPA? + +4 5 MR. WEINBERG: Not the legality of the NPA. I think the discussion here is going to be about its scope. + +6 7 THE COURT: From the defense, yes. You don't think you expect to hear anything from the government, for example? + +8 9 10 11 12 13 14 15 16 17 MR. WEINBERG: In the Southern District case, the CVRA case, maybe two weeks ago the Northern District of Georgia prosecutors, who are proxy for the Southern District of Florida, filed the submission before District Judge Marrah in the CVRA case totally supporting the constitutionality and legality of the NPA, their discretion to enter into it, and that there absolutely has never been a charge that Mr. Epstein ever did anything other than fully perform his end as a citizen who is expecting the benefits of a contract that he lived up to. + +18 19 20 21 THE COURT: I thought there had been some contention that the way that the victims vis-a-vis the Florida NPA were dealt with or not dealt with was one basis for attacking the legality of that arrangement. + +22 23 24 25 MR. WEINBERG: The petitioners are vigorously and have vigorously for many years challenged, many years starting quite frankly after Mr. Epstein performed his obligations to go to jail and challenged it, claiming that there was no consultation + +2 3 4 5 6 7 8 The Department of Justice at the time did not believe the CVRA extended absent a federal charge. The predicate is a federal crime that harms a victim. The petitioners have vigorously asserted a different position. Judge Marrah, in a summary judgment motion, agreed with the petitioners as to the fault of the government in not conferring. The issue of remedy is before Judge Marrah at the present time, your Honor. + +9 THE COURT: Okay. + +10 MR. ROSSMILLER: Your Honor, if I may very briefly? + +11 THE COURT: Yes. + +12 13 14 15 16 17 18 19 20 MR. ROSSMILLER: The crux of the defense argument here I think cuts precisely the other way. They are arguing that the Southern District of Florida has sort of sent up a flag that these prosecutions could be undertaken elsewhere. That's true. The Southern District of Florida has argued in papers that they believed, the Southern District of Florida believed, that the nonprosecution agreement was limited to that district. They have said that out loud and in public and in their positions in filing. + +21 22 23 24 25 So certainly this investigation was not shoveled to the Southern District of New York from anywhere else, including the Department of Justice. We expect that the nonprosecution agreement will not be an impediment, in particular because the defendant certainly did not lack for sophisticated counsel in + +1 2 3 negotiating that agreement, which again did not include the Southern District of New York. We don't expect that to be any impediment at all here. + +4 THE COURT: Got it. + +5 6 7 This is a small item. In the pretrial services report which was prepared today -- how many, if more than one, passports does Mr. Epstein have? + +8 9 10 MR. WEINGARTEN: Mr. Epstein reported today one. Two others were rescinded. As we understand it, there is one effective passport today. + +11 12 I would like to make one other point about the pretrial that is extremely important. + +13 THE COURT: Go ahead. + +14 15 MR. WEINGARTEN: The way it reads is that we have refused to provide information about income and assets. + +16 17 18 19 THE COURT: I didn't really read it that way myself. I thought it was incomplete in some places and I thought it could be beefed up, so to speak. But I imagine that in the bail application those matters may be dealt with. + +20 MR. WEINGARTEN: Exactly. + +21 22 23 24 25 THE COURT: For Mr. Rossmiller: In your letter you describe some obstruction or harassment, witness tampering, alleged, by Mr. Epstein. That, I take it, is going to be included in any response or any bail submission made by the government? + +1 2 3 4 5 MR. ROSSMILLER: Your Honor, I think we addressed that in our initial submission. To the extent defense counsel has a response to it, we will evaluate that response and see whether additional submission from the government is required or appropriate. + +6 7 THE COURT: I think that's it for me in terms of questions that I might have had. + +8 9 10 11 There is, of course, a conspiracy charge here, one of the two counts. It may be early in your investigation to know. Do you anticipate that there may be other defendants in this proceeding? + +12 13 14 MR. ROSSMILLER: Your Honor, we don't expect any imminent superseding indictments in this case. It certainly is possible down the road. + +15 16 17 18 19 20 21 22 MR. WEINGARTEN: May I make one point, your Honor? These obstruction allegations we find very nettlesome and bothering. My understanding is that the Feds and Mr. Epstein's attorneys back in the early 2000s, or 2007 and 8, when they were negotiating were looking desperately for an appropriate statute. They finally settled on a state statute that Mr. Epstein pled to. We all know how unusual that is. There was some consideration of a federal statute, including obstruction. + +23 24 25 So lawyers in good faith were having discussions back and forth whether or not they could squeeze Mr. Epstein's conduct into a particular statute, and they concluded they + +1 2 couldn't because the facts didn't fit. That is my understanding of how those obstruction discussions arose. + +3 THE COURT: Got it. + +4 5 6 7 8 9 10 In terms of bail application, it would be helpful, and maybe this is your anticipation, to file written submissions. If you could do that. What I'm getting to is Thursday afternoon is not a good time, in my opinion. I would prefer to do it, if you would go along with this, Monday morning at, say, 9:30. That would give everybody more time to make these submissions and to study them. Is that agreeable? + +11 MR. WEINGARTEN: Yes. + +12 MR. WEINBERG: Yes. + +13 14 15 THE COURT: Why don't we say Monday at 10:00. Have you arranged written submissions on any time schedule with Magistrate Judge Pitman? + +16 17 MR. ROSSMILLER: May we have just a moment, your Honor, with defense counsel? + +18 19 20 THE COURT: Yes, would you. And also determine if one party or the other is going first and that the other is responding or they are simultaneous. + +21 MR. ROSSMILLER: Yes, your Honor. Thank you. + +22 (Pause) + +23 24 25 MR. ROSSMILLER: Your Honor, the government is prepared to rely on its initial submission at least for its first argument. I expect defense counsel will respond to that + +1 2 and propose a package. Then the government would like an opportunity to reply to that submission. + +3 4 5 6 7 8 9 The parties would be happy to make those deadlines Thursday and Saturday respectively. However, we are also happy to back that up a little bit if the Court prefers not to receive the government's submission over the weekend. We could do an earlier deadline on Thursday for defense and a late Friday deadline for the Court from the government, depending on what the Court prefers. + +10 11 THE COURT: I was going to propose defense Thursday at noon. Is that okay to get your submission in? + +12 MR. WEINBERG: We can do that, your Honor. + +13 THE COURT: Thanks. + +14 And if you could respond Friday by 5:00 p.m. + +15 MR. ROSSMILLER: We will, your Honor. Thank you. + +16 17 18 19 THE COURT: Then we can have oral presentations. I take it everybody wants to have oral presentations in addition to the written. I'll set aside as much time as we need on the 15th at 10:00. + +20 21 I ask the government if there is a speedy trial issue or application that takes us to Monday at 10:00 a.m. + +22 23 24 25 MR. ROSSMILLER: Yes, your Honor. The government asks that speedy trial time be excluded until Monday. We do expect to begin the process of working on producing discovery, to include discussions with defense counsel about a protective + +1 2 3 4 order. I think, frankly, the outcome of that will be effected by the coming week. But we do expect to have those conversations and therefore request that speedy trial time be excluded until Monday. + +5 6 7 8 9 THE COURT: I am going to find under 18 United States Code 3161 that the request for adjournment, joined in by both sides, to and including Monday the 15th at 10:00 a.m., is appropriate and warrants exclusion of the adjourned time from speedy trial calculations. + +10 11 12 13 14 15 16 17 I further find that the exclusion is designed to prevent any possible miscarriage of justice to facilitate these proceedings and, initially at least, so that counsel has time to prepare written bail submission and to guarantee effective representation of and preparation by counsel for both sides. Thus, the need for exclusion and the ends of justice outweigh the interests of the public and the defendant in a speedy trial pursuant to 18 U.S.C. section 3161(h)(7)(A) and (B). + +18 Does anybody want to add anything to today's session? + +19 20 MR. ROSSMILLER: Your Honor. May we have one more moment with defense counsel? + +21 THE COURT: Sure. + +22 (Pause) + +23 24 MR. ROSSMILLER: Nothing from the government. Your Honor. + +25 THE COURT: Defense? + + THE COURT: Nice to see you all. 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calendar days from the date of filing of this NOTICE to file with the court any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically available to the public without redaction after ninety (90) calendar days. + +This process may only be used to redact the following personal data identifiers: Social Security numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information may proceed by motion. + +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. + +Is + +Court Reporter/Transcriber Date \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824283/EFTA02824283.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824283/EFTA02824283.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ec0e2a452edca0384d73ddd990e5b056a46e9c60 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824283/EFTA02824283.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824283.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1428, + "elapsed_seconds": 0.85, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "IN THE UNITED STATES DISTRICT COURT \nFOR THE SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 153.612, + 67.23 + ], + [ + 418.71282958984375, + 67.23 + ], + [ + 418.71282958984375, + 96.363037109375 + ], + [ + 153.612, + 96.363037109375 + ] + ] + }, + { + "title": "NOTICE OF FILING OF OFFICIAL TRANSCRIPT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 167.688, + 308.6015625 + ], + [ + 448.52362060546875, + 308.6015625 + ], + [ + 448.52362060546875, + 322.4830627441406 + ], + [ + 167.688, + 322.4830627441406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 28 + ], + [ + "Text", + 15 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824283" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824284/EFTA02824284.md b/marker2/court-us-v-epstein-cr/EFTA02824284/EFTA02824284.md new file mode 100644 index 0000000000000000000000000000000000000000..7d19ac19d6b7c4e088879c287fa8103972a66b74 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824284/EFTA02824284.md @@ -0,0 +1,741 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +UNITED STATES OF AMERICA, + +v. + +JEFFREY EPSTEIN, + +Defendant. + +Before: + +New York, N.Y. + +19 Cr. 490(RMB) + +x Conference + +July 8, 2019 + +1:20 p.m. + +HON. HENRY B. PITMAN, + +Magistrate Judge + +APPEARANCES + +GEOFFREY S. BERMAN + +United States Attorney for the Southern District of New York + +BY: ALEXANDER ROSSMILLER + +ALISON J. MOE + +MAURENE R. COMEY + +Assistant United States Attorneys + +STEPTOE & , LLP + +Attorneys for Defendant + +BY: REID H. WEINGARTEN + +G. WEINBERG + +Attorney for Defendant + +MARC FERNICH + +Attorney for Defendant + +Also Present: + +Special Agent Amanda Young, FBI + +Detective Paul Byrne, NYPD + +4 5 6 7 MR. ROSSMILLER: Good afternoon, your Honor. For the government, Alex Rossmiller, Alison Moe, and Maurene Comey. With us are Special Agent Amanda Young of the F.B.I. and Detective Paul Byrne, NYPD task force officer. + +8 THE COURT: Okay. + +9 10 11 MR. WEINGARTEN: Good afternoon, your Honor. For Jeffrey Epstein, Reid Weingarten from the law firm of Steptoe & + +12 13 14 15 MR. WEINBERG: Good afternoon, your Honor. Weinberg. I'm an attorney from Boston, Massachusetts; and, with your Honor's permission, I will be filing a pro hac vice to represent Mr. Epstein. + +16 THE COURT: Okay. + +17 18 MR. FERNICH: Good afternoon, your Honor. Marc Fernich, New York, New York, also for Mr. Epstein. + +19 20 21 THE COURT: All right. I have spoken to Judge Berman. The matter has been referred to me for the initial appearance, arraignment, and bail. + +22 23 24 25 Mr. Epstein, my name is Magistrate Judge Pitman. The purpose of this proceeding is to inform you of certain rights that you have, to inform you of the charges against you, to consider whether counsel should be appointed for you, and to + +(Case called) + +THE DEPUTY CLERK: Counsel, please state your name for the record. + +4 MR. ROSSMILLER: Yes, your Honor. The defendant was arrested on Saturday, July 6, at approximately 5:30 p.m. + +5 THE COURT: Thank you. + +6 7 8 9 10 Mr. Epstein, you have the right to remain silent. You are not required to make any statements. Even if you have made any statements to the authorities, you need not make any further statements. Anything you do say can be used against you. + +11 12 13 14 15 You have the right to be released, either conditionally or unconditionally, pending trial unless I find that there are no conditions or combination of conditions that would reasonably assure your presence in court and the safety of the community. + +16 17 18 19 You have the right to be represented by counsel during all court proceedings, including this one, and during all questioning by the authorities. If you cannot afford an attorney, I will appoint one to represent you. + +20 21 22 23 24 25 It is my understanding that you are being represented by retained counsel. I want to advise you that the right to the appointment of counsel is an ongoing right that you possess throughout these proceedings. If at any time you are unable to continue with retained counsel for financial reasons, you can apply to the court at any time for the appointment of counsel. + +decide under what conditions, if any, you should be released. + +Can I have the date and time of arrest, please? + +4 THE COURT: Mr. Epstein, you are charged in an indictment in two counts. + +5 6 Count One charges you with a sex trafficking conspiracy in violation of Title 18 United States Code § 371. + +7 8 9 Count Two charges with you with the substantive offense of sex trafficking in violation of Title 18 United States Code § 1591. + +10 11 Mr. Weingarten, are you going to be lead counsel here today? + +12 MR. WEINGARTEN: Yes, your Honor. + +13 14 THE COURT: Mr. Weingarten, have you received a copy of the indictment? + +15 MR. WEINGARTEN: Yes, your Honor. + +16 THE COURT: Have you reviewed it with your client? + +17 MR. WEINGARTEN: Yes, your Honor. + +18 THE COURT: Do you waive its reading? + +19 MR. WEINGARTEN: Yes, your Honor. + +20 THE COURT: Mr. Epstein, how do you plead? + +21 THE DEFENDANT: Not guilty, your Honor. + +22 23 24 25 THE COURT: Because the defendant has been indicted, there will be no preliminary hearing, and that takes us to the question of bail. In that regard, I have received the Pretrial Services report. I have also received a letter from the + +Do you understand that? + +THE DEFENDANT: Yes, your Honor. + +4 5 THE COURT: I will hear from the government first, and then I will hear from defense counsel. + +6 MR. ROSSMILLER: Yes, your Honor. + +7 8 9 The government intends to seek detention, and I am happy to explain the reasons why. Would the court prefer that I speak from the table or from the podium? + +10 THE COURT: Whatever your pleasure is. + +11 12 13 14 15 16 17 MR. ROSSMILLER: Your Honor, the defendant poses an extraordinary risk of flight and danger presented by him. Given the charges and the characteristics of the defendant, he simply cannot reasonably be expected to appear in court if he is granted bail. Accordingly, the government joins the recommendation of Pretrial Services that the defendant be detained pending trial for a number of reasons. + +18 19 20 21 22 Starting with the conduct alleged, the defendant is charged with trafficking minors for sex acts, as the court explained, in violation of 18 United States Code § 591, and is charged with a count of conspiracy to traffic minors for sex acts in violation of 18 U.S.C. 371. + +23 24 25 In particular, the indictment charges that the defendant engaged in a years-long scheme to sexually abuse underage girls, paying minor girls to themselves be abused, and + +government dated July 8, 2019. + +I take it all counsel have the same documents? + +MR. WEINGARTEN: Yes, your Honor. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +also paying certain victims to recruit other girls to be subject to the defendant's sexual abuse. + +The indictment alleges that the defendant undertook this conduct at at least two locations, including his mansion in Manhattan and his estate in Palm Beach, Florida. In both locations, 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 contact with the victims' genitals. These victims, who were often particularly vulnerable, were as young as 14, and the defendant knew he was abusing underage girls. The indictment further alleges that the defendant perpetrated these crimes by working with others, including employees and associates who facilitated these abusive encounters. + +Regarding the defendant himself, your Honor, he is extraordinarily wealthy, mobile, and unattached to the Southern District of New York. He maintains at least six residences in the United States and abroad, including the ownership of a private island in the U.S. Virgin Islands and a residence in Paris, France. Among other things, the defendant owns two private jets and routinely uses them to travel abroad. He is a man of nearly infinite means, your Honor; and, as set forth in our submission, he has tremendous incentives to use those means to flee prosecution. + +4 5 The government notes as an initial matter that this is a presumption case because sex trafficking is charged; and, moreover, each of the four factors to be considered in the detention analysis strongly militates towards pretrial detention. + +6 7 8 9 10 So starting with the nature and seriousness of the offense, as previously discussed, the nature and circumstances of the crime are the most serious crime that this court sees. The defendant is alleged to have spent years sexually abusing minors in multiple locations and with dozens of victims. + +11 12 13 14 15 16 17 The seriousness of the charge is also reflected in the potential penalties, which include up to 45 combined years of incarceration on Counts One and Two, and the likelihood of a substantial period of incarceration is supported by the fact that the government's evidence is strong. There are multiple individual identified victims in the indictment, numerous specified overt acts, and dozens of overall victims alleged. + +18 19 20 21 22 23 24 In order to protect the privacy of the victims, your Honor, I'm not going to go into detail about particular victims, but we can say that information provided by victims has been detailed, it has been credible, and it has been corroborated by other witnesses and contemporaneous documents and records, including from a recent search of the defendant's Manhattan mansion, as I will discuss further in a moment. + +25 Separately, your Honor, in just the last 36 hours, 4 5 that is, post charge, we have been contacted by multiple attorneys and several additional individuals who have identified themselves as victims and are interested in speaking with the government, none of whom the government has previously spoken with. + +6 7 8 9 10 11 Your Honor, the defendant is 66 years old. He is charged with appalling crimes, and those charges are supported by significant evidence, including victim and witness testimony and damning record evidence. He faces the very real prospect of spending the rest of his life in prison. He has every motivation in the world to flee, and he has the means to do it. + +12 13 14 15 16 17 18 19 And I will note for the court that this is a case where the government has really put its money where its mouth is on the risk of flight. This district took extraordinary efforts to maintain the covert status of its investigation for many months due to the risk of flight of the defendant -- not a single media report, not a single public statement, no appeals for victims to come forward because of precisely the flight risks we are discussing now. + +20 21 22 23 24 25 Turning to the characteristics of the defendant, your Honor, some individuals who face significant charges lack the means to flee. Not this defendant. As set forth in the government's submission, in the defendant's most recent sex offender registration, he lists six residences worth tens or hundreds of millions of dollars, including a residence abroad. + +4 5 6 7 8 9 10 11 12 13 14 The defendant has refused to answer any questions about his income or assets for the Pretrial Services report, so the scope of his wealth and his assets remains entirely concealed to the government and to the court. But the defendant certainly has access to endless means to flee, including two private jets. He has no meaningful family ties, and any argument that his properties would keep him in the United States ignores his ability to simply leave those properties behind in favor of moving beyond the reach of U.S. authorities to live off his extensive wealth abroad, extensive wealth, I should add, that the court doesn't even have any accounting of. He travels abroad extensively, has a residence in France, and all of those factors further contribute to the risk of flight. + +15 16 17 18 19 20 21 With respect to danger and obstruction, again, this is a presumption case, and not only is the defendant charged with the sexual abuse of minors, he has previously pled guilty to solicitation of an underage girl. This court knows that defendants are routinely detained in this district when facing such charges and that this is not an unusual position for the government to take. + +22 23 24 25 It is further concerning that there are credible allegations from the prior investigation that the defendant or his agents engaged in witness tampering and harassment, and in fact there is evidence that he was contemplating pleading + +4 guilty to that kind of offense in Florida. Those allegations include verbal harassment, evasion of legal process, and forcing off the road the father of an individual relevant to that investigation. + +5 6 THE COURT: Can you elaborate on that last point about forcing somebody off the road? + +7 8 9 10 11 12 13 14 15 MR. ROSSMILLER: Your Honor, what we have is the record evidence from an underlying civil dispute in Florida that discusses this incident and discusses it in the context of a potential plea of the defendant to obstruction or harassment charges. The government sets before this court that if the defendant was willing to undertake such measure simply as a result of an investigation, the potential for dangerous and obstructive activity in an indicted case is alarming and very real. + +16 17 18 19 20 21 22 23 24 Despite having been previously convicted of a sex offense involving an underage victim and being a registered sex offender, the defendant has continued to maintain a vast trove of lewd photography of young-looking women or girls at his mansion. Your Honor, pursuant to judicially authorized warrants, law enforcement agents searched his home on Saturday and found at least hundreds, and perhaps thousands, of sexually suggestive photographs of nude females, many of whom appear to be underage. + +25 I also want to note that the search revealed specific + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +evidence from his home consistent with victim accounts. Even the room where the abuse occurred, your Honor, the massage room, was still set up in the same way it was 15 years ago, with a massage table and sex paraphernalia. + +And with respect to the photographs + +THE COURT: When you say the evidence was consistent with victim accounts, is it limited to the massage table and massage room or is there something else? + +MR. ROSSMILLER: Descriptions of the massage room and the massage table, that's correct, your Honor. + +THE COURT: Okay. All right. + +MR. ROSSMILLER: With respect to the photographs, your Honor, some of those were found in a locked safe which also held electronic disks with labels that included the words "Young Miscellaneous Nudes 1" and "Girl Pics Nude." + +Your Honor, this is not an individual who has left his past behind. He is a continuing danger to the community and an extraordinary risk of flight and, for those reasons, the government joins the pretrial recommendation that the defendant be detained pending trial. + +THE COURT: All right. Thank you. + +Mr. Weingarten. + +MR. WEINGARTEN: Thank you, your Honor. I will use the podium, if that's okay. + +THE COURT: That's fine. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +MR. WEINGARTEN: So your Honor, I would like to start by providing some context, and then I'm going to make a suggestion as to how we proceed. + +The beginning here is 2005 in Florida. That's when an allegation was received by the local police that Mr. Epstein was engaged in sexual conduct for money, prostitution. Thereafter, there was a very sophisticated three-year investigation by law enforcement, including locals and feds, into Mr. Epstein's conduct. Numerous girls were interviewed, employees were interviewed, and it is fair to say that a significant segment of the law enforcement community in Florida thought what we had in hand was simple prostitution. There was no coercion. There were no threats. There was no violence. And it is also fair to say that a significant portion of the law enforcement community in Florida believed that a local misdemeanor was the appropriate sanction. + +Now, it is also -- + +THE COURT: Did you represent Mr. Epstein in the Florida investigation? + +MR. WEINGARTEN: No, but I'm familiar with the records. + +THE COURT: All right. + +MR. WEINGARTEN: It is also true that there was a contrary view largely taken by the feds, and what ensued was a complex set of discussions and negotiations and finally an + +agreement, an agreement that was consummated and agreed to all the way up to main justice at a very, very high level. + +4 5 6 7 8 9 The agreement involved a plea in soliciting an underaged girl, which would compensation paid to alleged victims, and state court to require registration, an NPA from the feds, in other words, a declination by the federal government, an agreement that was approved all the way up in main justice and it sure seemed like a global solution at the time to everyone involved, including my client. + +10 11 12 13 14 15 16 17 What happened since then? Mr. Epstein continued a life of success, generosity, creativity and, more important, a law-abiding life from 2008 forward. How do we know? Because when you are in registration the way he is, every single night his whereabouts are known. There is constant reporting, constant monitoring, and absolutely, to our knowledge, no complaints by anybody from that moment forward about his conduct until we have arrived in court here. + +18 19 20 21 22 Now, what has happened in court from that moment? There have been lawsuits, many of them ludicrous, dismissed out of hand. But when something like this happens, a lot of stuff comes out of the woodwork, and there were lawsuits that Mr. Epstein settled also in the normal course. + +23 24 25 There was one particular litigation that leads to this occasion, and that is, under the Crime Victims Rights Act, that act simply says that victims have a right to be consulted by + +4 5 6 7 8 9 10 the United States, and there are alleged victims in this case who complain that they were not, and there has been extensive litigation in the Southern District of Florida before Judge Marra on that very subject. In fact, the judge concluded that the prosecutors from the Southern District of Florida did not adequately notify some of the victims about the ongoing discussions and the consummation of the deal and, in particular, the NPA. The United States took the position that they had no responsibility to do so, that they had treated the victims properly, and that matter continues to this day. + +11 12 13 14 15 The consequences of that matter are overwhelming, because the judge suggested, I think three times, that the NPA, the declination, could be voided. And we think about that for a second. So a defendant negotiates what he thinks is a global solution with the feds. He does his time -- + +16 17 18 19 THE COURT: Does the nonprosecution agreement in Florida -- the nonprosecution agreements in the Southern District routinely say they are limited to the Southern District of New York. + +20 MR. WEINGARTEN: Obviously -- + +21 22 THE COURT: Is there a similar provision in the Florida agreement? + +23 24 25 MR. WEINGARTEN: I don't want to misstate. It is not before me. It is obviously going to be an important part of the pretrial motions. What is for sure is that there was + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +the negotiation with the Southern District included negotiations with main justice. What's also true is the investigation extended into the Southern District of New York and elsewhere in terms of girls being interviewed. + +So obviously your question is relevant and will be part of the pretrial litigation for sure. But what matters here and for now is there certainly was a belief that there was a global solution based upon the facts on the ground. + +THE COURT: Have you seen the Florida nonprosecution agreement? + +MR. WEINGARTEN: Yes. + +THE COURT: And -- + +MR. WEINGARTEN: I don't have it before me. I don't want to make a specific representation and not be completely accurate. + +THE COURT: Okay. All right. Go ahead. + +MR. WEINGARTEN: The consequences of this are huge in that if in fact there is a negotiation with a defendant, the defendant does his time, the defendant pays his victim, and the defendant spends ten years on the registration list and prosecutors don't adequately notify the victims, how in the world can that deal be undone? Every prosecutor in the world has to oppose that possibility. No defense attorney in their right mind would negotiate a deal with that potential consequence. + +So this is a huge problem for the department and what 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 solution ensues, and I suggest the solution that ensued is this indictment. To us, this indictment is essentially a do-over. The allegations are from 2002 to 2005. This is old stuff. This is ancient stuff. This is the very stuff that was investigated by the feds in Florida, a sophisticated three-year investigation. Two of the alleged victims in this indictment are from Florida. The indictment here tracks the conduct that was investigated in Florida back before the agreement was reached. Obviously we need to get discovery to find out just how inextricably linked the investigation back in Florida is with what's going on here. We do know we are talking about ancient conduct. We do know we are talking about facts that are from 2002 to 2005, facts that were known to the United States prosecutors before they entered into the NPA, the declination. This is essentially a redo. That's how it feels to us. And if we are correct, that should chill the blood of every defense attorney who negotiates a deal with the United States. + +20 21 22 23 24 25 In addition, we have -- the central allegation here is trafficking, and obviously it is useful and relevant to make inquiry as to why the trafficking law was passed. It is to cover abhorrent conduct, where young girls are kidnapped, they are fooled, they are forced to come usually to unfamiliar places, work in brothels where they service 15, 20 guys in a + +4 5 6 7 I remember an occasion when the Attorney General Eric Holder and I think Director Comey had a press conference establishing this as a law enforcement priority. Every sensible person in the world would think that this is the exact right thing law enforcement should do. + +8 9 10 11 12 13 14 This is not this case. There was no violence. There was no coercion. There was no intimidation. There is no deception. The bottom line, if you take a fair look at the facts of this case as alleged and in the record, you may come to the conclusion there was prostitution involved and maybe a lot of it, but that doesn't mean that the person involved is a pedophile, a rapist or, heaven knows, a trafficker. Just -- + +15 16 THE COURT: Well, if the women involved were under 18, isn't that rape? + +17 MR. WEINGARTEN: My understanding -- + +18 19 THE COURT: Legally they are incapable of consent, are they not? + +20 MR. WEINGARTEN: Well, it could be statutory rape. + +21 22 23 24 But what I am talking about is trafficking and why the statute was passed, and obviously the statute was passed to protect women from the horrors that occur in such settings, and that is light years removed to what happened in this case. + +25 So what about bond? I would suggest that the + +day. They can't leave or else their families are threatened. This is dreadful conduct. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +traditional issues that we look at, the issues involved, let's start with that, we believe we have extremely powerful motions relating to the government seeking two bites at the apple and for due process reasons, double jeopardy reasons, we don't think that will stand. We also think fundamentally what's at issue here is not trafficking. That's not why the statute was passed. + +The risk to others, what we have here is at least ten years post incarceration in the State of Florida of conduct that has never been challenged by anyone until now. The registration requirements are onerous. He is under constant surveillance. Law enforcement knows, if they choose to look, exactly where he is at any time. + +The risk of flight, what is true is from the moment of Judge Marra's litigation in the Southern District of Florida, the defendant knew that there would be challenges to the NPA. From 2013 on, there were representations made in court that that challenge was ongoing, and the defendant never sought to flee, never anticipated a time when he would flee, continued to live his law-abiding life. So the risk of flight, I think, is dramatically overstated in the government's presentation. + +I think the traditional remedies that the court finds appropriate in case after case -- a large cash bond; passport relinquished; waiving extradition; a bracelet on; some form of supervision that is adequate to guarantee his appearance, it + +4 5 6 7 Because we have not had an opportunity to see our client until today and because we have just received the government's submission, what we would like to do is have the opportunity to sit down and put together a bail package, a coherent bail package in writing and provide it to the court. + +8 I would point out on the obstruction allegation + +9 10 11 THE COURT: Let me ask you this -- sorry to interrupt you -- do you want to adjourn the detention hearing? Under the statute, you have up to three days. + +12 13 14 MR. WEINGARTEN: What I would like is to have until the end of the week to provide something in writing, a specific recommendation in writing. + +15 16 THE COURT: So you want to adjourn a determination of bail? + +17 MR. WEINGARTEN: Yes. + +18 19 20 THE COURT: Is there any objection to that from the government? The defendant is detained in the interim under 3142(f). + +21 MR. WEINGARTEN: Right. + +22 23 24 MR. ROSSMILLER: Your Honor, we certainly don't object if the defendant is consenting to detention with leave to make a further application. + +25 I think the government would like at least a brief + +will be child's play to find that; bonds from other people, surety bonds from other people. + +4 opportunity to respond to some of those points, to the extent that the defense is arguing that Mr. Epstein should be granted bail as a general matter and the court is going to consider those arguments. + +5 6 THE COURT: Well, the court always considers the parties' arguments. + +7 8 9 10 But let me just come back to Mr. Weingarten for a minute. Mr. Weingarten, under the Bail Reform Act you are entitled to a continuance of three days, which I guess would take us to Thursday. + +11 MR. WEINGARTEN: Right. + +12 13 14 THE COURT: The other alternative, I guess, if you want to de facto extend that three days is consent to detention without prejudice. + +15 16 17 MR. WEINGARTEN: We estimated that by Thursday we could get you something in writing and then appear back before you at your convenience. + +18 19 20 21 22 THE COURT: Okay. Do you want to schedule it -- well, I think Thursday's proceedings right now would be in front of Judge Berman unless he wants to send it back to me for bail, but do you want to put this down for detention hearing on Thursday? + +23 24 MR. WEINGARTEN: Can I make one point that I don't want to forget that I think is extremely important? + +25 THE COURT: Go ahead. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +MR. WEINGARTEN: The last thing we did today was refuse to answer questions. What we said at Pretrial is heaven forbid we make a mistake, and in terms of assets, we wanted to be precise. So there was no refusal. There was a request for time to supplement. That was accepted. And that's part of the reason we want to sit down and make sure we get our information correct to provide to the court. + +THE COURT: All right. + +MR. WEINGARTEN: Can I make one other point? + +THE COURT: Sure. + +MR. WEINGARTEN: In terms of the obstruction, I think it is such a significant part of our argument that the conduct at issue is ancient. It is from 2002 to 2005. So obviously if the defendant is a threat to obstruct justice, the court needs to take that into account. The allegations raised -- and I just read them briefly because we just got the government's letter -- relate to negotiations between the feds and the defendant. Back when the Southern District of Florida was attempting to find an appropriate remedy, there were discussions going back and forth: Can we squeeze you into this statute? And it didn't work, and it didn't work because there is no factual basis. That is the reference to the alleged obstruction. Not obstructive acts. Instead, the feds in Florida agreed to the plea to the state offense because there was no appropriate statute that covered conduct that was + +4 MR. WEINGARTEN: Yes. + +5 6 7 THE COURT: All right. Is there any objection to that from the government? I think under the statute he is entitled to three days. + +8 MR. ROSSMILLER: That is, of course, fine, your Honor. + +9 10 11 I think we would like just a very brief opportunity to respond to some of those arguments so that they don't sort of hang with the court for three days unresponded to. + +12 THE COURT: All right. Go ahead. + +13 14 15 MR. ROSSMILLER: Just very briefly, your Honor, I think a lot of that discussion was entirely orthogonal to the issues here. + +16 17 18 19 But just very briefly, with respect to the charges here, there is simply no force required for underage victims. A grand jury has properly returned an indictment, and these are fact issues that are being presented in large part. + +20 21 22 23 24 25 Certainly the concept of child prostitution is, frankly, offensive and not recognized in federal law. The idea that children can consent to sex and be prostitutes is beyond the realm of federal law which contemplates trafficking, which is what has been charged here. Mr. Weingarten is free to argue to a jury that trafficking minors was only statutory rape or + +proveable. That is the answer to the obstruction issue. + +THE COURT: All right. So you want to adjourn the detention hearing until Thursday? + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +that those victims weren't treated as badly as the parade of horribles he has in mind. But for now the question is whether the defendant's attendance can be assured. + +And with respect to the nonprosecution agreement + +THE COURT: I'm not sure I would refer to something as only statutory rape. The use of the word "only" before "statutory rape" I'm not sure sits well. But go ahead. + +MR. ROSSMILLER: And I agree, your Honor. + +With respect to the actual substance, the Southern District of Florida has represented in public filings that the nonprosecution agreement was limited to the Southern District of Florida, and we can litigate that in a motion to dismiss, but it is simply not relevant here. + +With respect to the statute of limitations, Mr. Weingarten says that the conduct is old. He did not say that that it is beyond the statute of limitations because it is not. + +And, finally, it is not the same conduct. Some of the conduct overlaps. Some of the conduct does not. And in particular, one of the two counts of the indictment is predicated exclusively on New York victims. + +So for all of those reasons, we just ask the court to consider those responses as it awaits the defendant's filings later this week. + +MR. WEINGARTEN: Can I just make one point to clarify? + +4 MR. WEINGARTEN: On the statutory rape thing, I had a senior moment. There is no statutory rape because there is no penetration, and that is the answer to that question. + +5 THE COURT: All right. + +6 7 8 We will set this down for a detention hearing on Thursday, July 11, for the continuation of the detention hearing. Thursday, July 11, at 2 p.m. + +9 10 11 The defendant is detained at least until the continuation of the detention hearing pursuant to 18 United States Code 3142(f). + +12 13 14 I have been advised by Judge Berman that he wants to see counsel right after these proceedings. Judge Berman's courtroom is 17B. So counsel and Mr. Epstein should go to 17B. + +15 All right. Anything else from the government? + +16 17 18 MR. ROSSMILLER: Your Honor, ordinarily we would ask to exclude speedy trial time, but I think because we are going directly to Judge Berman, we have no such application. + +19 THE COURT: Mr. Weingarten, anything else? + +20 MR. WEINGARTEN: No, thank you, your Honor. + +21 THE COURT: Mr. Weingarten, anything else? + +22 MR. WEINGARTEN: No, your Honor. + +23 THE COURT: All right. 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Notice is hereby given that an official transcript of a held on has been filed by the court reporter/transcriber in the above-captioned matter. 7/8/19 + +Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting the transcript is a judge or a member of the public or media. + +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically available to the public without redaction after ninety (90) calendar days. + +This process may only be used to redact the following personal data identifiers: Social Security numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information may proceed by motion. + +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. + +/s KRISTEN CARRANANTE + +Court Reporter/Transcriber Date \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824308/EFTA02824308.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824308/EFTA02824308.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e72b49b34b505efeacfee418ac203ecb5ac741d2 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824308/EFTA02824308.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824308.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1450, + "elapsed_seconds": 0.84, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "IN THE UNITED STATES DISTRICT COURT \nFOR THE SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 153.612, + 67.23 + ], + [ + 418.71282958984375, + 67.23 + ], + [ + 418.71282958984375, + 96.363037109375 + ], + [ + 153.612, + 96.363037109375 + ] + ] + }, + { + "title": "NOTICE OF FILING OF OFFICIAL TR.A NSCR I P", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 167.688, + 308.6015625 + ], + [ + 446.76, + 308.6015625 + ], + [ + 446.76, + 322.4830627441406 + ], + [ + 167.688, + 322.4830627441406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 28 + ], + [ + "Text", + 15 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824308" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824309/EFTA02824309.md b/marker2/court-us-v-epstein-cr/EFTA02824309/EFTA02824309.md new file mode 100644 index 0000000000000000000000000000000000000000..871c210b953db45e5907e702b9341c230655d610 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824309/EFTA02824309.md @@ -0,0 +1,87 @@ +## LAW OFFICE OF MARC FERNICH + +MARC FERNICH maf4114michlaw.com ALSO ADMOTED IN MASSACHUSETTS + +## BY ECF + +Hon. Richard M. Berman USDJ-SDNY 500 Pearl St. New York, NY 10007 + +810 SEVENTH AVENUE, SUITE 620 NEW YORK, NEW YORK 10019 212-446-2146 FAX: 212459-2299 www.fernichlaw.com + +July 16, 2019 + +Re: US v. Epstein, 19 CR 490 (SDNY) + +Dear Judge Berman: + +In response to requests from the Court and certain arguments made yesterday by the government, we write to supplement Jeffrey Epstein's request for bail. + +First, make no mistake about the crux of the government's detention argument and its necessary implications. Stripped to its core, the government's position — as urged in its letters and echoed again yesterday — distills to this: the nominally rebuttable remand presumption (connected with 18 USC § 1591 charges) 1 plus Mr. + +1 To be clear, Epstein contends that § 1591 and the concomitant remand presumption do not contemplate or cover the core conduct at issue here: performing sexual + +Epstein's wealth creates an *irrebuttable* presumption whereby no condition(s) can reasonably assure personal appearance or protect the public. The Court should reject the government's misguided effort to effectively create a *per se* rule.2 Indeed, for the government, there's literally *nothing* a person of Epstein's means could say, do or pledge to rebut the operative presumption and make himself eligible for release. + +That cannot be the law. Such a construction turns the statute's + +--- + +massages for money. *See Fierro v. Taylor*, No. 11-CV8573, 2012 WL 13042630, at \*3 (SDNY July 2, 2012) (holding that sex purchasers from minors fall outside § 1591's ambit). + +2 *E.g.*, 7/15/19 Tr. 11 ("even if the defense were able at some point to rebut the presumption by providing some more information, there simply is no way that they can meet the standard here"); 7/12/19 Ltr. 5 ("even assuming the defendant's assets are *presently* in the United States, nothing ... 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 [notice] to places where the [g]overnment would never find them so as to ensure he could live comfortably while a fugitive."); *id.* ("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 ... tens of millions of dollars per year outside of the United States.... [T]here would be little to stop the defendant from fleeing, transferring his unknown assets abroad, and then continuing to ... earn his vast wealth from a computer terminal beyond the reach of extradition.") (footnote omitted); *id.* 7 ("the notion that *any* individual co-signer could meaningfully secure a bond for this defendant strains credulity"). + +plain text — expressly providing that the presumption is "[s]ubject to rebuttal," and otherwise mandating bail on the "least restrictive" conditions that reasonably assure the defendant's presence and community safety — on its head. It defies legislative intent. It thwarts the presumption of innocence. And it violates the Fifth, Sixth and Fourteenth amendment rights to due process, counsel, a defense and equal protection, not to mention the Eighth Amendment guarantee of bail — all based on a suspect if not invidious classification. To be sure, wealthy defendants do not deserve preferential treatment. But they certainly shouldn't be singled out for worse treatment - in effect, categorically disqualified from bail, at least in a presumption case — on the basis of their net worth. + +Second, it bears emphasis that the presumption is hardly an insurmountable bar to release in a § 1591 prosecution.3 To the contrary, courts have determined that there are suitable conditions under which + +3 E.g., US v. No. 13-CR-04-GKF, 2013 WL 11305792 (N.D. Okla. Feb. 8, 2013); US v. Afyare, No. 3:10-cr-00260, 2011 WL 1397820 (M.D. Tenn. April 13, 2011); US v. Gardner, 523 F. Supp. 2d 1025 (N.D. Cal. 2007). + +defendants accused of trafficking minors are bailed — notwithstanding the remand presumption. + +Third, as apparent from Mr. Epstein's initial financial disclosure, Mr. Epstein's finances are fairly complex. It would be impossible for Mr. Epstein — given, among other impediments, his detention, inability to quickly access pertinent records, and inability to quickly make a precise valuation of particular assets — to provide a sufficient financial statement by the Court's 5pm deadline. Mr. Epstein certainly recognizes the Court's request for further transparency and is committed to providing a complete and accurate disclosure. Accordingly, we propose that the Court preliminarily accept the initial disclosure proffered last Friday and, if intending to grant bail, include a release condition directing Mr. Epstein to tender a comprehensive forensic accounting of his finances as expeditiously as practicable. Joel Podgor, Partner Emeritus at prominent Manhattan accounting firm Baker Tilly Virchow Krause, LLP, has agreed to conduct the forensic investigation and prepare a report rapidly. As counsel said during the July 15 argument, Epstein will agree to any + +monetary condition — consistent with his Sixth Amendment need to retain counsel and pay ordinary expenses, which, at the Court's discretion, could be subject to supervision by a Court-appointed trustee that collateralizes his assets as a condition of release. + +Fourth, to the extent the government complains Epstein lacks meaningful domestic ties, we clarify and emphasize that his brother Mark, a U.S. resident, stands prepared to co-sign and secure a release bond in the full amount of his "own net worth,"4 which exceeds \$100 million — tangible proof of his certainty that Epstein will appear as necessary. + +Fifth, in response to the Court's inquiry about Epstein's New Mexico registration status, the state's Public Safety Department formally advised in August 2010 that "you are not required to register with the State of New Mexico ... for your 2008 Florida conviction of Procuring Person Under 18 for Prostitution." Nonetheless, in an abundance of caution and as an extra precaution, Epstein consistently notified the + +4 7/12/19 Ltr. 6 (footnote omitted). + +appropriate New Mexico official, Detective Deborah Anaya, when he spent any time at his ranch there. (The underlying documents are available upon request.) + +Sixth, though some studies may well indicate that sex offender recidivism rates "actually goo up at 15 years," as Your Honor suggested from the bench,5 others reach the opposite conclusion. For example, a respected study found that the relapse risk drops substantially the longer a person remains sex-offense free in the community. 6 Another determined that it's mistaken to think of anyone who's been offense-free for 15 years as high-risk.? + +Seventh, to the extent third-party counsel (Mr. Boies) speculated that the alleged November 28 and December 3, 2018 payments8 were + +5 7/15/19 Tr. 34. + +6 Hanson et al., "High-Risk Sex Offenders May Not Be High Risk Forever," Journal of Interpersonal Violence (March 2014), httns://www.researcheate.net/oublication/261069441 High-Risk Sex Offenders May Not Be High Risk Forever. + +7 Ira Mark & Tara Ellman, `Frightening and High': The Supreme Court's Crucial Mistake About Sex Crime Statistics" (2015). Constitutional Commentary. 419. https://scholarship.law.umn.edukoncomm/419. + +8 7/12/19 Ltr. 11. + +made to "witnesses who were cooperating with us"9 in civil litigation, he is wrong. As explained in Court, the recipients were "long-time [Epstein] friends and employees" 10 — not putative victims — and they never cooperated with Mr. Boies. To the contrary, each invoked the Fifth Amendment and refused to testify when civilly deposed, respectively, in prior New York federal and Florida state civil proceedings. Subject to the protective orders in these proceedings, we would be pleased to provide relevant deposition transcripts. + +Eighth, as for the Austrian passport the government trumpets, it expired 32 years ago. And the government offers nothing to suggest — and certainly no evidence — that Epstein ever used it. In any case, Epstein an affluent member of the Jewish faith — acquired the passport in the 1980s, when hijackings were prevalent, in connection to Middle East travel. The passport was for personal protection in the event of travel to dangerous areas, only to be presented to potential kidnapers, hijackers + +9 7/15/19 Tr. 70-71. + +10 Ibid. 69. + +or terrorists should violent episodes occur. + +Ninth, the Court is undoubtedly aware of the highly charged context surrounding this prosecution. In November 2018, media reports suggested that Epstein received a plea deal that amounted to a "slap on the wrist." Putting aside the robust negotiations leading to the nonprosecution agreement (NPA) and the prison sentence that Epstein completed, there can be no dispute that certain witnesses through their attorney representatives,11 the media — e.g., The Miami Herald — and the public were all clamoring for his re-prosecution, Epstein traveled extensively over these eight months and invariably returned to the United States. That inescapable reality emphatically proves he won't flee and entitles him to release — on any and all conditions the Court deems appropriate. + +ii See, e.g., Doe v. 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Incident Report + +Page: Program: ION + +Case No + +Entered By.: + +(Continued + +On Mi./ 3 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 errandjilliughout the county, the same vehicle was behind him running other vehicles off the road in an attempt not to lose sight of ms '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 explained to him that there was a meeting scheduled with and Attorney Jack Goldberger at scheduled on June 1 2006 at 9:00 am. I attempted to call to inform i of the rivate investi•ators following however; + +On May 23, 2006, I received other phone calls from and who advised they were able to acquire the private investigators license plate information. The sub'ect following them was a ain driving very aggressively and caused the road. the vehicle is a IIIII evy bearing Florida tag The vehicle is registered to of Flori a. is employed with Investigations from Florida. is a licensed Private Investigator in the state of Florida. + +Since the discovery of the threat made against one of the victims in received from during the month of March 2006 for her this case I re ested subpoenas for all calls made to and cell hone and home phone. I had confirmed with the exact dates of Spring Break for 2006. 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 March 2006. I reviewed the 989 calls made and received during the month of March 2006. I observed on March 7, 2006, made and received thirty five calls during that day. + +| | | In/Out | +|-------------------|---------|----------| +| Time Date | Seconds | Outbound | +| 11:03 AM 7-Mar-06 | 492 | | +| 7-Mar-06 11:16 AM | 6 | Inbound | +| 7-Mar-06 11:22 AM | 887.2 | Inbound | +| 7-Mar-06 11:37 AM | 48 | Outbound | +| 7-Mar-06 11:39 AM | 28.2 | Inbound | +| 7-Mar-06 12:02 PM | 727.2 | Inbound | + +The table reflects the date of the calls, time of day (EST), duration + +Case No. : [REDACTED] (Continued) +of call in seconds, inbound or outbound calls and calls made to or from [REDACTED] phone. On March 7, 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 March or April of 2006. I also noted that there was no further contact with [REDACTED] or Jeffrey Epstein during the remainder of the month of March or April 2006. + +On June 1, 2006, [REDACTED] telephoned me to inform me of the meeting that occurred with Atty. Jack Goldberger and [REDACTED] reference this case. 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Berman United States District Judge Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 + +The Silvio J. Mollo Building One Saint Andrew's Pla:a New York. New York 10007 + +July 16, 2019 + +#### REQUEST TO FILE PARTIALLY UNDER SEAL + +Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) + +Dear Judge Berman: + +The Government respectfully submits this letter to provide the Court with additional information in response to the Court's questions at the detention hearing held on July 15, 2019 (the "Detention Hearing"). + +### I. Payments to Potential Witnesses' + +In a July 12, 2019 letter, the Government informed the Court that the Government had recently obtained records from a financial institution ("Institution-1") that appeared to show the defendant had made suspicious payments shortly after the Miami Herald began publishing, on approximately November 28, 2018, a series of articles relating to the defendant, his alleged sexual misconduct, and the circumstances under which he entered into a non-prosecution agreement ("NPA") with the U.S. Attorney's Office for the Southern District of Florida in 2007. The same series highlighted the involvement of several of Epstein's former employees and associates in the alleged sexual abuse. At the Detention Hearing, the Court asked the Government to provide additional information about the individuals to whom these payments appear to have been made. + +First, records from Institution-1 show that on or about November 30, 2018, or two days after the series in the Miami Herald began, the defendant wired \$100,000 from a trust account he controlled to , an individual named as a potential co-conspirator—and for whom Epstein obtained protection in—the NPA. This individual was also named and featured prominently in the Herald series. + +Second, the same records show that just three days later, on or about December 3, 2018, the defendant wired \$250,000 from the same trust account to who was + +I For the reasons set forth at the Detention Hearing, and with the consent of the Court, the Government is redacting the identities of these individuals in the publicly filed version of this letter. + +Hon. Richard M. Berman United States District Judge July 16, 2019 Page 2 + +also named as a potential co-conspirator—and for whom Epstein also obtained protection in—the NPA. This individual is also one of the employees identified in the Indictment, which alleges that she and two other identified employees facilitated the defendant's trafficking of minors by, among other things, contacting victims and scheduling their sexual encounters with the defendant at his residences in Manhattan and Palm Beach, Florida. This individual was also named and featured prominently in the Herald series. + +# II. Police Report + +During the Detention Hearing, the parties referenced a redacted copy of a Palm Beach police report, which was annexed to the Government's July 12, 2019 detention memorandum. At the Court's request, the Government has provided a supplemental copy of the police report previously filed, with information referred to in open court unredacted. The updated copy of the police report is attached as Exhibit A. + +# III. Foreign Passport + +During the Detention Hearing, the Government informed the Court that it had recently learned that law enforcement agents had seized what appears to be an expired foreign passport (the "Foreign Passport") from a safe in the defendant's Manhattan residence during the execution of a search warrant on or about July 6, 2019. The Foreign Passport has a photograph that appears to depict the defendant, but lists a different name. Photographs of that passport are annexed hereto as Exhibit B. In the same safe, agents discovered what appears to be an expired United States passport issued to the defendant, in his true name, within three years of the date on the Foreign Passport. A photograph of that United States passport is annexed hereto as Exhibit C, so that the Court may compare the passports, both of which appear to depict the defendant. Because Exhibits B and C contain personally identifiable information and sensitive information relevant to the ongoing investigation, the Government respectfully requests that Exhibits B and C be filed under seal. + +The Government is attempting to obtain additional information about the Foreign Passport, including how it was obtained and whether the passport is genuine or fabricated. But the defendant's possession of what purports to be a foreign passport issued under an alias gives rise to the inference the defendant knows how to obtain false travel documents and/or assume other, foreign identities. This adds to the serious risk of flight posed by the defendant.2 + +2 The Government has asked defense counsel to advise whether the defendant is currently, or has been in the past, a citizen or legal permanent resident of a country other than the United States. To date, defense counsel has declined to respond. Certainly if the defendant is, or has been, a citizen or permanent resident of another country, that would add significantly to the overwhelming evidence of risk of flight. + +Hon. Richard M. Berman United States District Judge July 16, 2019 Page 3 + +### IV. Cash and Diamonds + +At the Detention Hearing, the Government informed the Court that diamonds and cash were seized from a safe in the defendant's Manhattan residence. The Court inquired as to the value of these items. After conferring with law enforcement agents who have reviewed the materials from the safe, the Government has learned that the safe contained more than \$70,000 in cash. In addition, the safe contained 48 loose diamond stones, ranging in size from approximately 1 carat to 2.38 carats, as well as a large diamond ring. The Government is currently unaware of whether the defendant maintains similar stashes of cash and/or jewels at his multiple properties, or in other locations. Such ready cash and loose diamonds are consistent with the capability to leave the jurisdiction at a moment's notice. + +## V. Conclusion + +For the reasons set forth herein, in the Government's July 8, 2019 and July 12, 2019 detention memoranda, and on the record at the Detention Hearing, the Court should order that the defendant be detained pending trial. The defendant 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. + +Respectfully submitted, + +GEOFFREY S. BERMAN United States Attorney + +By: /s Alison Moe / Alex Rossmiller / Maurene Comey Assistant United States Attorneys Southern District of New York Tel: (212) 637-2225 / 2415 / 2324 + +Cc: Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824320/EFTA02824320.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824320/EFTA02824320.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..92dc856ddea3c9c110c4913ed322bab11a30f356 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824320/EFTA02824320.metadata.json @@ -0,0 +1,337 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824320.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 6955, + "elapsed_seconds": 1.05, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.464, + 26.73 + ], + [ + 463.6324768066406, + 26.73 + ], + [ + 463.6324768066406, + 40.93353271484375 + ], + [ + 319.464, + 40.93353271484375 + ] + ] + }, + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 169.1015625 + ], + [ + 124.12138366699219, + 169.1015625 + ], + [ + 124.12138366699219, + 182.9830322265625 + ], + [ + 68.544, + 182.9830322265625 + ] + ] + }, + { + "title": "REQUEST TO FILE PARTIALLY \nUNDER SEAL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.464, + 169.29 + ], + [ + 501.2286071777344, + 169.29 + ], + [ + 501.2286071777344, + 196.863037109375 + ], + [ + 319.464, + 196.863037109375 + ] + ] + }, + { + "title": "I. 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Richard M. Berman USDJ-SDNY 500 Pearl St. New York, NY 10007 + +810 SEVENTH AVENUE, SUITE 620 NEW YORK, NEW YORK 10019 212-446-2146 FAX: 212459-22W www.fernichlaw.com + +July 16, 2019 + +Re: US v. Epstein, 19 CR 490 (SDNY) + +Dear Judge Berman: + +In response to requests from the Court and certain arguments made yesterday by the government, we write to supplement Jeffrey Epstein's request for bail, + +First, make no mistake about the crux of the government's detention argument and its necessary implications. Stripped to its core, the government's position — as urged in its letters and echoed again yesterday — distills to this: the nominally rebuttable remand presumption (connected with 18 USC § 1591 charges)' plus Epstein's + +1 To be clear, Epstein contends that § 1591 and the concomitant remand presumption do not contemplate or cover the core conduct at issue here: performing sexual + +wealth creates an *irrebuttable* presumption whereby no condition(s) can reasonably assure personal appearance or protect the public. The Court should reject the government's misguided effort to effectively create a *per se* rule.2 Indeed, for the government, there's literally *nothing* a person of Epstein's means could say, do or pledge to rebut the operative presumption and make himself eligible for release. + +--- + +massages for money. *See Fierro v. Taylor*, No. 11-CV8573, 2012 WL 13042630, at \*3 (SDNY July 2, 2012) (holding that purchasers of sex from minors fall outside § 1591's ambit). + +2 *E.g.*, 7/15/19 Tr. 11 ("even if the defense were able at some point to rebut the presumption by providing some more information, there simply is no way that they can meet the standard here"); 7/12/19 Ltr. 5 ("even assuming the defendant's assets are *presently* in the United States, nothing ... 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 [notice] to places where the [g]overnment would never find them so as to ensure he could live comfortably while a fugitive."); *id.* ("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 ... tens of millions of dollars per year outside of the United States.... [T]here would be little to stop the defendant from fleeing, transferring his unknown assets abroad, and then continuing to ... earn his vast wealth from a computer terminal beyond the reach of extradition.") (footnote omitted); *id.* 7 ("the notion that *any* individual co-signer could meaningfully secure a bond for this defendant strains credulity"). + +That cannot be the law. Such a construction turns the statute's plain text — expressly providing that the presumption is "[s]ubject to rebuttal," and otherwise mandating bail on the "least restrictive" conditions that reasonably assure the defendant's presence and community safety — on its head. It defies legislative intent. It thwarts the presumption of innocence. And it violates the Fifth, Sixth and Fourteenth amendment rights to due process, counsel, a defense and equal protection, not to mention the Eighth Amendment guarantee of bail — all based on a suspect if not invidious classification. To be sure, wealthy defendants do not deserve preferential treatment. But they certainly shouldn't be singled out for worse treatment — in effect, categorically disqualified from bail, at least in a presumption case — on the basis of their net worth. + +Second, it bears emphasis that the presumption is hardly an insurmountable bar to release in a § 1591 prosecution.3 To the contrary, + +3 E.g., US u. No. 13-CR-04-GKF, 2013 WL 11305792 (N.D. Okla. Feb. 8, 2013); US v. Afyare, No. 3:10-cr-00260, 2011 WL 1397820 (M.D. Tenn. April 13, 2011); US v. Gardner, 523 F. Supp. 2d 1025 (N.D. Cal. 2007). + +courts have determined that there are suitable conditions under which defendants accused of trafficking minors are bailed — notwithstanding the remand presumption. + +Third, as apparent from Epstein's initial financial disclosure, his finances are fairly complex. It would be impossible for Epstein — given, among other impediments, his detention, inability to quickly access pertinent records, and inability to quickly make a precise valuation of particular assets — to provide a sufficient financial statement by the Court's 5 pm deadline. Epstein certainly recognizes the Court's request for further transparency and is committed to providing a complete and accurate disclosure. Accordingly, we propose that the Court preliminarily accept the initial disclosure proffered last Friday and, if intending to grant bail, include a release condition directing Epstein to tender a comprehensive forensic accounting of his finances as expeditiously as practicable. Joel Podgor, Partner Emeritus at prominent Manhattan accounting firm Baker Tilly Virchow Krause, LLP, has agreed to conduct the forensic investigation and prepare a report rapidly. As counsel said + +during the July 15 argument, Epstein will agree to any monetary condition — consistent with his Sixth Amendment need to retain counsel and pay ordinary expenses, which, at the Court's discretion, could be subject to supervision by a Court-appointed trustee — that collateralizes his assets as a condition of release. + +Fourth, to the extent the government complains Epstein lacks meaningful domestic ties, we clarify and emphasize that his brother Mark, a U.S. resident, stands prepared to co-sign and secure a release bond in the full amount of his "own net worth,"4 which exceeds \$100 million — tangible proof of his certainty that Epstein will appear as necessary. + +Fifth, in response to the Court's inquiry about Epstein's New Mexico registration status, the state's Public Safety Department formally advised in August 2010 that "you are not required to register with the State of New Mexico ... for your 2008 Florida conviction of Procuring Person Under 18 for Prostitution." Nonetheless, in an abundance of + +4 7/12/19 Ltr. 6 (footnote omitted). + +caution and as an extra precaution, Epstein consistently notified the appropriate New Mexico official, Detective Deborah Anaya, when he spent any time at his residence there. (The underlying documents are available upon request.) + +Sixth, though some studies may well indicate that sex offender recidivism rates "actually go a up at 15 years," as Your Honor suggested from the bench,5 others reach the opposite conclusion. For example, a respected study found that the relapse risk drops substantially the longer a person remains sex-offense free in the community. 6 Another determined that it's mistaken to think of anyone who's been offense-free for 15 years as high-risk.? + +5 7/15/19 Tr. 34. + +6 Hanson et al., "High-Risk Sex Offenders May Not Be High Risk Forever," Journal of Interpersonal Violence (March httos://www.researchgate.net/publication/261069441 High-Risk Sex Offenders May Not Be High Risk Forever. 2014), + +7 Ira Mark & Tara Ellman, 'Frightening and High': The Supreme Court's Crucial Mistake About Sex Crime Statistics" (2015). Constitutional Commentary. 419. httos://scholarshio.law.umn.edu/concomm/419. + +Seventh, to the extent third-party counsel (Mr. Boies) speculated that the November 28 and December 3, 2018 payments8 were made to "witnesses who were cooperating with us"9 in civil litigation, he is wrong. As explained in Court, the recipients were "long-time [Epstein] friends and employees" i0 — not putative victims — and they never cooperated with Mr. Boies. To the contrary, each invoked the Fifth Amendment and refused to testify when civilly deposed, respectively, in prior New York federal and Florida state civil proceedings. Subject to the protective orders in these proceedings, we would be pleased to provide relevant deposition transcripts. + +Eighth, as for the Austrian passport the government trumpets, it expired 32 years ago. And the government offers nothing to suggest — and certainly no evidence — that Epstein ever used it. In any case, Epstein an affluent member of the Jewish faith — acquired the passport in the + +8 7/12/19 Ltr. 11. + +9 7/15/19 Tr. 70.71. + +10 Ibid. 69. + +1980s, when hijackings were prevalent, in connection to Middle East travel. The passport was for personal protection in the event of travel to dangerous areas, only to be presented to potential kidnapers, hijackers or terrorists should violent episodes occur. + +Ninth, the Court is undoubtedly aware of the highly charged context surrounding this prosecution. In November 2018, media reports suggested that Epstein received a plea deal that amounted to a "slap on the wrist." Putting aside the robust negotiations leading to the nonprosecution agreement and the prison sentence Epstein completed, there's no denying that although certain witnesses through their attorney representatives,'/ the media — e.g., The Miami Herald — and the public were all clamoring for his re-prosecution, Epstein traveled extensively over these eight months and invariably returned to the United States. That inescapable reality emphatically proves he won't flee and entitles him to release — on any and all conditions the Court deems appropriate. + +11 See, e.g., Doe u. 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OF THE CHIEF +NEW MEXICO STATE POLICE +827-9219 + +FARON W. SEGOTTA +DEPUTY SECRETARY—OPERATIONS +CHIEF—STATE POLICE +Dr. MIKE L. MIER +DEPUTY SECRETARY—ADMINISTRATION + +August 19, 2010 + +Jeffery E. Epstein +[REDACTED] +Stanley, NM + +## RE: SEX OFFENDER REGISTRATION AND NOTIFICATION ACT + +Dear Jeffery E. Epstein: + +After reviewing your file it is our determination that under the current NMSA 29-11A you are not required to register with the State of New Mexico at this time for your 2008 Florida conviction of Procuring Person Under 18 for Prostitution. However, while you reside temporarily in New Mexico you may be required to register per Title I of the Adam Walsh Child Protection and Safety Act of 2006. + +Please contact Teresa Hernandez at [REDACTED] if you have any further questions. + +Sincerely, + +![]()Regina Chacon, Assistant Bureau Chief +Law Enforcement Records Bureau +NM Department of Public Safety + +CC: Santa Fe County Sheriff + +File: +TH: RC + +ADMINISTRATIVE SERVICES +827-9022 +INFORMATION TECHNOLOGY +827-9262 +MOTOR TRANSPORTATION +POLICE DIVISION +476-2457 + +![](_page_1_Picture_43.jpeg) + +SPECIAL INVESTIGATIONS +841-8053 +TECHNICAL SUPPORT +827-9221 +TRAINING AND RECRUITING +827-9251 \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824332/EFTA02824332.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824332/EFTA02824332.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d29263ff56c953bb9337daab906d61fe48f00322 --- /dev/null +++ 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a/marker2/court-us-v-epstein-cr/EFTA02824334/EFTA02824334.md b/marker2/court-us-v-epstein-cr/EFTA02824334/EFTA02824334.md new file mode 100644 index 0000000000000000000000000000000000000000..06ea0cef744dc7498df71dd81d6f539df8d1f9c1 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824334/EFTA02824334.md @@ -0,0 +1,67 @@ +## EXHIBIT B + +From: Jeffrey Eputeln Subject: Data: July 25, 2012 at 254 PM To: Deborah Anaya Cc: Dairen Indyke + +DETECTIVE. I WILL BE STAYING IN SANTA FE, FOR APPROX THREE WEEKS STARTING NEXT MONDAY THE 30 TH + +The information contained in this communication is confidential, may be attorney-client privileged. may constitute inside information, and is intended only for the use of the addressee. It Is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. It you have received this communication in error, please notif us immediate by retum e-mail or by e-mail t and destroy this communication an copies er . including all attachments. copyright -all rights reserved + +From: Jeffrey Epstein + +Subject: + +Date: July 30, 2012 at 10 27 PM + +To: Deborah Anaya + +Cc: Darren Indyke + +I arrived today in new mexico will be in and out of the state for the next month hope things we well + +The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein + +Unauthorized use, disclosure or copying of this communication or any pail thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please motif us immediate) by return e-mail or by e-mail t and destroy this communication an al copies er , including all attachments. copyright -all rights reserved + +From: Jeffrey Epstein Subject: Date: September 14, 2012 w 10.13 PM To: Deborah Anaya Co: Darren Indyke + +out of an abundance of caution ,i write to tell you that i arrived in new mexico. and will leave on toes the 18th., hope you are well + +The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and Is Intended only for thn use of the addressee. It is the property of + +Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediate) by return e-mail or by e-mail t and destroy this communication an copies er including all attachments. Copyright •all rights reserved + +From: Jeffrey Epstein + +Subject: Date: Futxuaiy 23. 2013 at 8 52 AM + +To: Deborah Anaya + +Cc: Darren Indyke + +will be in new mexico 23-25 hope you are well + +The information contained in this communication is confidential, may be attomey-dient privileged. may constitute inside information, and is intended only for the use of the addressee. It is the property of + +Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof rs strictly prohibited and may be unlawful If you have received this communication in error, please notrf us immediately by return e-mail or by e-mail to and destroy this communication and copies ere , including all attachments. copyright -all rights reserved + +From: Jeffrey Epstein Subject: Date: April 25, 2013 at 7:09 PM To: Deborah Anaya Darren Indyke + +will be in new mexico for lour days, hope you are well + +The information contained in this communication is confidential, may be attorney-client privileged, may constitute Inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please nob' us Immediate! by return e-mail or by e-mail to rid destroy this communication an copies er , including all attachments. copyright -all rights reserved + +From: Jeffrey Epstein Subject: sex reqi Date: December 18, 2013 at 630 PM To: Deborah Anaya Darren Indyke + +happy holiday, again out of an abundance of caution please be advised that I will be in new mexico for the week of 2028 happy holiday + +The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. it is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notil us immediate) by return e-mail or by e-mail to nd destroy this communication an copies ere , including all attachments. copyright -all rights reserved + +From: Jeffrey E Subject: Date: July 31, 2015 at 11.25 AM To: Deborah Anaya Cc: Darren Indyke + +As an extra precaution I am letting you know that I will be on my ranch for the month of August . Hope you are well + +please note + +The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE + +Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. 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sleptoe com rweingartenAsteptoe corn + +July 17, 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 v. Jeffrey Epstein. No. 19-c r-490 + +Dear Judge Berman: + +![](_page_0_Picture_3.jpeg) + +Pursuant to the Court's request and in further support of Mr. Epstein's bail submissions, attached are documents relating to Mr. Epstein's New Mexico registration status referenced in Mr. Epstein's July 16, 2019 letter supplementing his bail submission (Dkt.24). + +We thank the Court for its consideration and are pleased to provide any additional information the Court may need. + +Yours truly, + +/s Reid Wei. Steptoe & , LLP (NYC) 1114 Avenue of the Americas New York, NY 10036 (202)-506-3900 Fax: (212)-506-3950 rweingarten@steptoe.com + +**G. Weinberg** (pro hac vice) 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 \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824342/EFTA02824342.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824342/EFTA02824342.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..489a8a51ae72a93b8fe9470e6d01aa20a251db11 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824342/EFTA02824342.metadata.json @@ -0,0 +1,126 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824342.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1242, + "elapsed_seconds": 0.77, + "image_assets": [ + "_page_0_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 181.44 + ], + [ + 124.17080688476562, + 181.44 + ], + [ + 124.17080688476562, + 196.10302734375 + ], + [ + 68.544, + 196.10302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 34 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 36 + ], + [ + "Line", + 18 + ], + [ + "Text", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824342" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824342/_page_0_Picture_3.jpeg b/marker2/court-us-v-epstein-cr/EFTA02824342/_page_0_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..d2fda5e8c494335e79ea4f5e1078b2a8e7666381 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824342/_page_0_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b194e05581bc3c356a61e831ee9dc54d8e2b41772b54c98c8aa7489f87ad9b5d +size 4865 diff --git a/marker2/court-us-v-epstein-cr/EFTA02824344/EFTA02824344.md b/marker2/court-us-v-epstein-cr/EFTA02824344/EFTA02824344.md new file mode 100644 index 0000000000000000000000000000000000000000..abd81543a413b244f862103c2cd370d34e9f543c --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824344/EFTA02824344.md @@ -0,0 +1,25 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA, x + +- against - + +JEFFREY EPSTEIN, + +USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED:.3114/ + +Government, 19 Cr 490 (RMB) + +Defendant. + +x + +ORDER + +The conference in this matter is rescheduled from 9:30 am on July 18, 2019 to + +11:30 am on July 18, 2019. + +Dated: New York, New York July 17, 2019 + +RICHARD M. 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Michael C. STEPTOE & LLP 1114 Avenue of the Americas New York, NY 10036 Tel: (212) 506-3900 Fax: (212) 506-3950 E-mail: mmiller®steptoe.com + +> Counsel for Defendant Jeffrey Epstein \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824345/EFTA02824345.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824345/EFTA02824345.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8c2578da29f66890e653474e718cacf23058c277 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824345/EFTA02824345.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824345.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 686, + "elapsed_seconds": 0.69, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.78000000000003, + 71.28 + ], + [ + 418.4738464355469, + 71.28 + ], + [ + 418.4738464355469, + 100.10302734375 + ], + [ + 192.78000000000003, + 100.10302734375 + ] + ] + }, + { + "title": "NOTICE OF APPEARANCE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 361.08, + 195.20999999999998 + ], + [ + 520.8271484375, + 195.20999999999998 + ], + [ + 520.8271484375, + 210.7330322265625 + ], + [ + 361.08, + 210.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 25 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824345" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824346/EFTA02824346.md b/marker2/court-us-v-epstein-cr/EFTA02824346/EFTA02824346.md new file mode 100644 index 0000000000000000000000000000000000000000..a33576d6d6b19f4cbbeb8a9c5c9b91dfba2f41ff --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824346/EFTA02824346.md @@ -0,0 +1,21 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA, + +JEFFREY EPSTEIN, + +v. + +Defendant. + +Case No. 19 Cr. 490 (RMB) + +## NOTICE OF APPEARANCE + +PLEASE TAKE NOTICE that James L. Brochin, a member in good standing of the Bar of this Court and a member of the law firm Steptoe & LLP, hereby enters his appearance as counsel of record for Defendant Jeffrey Epstein, in the above-captioned action. + +Dated: New York, New York Respectfully submitted, July 17, 2019 + +By: Is/ James L. Brochin James L. Brochin STEPTOE & LLP 1114 Avenue of the Americas New York, NY 10036 Tel: (212) 506-3900 Fax: (212) 506-3950 E-mail: jbrochin@steptoe.com + +> Counsel for Defendant Jeffrey Epstein \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824346/EFTA02824346.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824346/EFTA02824346.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fa37a2d58e3c3899afc5b6c78d5e7009f6623862 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824346/EFTA02824346.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824346.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 703, + "elapsed_seconds": 0.66, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.78000000000003, + 71.28 + ], + [ + 418.4738464355469, + 71.28 + ], + [ + 418.4738464355469, + 100.10302734375 + ], + [ + 192.78000000000003, + 100.10302734375 + ] + ] + }, + { + "title": "NOTICE OF APPEARANCE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 361.08, + 195.20999999999998 + ], + [ + 520.8271484375, + 195.20999999999998 + ], + [ + 520.8271484375, + 210.7330322265625 + ], + [ + 361.08, + 210.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 50 + ], + [ + "Line", + 25 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824346" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824347/EFTA02824347.md b/marker2/court-us-v-epstein-cr/EFTA02824347/EFTA02824347.md new file mode 100644 index 0000000000000000000000000000000000000000..b654b0ea4115ed31b04de91a6369446295b94a85 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824347/EFTA02824347.md @@ -0,0 +1,21 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA, + +JEFFREY EPSTEIN, + +v. + +Defendant. + +Case No. 19 Cr. 490 (RMB) + +## NOTICE OF APPEARANCE + +PLEASE TAKE NOTICE that Michael G. Scavelli, a member in good standing of the Bar of this Court and a member of the law firm Steptoe & LLP, hereby enters his appearance as counsel of record for Defendant Jeffrey Epstein, in the above-captioned action. + +Dated: New York, New York Respectfully submitted, July 17, 2019 + +By: Is/ Michael G. Scavelli Michael G. Scavelli STEPTOE & LLP 1114 Avenue of the Americas New York, NY 10036 Tel: (212) 506-3900 Fax: (212) 506-3950 E-mail: mscavelli@steptoe.com + +> Counsel for Defendant Jeffrey Epstein \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824347/EFTA02824347.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824347/EFTA02824347.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..37ce7a070bca9203fd29995ba6789c10174e2795 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824347/EFTA02824347.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824347.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 713, + "elapsed_seconds": 0.63, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.78000000000003, + 71.28 + ], + [ + 418.4738464355469, + 71.28 + ], + [ + 418.4738464355469, + 100.10302734375 + ], + [ + 192.78000000000003, + 100.10302734375 + ] + ] + }, + { + "title": "NOTICE OF APPEARANCE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 361.08, + 195.20999999999998 + ], + [ + 520.8271484375, + 195.20999999999998 + ], + [ + 520.8271484375, + 210.7330322265625 + ], + [ + 361.08, + 210.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 50 + ], + [ + "Line", + 25 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824347" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824348/EFTA02824348.md b/marker2/court-us-v-epstein-cr/EFTA02824348/EFTA02824348.md new file mode 100644 index 0000000000000000000000000000000000000000..203b0d838621ee489590b2d8d6a5eb47fbb10d42 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824348/EFTA02824348.md @@ -0,0 +1,27 @@ +![](_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 17, 2019 + +## VIA ECF + +The Honorable Richard M. Berman United States District Judge 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 to briefly respond to one aspect of the defendant's July 16, 2019 letter (ECF No. 24), and to provide the Court with additional information regarding the defendant's foreign passport. The defendant's July 16, 2019 letter asserts: "[Ajs for the Austrian passport the government trumpets, it expired 32 years ago. And the government offers nothing to suggest—and certainly no evidence—that Epstein ever used it." (ECF No. 24 at 7). In fact, the passport contains numerous ingress and egress stamps, including stamps that reflect use of the passport to enter France, Spain, the United Kingdom, and Saudi Arabia in the 1980s. + +The Government further notes that the defendant's submission does not address how the defendant obtained the foreign passport and, more concerning, the defendant has still not disclosed to the Court whether he is a citizen or legal permanent resident of a country other than the United States. + +Respectfully submitted, + +GEOFFREY S. BERMAN United States Attorney + +By: /s Alison Moe Alison Moe / Alex Rossmiller / Maurene Comey Assistant United States Attorneys Southern District of New York Tel: (212) 637-2225 / 2415 / 2324 + +Cc: All counsel of record (Via ECF) \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824348/EFTA02824348.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824348/EFTA02824348.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e6123267457776da5b86479734c7312dbc5e11a1 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824348/EFTA02824348.metadata.json @@ -0,0 +1,115 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824348.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1656, + "elapsed_seconds": 0.81, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.464, + 25.92 + ], + [ + 463.6654968261719, + 25.92 + ], + [ + 463.6654968261719, + 41.2330322265625 + ], + [ + 319.464, + 41.2330322265625 + ] + ] + }, + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 154.71 + ], + [ + 124.12138366699219, + 154.71 + ], + [ + 124.12138366699219, + 169.4830322265625 + ], + [ + 68.544, + 169.4830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 38 + ], + [ + "Text", + 12 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824348" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824348/_page_0_Picture_1.jpeg b/marker2/court-us-v-epstein-cr/EFTA02824348/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..dc8482b473cca66372547143db0541df2802c547 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824348/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:716d900eb71e825cb230477805998bbaaddefbdf892828a7285a406176b66820 +size 3357 diff --git a/marker2/court-us-v-epstein-cr/EFTA02824349/EFTA02824349.md b/marker2/court-us-v-epstein-cr/EFTA02824349/EFTA02824349.md new file mode 100644 index 0000000000000000000000000000000000000000..9e30fe0090cd8f416cf6bdbcc2c29f803dfb8245 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824349/EFTA02824349.md @@ -0,0 +1,36 @@ +LAW OFFICE OF +MARC FERNICH + +MARC FERNICH maf@fernichlaw.com +ALSO ADMITTED IN MASSACHUSETTS + +810 SEVENTH AVENUE, SUITE 620 +NEW YORK, NEW YORK 10019 +212-446-2346 +FAX: 212-459-2299 +www.fernichlaw.com + +July 18, 2019 + +**BY ECF** + +Hon. Richard M. Berman +USDJ-SDNY +Daniel P. Moynihan US Courthouse +500 Pearl St. +Courtroom 17B +New York, NY 10007-1312 + +Re: *US v. Jeffrey Epstein*, 19 CR 490 (SDNY) (RMB) + +Dear Judge Berman: + +Jeffrey Epstein replies to yesterday's government letter. + +Epstein was given the passport at issue by a friend. Some Jewish-Americans were informally advised at the time to carry identification bearing a non-Jewish name when traveling internationally in case of hijacking. He never used the document to travel internationally and never presented it to any immigration or customs authority. The passport stamps, predating his receipt of the document, do not reflect Mr. Epstein's entries or exits. His expired US passports, seized by the government and in its possession, would verify his true travel. The defense has asked the government to bring the original document to court for examination and inspection. + +As Mr. Epstein truthfully reported in his Pretrial Services interview, he is a life-long American citizen. He has no other citizenship or legal permanent residency. + +Respectfully, + +![]()![]()cc: All counsel \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824349/EFTA02824349.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824349/EFTA02824349.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..dbe25f3512537dca3e56419b0affebbcdcdf8961 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824349/EFTA02824349.metadata.json @@ -0,0 +1,113 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824349.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1356, + "elapsed_seconds": 5.59, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "LAW OFFICE OF MARC FERNICH", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 250.308, + 72.08999999999999 + ], + [ + 359.24399999999997, + 72.08999999999999 + ], + [ + 359.24399999999997, + 98.01 + ], + [ + 250.308, + 98.01 + ] + ] + }, + { + "title": "BY ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 69.156, + 220.32000000000005 + ], + [ + 116.28, + 220.32000000000005 + ], + [ + 116.28, + 233.27999999999997 + ], + [ + 69.156, + 233.27999999999997 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 36 + ], + [ + "Text", + 25 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "Caption", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824349" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824350/EFTA02824350.md b/marker2/court-us-v-epstein-cr/EFTA02824350/EFTA02824350.md new file mode 100644 index 0000000000000000000000000000000000000000..51d4ad08deac69bb4da201ad872e55dbde1cf0dd --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824350/EFTA02824350.md @@ -0,0 +1,93 @@ +Villafana, Ann C. (USAFLS) + +1'0M I'll' Jay lefkowitz [JLetkowitz@kindaid con} nt: Thursday, September 13, 2007 7.35 PM Viflafana, Ann Marie C. (USAFLS) ubject: Re. + +Sounds good. I will be at home. Let's talk at 9 an. the same statutes. + +Look forward to speaking in the morning. + +Best, ?ay + +Original message + +From: "Villafana, Ann C. \ Sent; 09/13/2007 07:26 PM AST To: ?ay Lefkowitz Subject: RE: + +Already thirking about + +Hi Jay -- Yes, I dm. I have been spending some quality time with title 18 looking for nisdemeanors. Do you want to take a look at 18 USC 403, 18 USC 1512(d), and 41 USC 223(a)(1)(B) and we can talk about then tomorrow? I know that someone mentioned there be:ng ctivity on an airplane, 1 just want to make sure that there is factual basis for the plea t the agents can confirm. + +. + +I'm not Sure exactly where I will be tomorrow morning, so is it alright if I call you? + +Have a good evening. + +A. Villafana Assistant U.S. AttOrney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 + +Original Message + +From: Jay Lefkowitz (mailt0:JLefkowitz@kirkland.com: Sent: Thursday, September 13, 2007 7:21 PM To: Villafana, Ann C. (USAFLS) Subject: + +Are you free to speak at 9 am tomorrow? + +Thanks. Jay + +Illil e information ccntained in this communication is confidential, may be attorney-client privileged, nay constitute inside information, and is intended only for + +the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this III ommunication or any part thereof is strictly prohibited d may be unlawful. If you have received this mmunication in error, please notify us immediately by return e-mail or by e-mail to postmastergkirkland.com, and destroy this communication and all copies thereof, including all attachments. + +The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to postmasterIkirkland.com, and destroy this communication and all copies thereof, including all attachments. + +• + +• + +Villafana, Ann C. (USAFLS) + +Villafana, Ann C. (USAFLS) nt: I uesday, September 15, 2007 b:44 AM 'Jay Lefkowite ubject: Draft Agreements? + +Ili Jay - I was hoping there would be things for me to rcad this morning, but I will try to remain patient. + +I believe there are only two types of agreements that would apply to this case: (I) a plea agreement to a federal charge or charges; and (2) a non-prosecution agreement (which is really a deferred prosecution agreement because the defendant agrees that if he violates the agreement, the U.S. can prosecute him). + +A plea agreement is part of the court file. It is not accessible on-line via PACER, but someone can go to the Clerk's Office to obtain a copy. + +A non-prosecution agreement would not be made public or filed with the Court, but it would remain part of our case file. It probably would be subject to a FOIA request, but it is no: something that we would distribute without compulsory process. + +On the obstruction charges, many of the facts I included in that first proffer were hypothesized based upon our discussions and the agents' observations of We will need to interview her to confirm :he accuracy of those facts. On a second count, we could rely on the incident where Mr. Epstein's private investigators followed father, forcing him off the road. Or, if there is something more recent related to any we could consider that. + +fr ope that helps. + +I/Waft:Fla Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 + +![](_page_2_Picture_11.jpeg) + +**Villafana, Ann** [REDACTED] **C. (USAFLS)** + +**From:** Jay Lefkowitz [JLefkowitz@kirkland.com] +**Sent:** Wednesday, September 19, 2007 11:36 AM +**To:** Villafana, Ann [REDACTED] C. (USAFLS) +**Subject:** Re: Draft Agreements? + +Confidential - For settlement purposes only + +Still working on redline. But pls look at this: + +On August \_\_, 2007, FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards traveled to the home of [REDACTED] in connection with an investigation pending in the Southern District of Florida. Mr. Epstein was informed of the service of the [REDACTED]. As a result, Mr. Epstein attempted to harass both [REDACTED] delay and hinder their receipt of a [REDACTED] to attend an official proceeding, more particularly the [REDACTED] to which [REDACTED] [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]. Mr. Epstein 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). + +----- Original Message ----- + +**From:** "Villafana, Ann [REDACTED] C. (USAFLS)" [REDACTED] +**Sent:** 09/19/2007 11:18 AM AST +**To:** Jay Lefkowitz +**Subject:** RE: Draft Agreements? + +Hi Jay - I don't know the factual basis for the alleged [REDACTED] because we have no independent evidence of that. So, the agents need to talk to them and then I can draft up a proposed factual proffer. I have sent an e-mail to Barry and Lanna to determine their availability. Thanks. + +*A. Marie Villafaña* +Assistant U.S. Attorney +[REDACTED] + +\*\*\*\*\* + +The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Authorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. 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Background + +This ruling follows the Court's bail hearing held on July 15, 2019. The issue before the Court is whether the Defendant should continue to be remanded (incarcerated) pending trial or whether he should be granted release while the case proceeds. No matter the answer to this question and no matter what has been said in Court in analyzing the matter, this is a criminal case and the Defendant, Jeffrey Epstein, is innocent of the Federal charges alleged against him now and until such time, if it comes, that a jury or the Court finds (after fair and thorough consideration of the facts and the law) that he is guilty. als Transcript, dated July 8, 2019 ("7/8/19 Tr."), at 2-3; Transcript, dated July 15, 2019 ("7/15/19 Tr."), at 40. It should also be borne in mind that the Court has not (yet) been presented with a motion to dismiss the Indictment. + +This is a federal as opposed to a state case. We proceed under federal law and federal rules. The key federal statute that applies here is 18 U.S.C. § 1591 which sets forth the crime of sex trafficking with which Mr. Epstein is charged. Mr. Epstein is also charged with conspiring with others to commit sex trafficking under 18 U.S.C. § 371. + +With respect to the issue of remand versus release, 18 U.S.C. § 3142 applies. It sets forth a presumption in favor of remand, an exception to the presumption in most cases which favors + +pretrial release. § 3142 states that: "if there is probable cause to believe that the person committed .. . an offense involving a minor victim under section ... 1591," then "it shall be presumed that no condition or combination of conditions will reasonably assure the appearance of the person as required and the safety of the community." 18 U.S.C. § 3142(e)(3XE) (emphasis added); see United States v. Martir, 782 F.2d 1141, 1144 (2d Cir. 1986). The Indictment in this case was returned by a grand jury thus establishing probable cause that the defendant committed the crimes of sex trafficking and sex trafficking conspiracy. See United States v. Contreras, 776 F.2d 51, 55 (2d Cir. 1985) ("[A]n indictment returned by a duly constituted grand jury conclusively establishes the existence of probable cause for the purpose of triggering the rebuttable presumptions set forth in § 3142(e)"). In most federal cases the rebuttable presumption that applies favors pretrial release, not remand. + +There is another very important issue to be considered in this case. It has to do with "victims" of the crimes charged in the Indictment. Victims refer to the "minor" girls who are alleged to have been sexually trafficked by the Defendant. Under 18 U.S.C. § 3771, victims are entitled to be heard in court, including on the question of whether the defendant is to be released or remanded. Victims have, among other things, been given the opportunity to testify at the bail hearing. + +# B. Counsels' Submissions + +The Government's letter application, dated July 8, 2019, requests that the Court remand Mr. Epstein. It argues that Mr. Epstein "poses [] an acute danger to the community" and, grounded in past experience with this Defendant, that "if [Mr. Epstein is] 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." Dkt. + +II, Ex. 1 at 1. The Government also contends that "[i]n light of the strength of the Government's evidence and the substantial incarceratory term the defendant would face upon conviction [45 years], 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." Id. + +The Government also provides the following background information: "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 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 the fall of 2007, the Defendant entered into a non-prosecution agreement ("NPA") with the Southern District of Florida 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." Id. at 3. "In June 2008, the defendant pled guilty in [Florida] 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, [also] 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." Id. + +The Defense moved on July II, 2019, for pretrial release of Mr. Epstein, arguing that "Mr. Epstein's strict compliance with the various monitoring requirements associated with his sex-offender registration actually decrease[s] any danger that he might otherwise pose" and also that "Mr. Epstein has never once attempted to flee the United States." Dkt. 6 at 1, 12. The + +Defense proposes what they describe as "a stringent set of [14] conditions that will effectively guarantee [Mr. Epstein's] appearance and abate any conceivable danger he's claimed to present." Id. at 1. The 14 conditions do not include private security guards 24/7. The 14 conditions do include: (1) "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"; (4) "Consent to U.S. extradition from any country and waiver of all rights against such [e]xtradition"; (5) "A substantial [unspecified] personal recognizance bond in an amount set by the Court after reviewing additional information regarding Mr. Epstein's finances ... ."; (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 my ill 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"; (9) Mr. Epstein "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"; (II) "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) "Any other condition the Court deems necessary to reasonably assure Mr. Epstein's appearance." Id. at 3-4. The Defense also proposes as a "fallback" "round-the-clock, privately funded security guards [which] will virtually guarantee - not just reasonably assure - Mr. Epstein's presence in the circumstances of this case." Id. at 10. The bail package originally was not accompanied by a financial statement reflecting Mr. Epstein's finances. However, on July 12, 2019, the Defense filed a one-page document which includes five groups of assets owned by Mr. Epstein totaling \$559,120,954. Dkt. 14 at 18. + +The Government responded to the Defense motion on July 12, 2019, arguing, among other things, that Mr. Epstein "has a history of obstruction and manipulation of witnesses, including . . . as recently as within the past year, when media reports about his conduct [in Florida] reemerged." Dkt. II at 1. The Government filing was made against a "backdrop of significant—and rapidly-expanding—evidence, serious charges, and the prospect of a lengthy prison sentence." Id. It contends that the defendant's proposed conditions of release are "woefully inadequate." Id. + +The Court also received a letter from the Government, dated July 16, 2019, providing, among other things, details about allegedly suspicious payments made by the Defendant in 2018; a Palm Beach, Florida police report; Mr. Epstein's expired Austrian passport in another name but with Mr. Epstein's photo; and a pile of cash and diamonds found in Mr. Epstein's safe. For example, the Government says: "[R]ecords from Institution-1 show that on or about November 30, 2018, or two days after the series in the Miami Herald began, the defendant wired \$100,000 from a trust account he controlled to ..., an individual named as a potential co-conspirator." Dkt. 23 at 1. And, "on or about December 3, 2018, the defendant wired \$250,000 from the same + +trust account to . .., [an individual] who was also named as a potential co-conspirator." Id. at 1- 2. According to the Government, the second individual "is also one of the employees identified in the Indictment, which alleges that she and two other identified employees facilitated the defendant's trafficking of minors by, among other things, contacting victims and scheduling their sexual encounters with the defendant at his residences in Manhattan and Palm Beach, Florida." Id. at 2. + +By letter, dated July 16, 2019, Defense counsel states, among other things, that the Court should reject the idea that "there's literally nothing a person of Epstein's means could say, do or pledge to rebut the operative presumption and make himself eligible for release." Dkt. 24 at 2. "Epstein contends that § 1591 and the concomitant remand presumption do not contemplate or cover the core conduct at issue here: performing sexual massages for money." M. at 1-2 n.1. Defense counsel also states that "Epstein certainly recognizes the Court's request for further transparency and is committed to providing a complete and accurate disclosure. Accordingly, we propose that the Court preliminarily accept the initial [financial] disclosure proffered last Friday and, if intending to grant bail, include a release condition directing Epstein to tender a comprehensive forensic accounting of his finances as expeditiously as practicable." M. at 4. By letters, dated July 16 and July 17, 2019, Defense counsel also submitted information regarding Epstein's New Mexico sex offender registration status. Defense counsel also stated that Epstein traveled extensively over the last eight months and "invariably returned to the to the United States. That inescapable reality emphatically proves he won't flee and entitles him to release on any and all conditions the Court deems appropriate." Id. at 8. + +### C. I n dictm en t + +A grand jury voted to indict Mr. Epstein on or about July 2, 2019. The Indictment charges Mr. Epstein with two felonies involving minor girls some as young as 14. Count includes conspiracy to commit sex trafficking of minor girls, in violation of 18 U.S.C. § 371, and Count II includes sex trafficking of minor girls, in violation of 18 U.S.C. § 1591. It states: "[F]rom at least in or about 2002, up to and including at least in or about 2005, Jeffrey Epstein, . . . enticed and recruited, and caused to be enticed and recruited, minor girls to visit his mansion in Manhattan, New York ... and his estate in Palm Beach, Florida, . .. to engage in sex acts with him, after which he would give the victims hundreds of dollars in cash." Indictment, dated July 2, 2019 ("Indictment"), 4' 2. "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." a + +The Indictment also charges that "the victims . . . were as young as 14 years old at the time they were abused by [Mr. Epstein] . . . and were, for various reasons, often particularly vulnerable to exploitation." Id. ¶ 3. "Mr. Epstein intentionally sought out minors and knew that many of his victims were in fact under the age of 18, [] because, in some instances, minor victims expressly told him their age." Id. + +Following his arrest, on Monday, July 8, 2019, Mr. Epstein was arraigned and presented with the Indictment by Magistrate Judge Henry Pittman. + +# D. Legal Principles Governing Release Versus Remand + +Under the Bail Reform Act, 18 U.S.C. § 3142, a Court can order a defendant's detention if it determines that the defendant is either (1) a danger to the community or (2) a risk of flight. + +18 U.S.C. § 3142(e). A Court does not need to find both bases are proven to order a defendant's detention. See id: United States v. = 570 F. App'x 76, 78 (2d Cir. 2014). Dangerousness means that the defendant is a "danger to the safety of any other person or the community." 18 U.S.C. § 3142. 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). "Where there is a strong probability that a person will commit additional crimes if released, the need to protect the community becomes sufficiently compelling that detention is, on balance, appropriate." United States v. Chim\_urenga, 760 F.2d 400, 403 (2d Cir. 1985). "[E]ven a single incident of witness tampering ... [may be] sufficient to revoke bail." LaFontaine. 210 F.3d at 134. + +To order detention based upon risk of flight, the Court must find by a preponderance of the evidence that "that no conditions could reasonably assure the defendant's presence at trial." See, e.g., United States v. = 823 F.2d 4, 5 (2d Cir. 1987); 18 U.S.C. § 3142. "[T]he constitutional limits on a detention period based on dangerousness to the community may be looser than the limits on a detention period based solely on risk of flight. In the former case, release risks injury to others, while in the latter case, release risks only the loss of a conviction." United States v. Milian, 4 F.3d 1038, 1048 (2d Cir. 1993) (quoting United States v. Orena, 986 F.2d 628, 631 (2d Cir. 1993)). A bail package that "may reasonably assure the appearance of [the defendant] at trial will not [necessarily] assure the safety of the community." United States v. Rodriguez, 950 F.2d 85, 89 (2d Cir. 1991). + +The Bail Reform Act sets forth the following four factors to be considered in the release/remand analysis: (I) the nature and circumstances of the crime(s) 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. 18 U.S.C. § 3142(g). "The weight afforded to each factor under section 3142(g) is within the `special province' of the district court." United States v. Paulino 335 F. Supp. 3d 600, 610 (S.D.N.Y. 2018) (quoting United States v. Shakur, 817 F.2d 189, 196 (2d Cir. 1987)). + +"The rules concerning admissibility of evidence in criminal trials do not apply to the presentation and consideration of information at the [release/remand] hearing." 18 U.S.C. § 3142(0(2) (emphasis added). For example, the Government is entitled to present evidence supporting remand by way of proffer, among other means. 18 U.S.C. § 3142(0(2); see also United States v. LaFontaine, 210 F.3d 125, 131 (2d Cir. 2000) ("bail hearings are typically informal affairs, not substitutes for trial or even for discovery"). 18 U.S.C. § 3142(f)(2)(B) expressly states that the Federal Rules of Evidence do not apply at bail hearings; thus, courts often base detention decisions on hearsay evidence. United States v. Abuhamra, 389 F.3d 309, 321 n.7 (2d Cir. 2004) "District courts [are afforded] wide discretion regarding the scope of such hearings . . . ." United States v. Bartok, 472 F. App'x 25, 27 (2d Cir. 2012). + +# E. The Presumption of Remand in 18 U.S.C. § 1591 Cases + +A 18 U.S.C. § 1591 case involving sexual victimization of a minor is unusual in that it includes a presumption in favor of pretrial detention, reflecting the significant harm caused by such a crime. 18 U.S.C. § 3142(e)(3)(E). The presumption is that no condition or combination of conditions will reasonably assure against flight or danger to the community. United States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quoting 18 U.S.C. § 3142(eX3)(E)). Mr. Epstein may rebut the presumption by "coming forward with evidence that he does not pose a danger to the community or a risk of flight." United States v. Mercedes 254 F.3d 433, 436 (2d Cir. 2001). The Government retains the "ultimate burden of persuasion" that Mr. Epstein presents a danger to the community (by clear and convincing evidence) and that Mr. Epstein presents a risk of flight (by a preponderance of the evidence). Id. Even if rebuttal evidence is presented, "the presumption favoring detention does not disappear entirely." Id. at 436. "[It] remains a factor to be considered among those weighed by the district court." Id. + +#### F. Mr. Epstein Poses a Danger To Others And To the Community + +The Court begins with "dangerousness" because that concept is at the heart of this case. It finds that the Government has shown by clear and convincing evidence that Mr. Epstein threatens the safety of another person and of the community, as follows on pages 10-21: + +- Victims Have Advised The Court That They Would Fear For Their Safety If Mr. Epstein Were Released + +Victims have "specifically conveyed" to the Government that any form of release of the Defendant, including home detention with full-time private guards, could "result in [their] harassment and abuse." Dkt. II at 4. At the bail hearing on July 15, 2019, two victims movingly testified about their past sexual encounters with Mr. Epstein when they were minors aged 14 and 16, respectively. 7/15/19 Tr. at 72; see also S. REP. 108-191 ("CVRA Legislative History"), at 22 (In enacting the CVRA, Congress stated that "[V]ictims deserve the right to be heard at specific points in the criminal justice process," including bail hearings. "Giving victims a voice not only improves the quality of the process but can also be expected to often provide important benefits to victims."). was introduced by her counsel, David Boles, and stated that she was 16 years old when she "had the misfortune of meeting Jeffrey Epstein [in] New York." 7/15/19 Tr. at 72. said that Mr. Epstein "flew [her] to New Mexico" and was "inappropriate" with her. M. She was reluctant to go into details about her experience with Mr. Epstein. Id. at 73. opposes Mr. Epstein's pretrial release because she believes other + +Epstein victims would "continu[e] to be victimized" and that Mr. Epstein's wealth and privilege and notoriety would make it difficult for "[other] victims to come forward." Id. at 72. + +was introduced by her counsel, Brad M, and said she was "sexually abused by Jeffrey Epstein starting at the age of 14." Id. at 73-74. She asked the Court to "keep [Mr. Epstein] in detention [] for the safety of any other girls out there that are going through what [she's] going through." id. at 74. said that Mr. Epstein is a "scary person to have walking the streets." Id. + +# • Mr. Epstein Poses A Threat to Additional Young Girls If He Is Released + +At the remand/release hearing on Monday, July 15, 2019, as noted, the Court heard poignant testimony from two of Mr. Epstein's alleged victims about their fears and anxiety over his potential release, even if under strict conditions of home confinement. The Court is also concerned for new victims. + +Mr. Epstein's alleged excessive attraction to sexual conduct with or in the presence of minor girls — which is said to include his soliciting and receiving massages from young girls and young women perhaps as many as four times a day — appears likely to be uncontrollable. See United States v. Minnici, 128 F. App'x 827, 829-30 (2d Cir. 2005) (defendant's alleged sex crimes were "of an addictive sexual nature that cannot be suppressed simply by a restrictive set of bail conditions"). Accordingly, Mr. Epstein's past sexual conduct is not likely to have abated or been successfully suppressed by fierce determination, as his Defense Counsel suggests. Defense Counsel contends that: "[H]e wasn't a predator that couldn't control his conduct. He disciplined himself." 7/15/19 Tr. at 31-32. Defense Counsel also argues that "appreciating the gravity of these charges .. . putting aside the age of these witnesses and putting the consent issue aside, it's not like [Epstein is] an out-of-control rapist." 7/15/19 Tr. at 36. It seems fair to say that Mr. Epstein's future behavior will be consistent with past behavior, including the trove of "lewd photographs of young-looking women or girls," which were recently uncovered during the July 6-7, 2019, search of Mr. Epstein's East 7Ist Street mansion. Sim Dkt. 11, Ex. 1 at 9. The search results suggest the "possibility that defendant could target another vulnerable victim." See United States v. Baker, 349 F. Supp. 3d 1113, 1135 (D.N.M. 2018) (where the defendant was alleged to specifically target "vulnerable women" and where he attempted to contact an alleged victim, the court was persuaded that the defendant "would be a danger to society if released"). + +Despite having been convicted of the above mentioned (two) Florida sex crimes (in 2008) involving an underage girl, Mr. Epstein, as noted, maintained at his New York residence a "vast trove" of sexually suggestive photographs of nude underage and adult girls. Dkt. 11, Ex. 1 at 9. That is, during the July 6-7, 2019 authorized search of Mr. Epstein's NYC residence, the FBI found a "substantial collection of photographic trophies of his victims and other young females." Dkt. 11 at 10. This evidence includes compact discs labeled "Young [Redacted Name] + [Redacted Name]," "Misc nudes 1," and Girl pies nude." Id. The Government contends that this evidence includes hundreds or perhaps thousands of "sexually suggestive photographs" of nude underage girls and women, and that it is corroborative in nature. Id. And, it is consistent with victim recollections of the inside of Mr. Epstein's residence. Dkt. 11, Ex. 1 at 9. This newly discovered evidence also suggests that Mr. Epstein poses "ongoing and forward-looking danger." Sic Dkt. 11 at 10; see also Baker 349 F. Supp. 3d at 1135; United States v. Goodwin 2015 WL 6386568, at \*3 (W.D. Ky. Oct. 21, 2015). + +- The § 1591 Presumption Of Pretrial Remand Reflects The Seriousness Of Mr. Epstein's Alleged Crimes + +The significant harms and dangers of sex crimes involving minors "animated [] Congress to create the statutory presumption of detention." United States v. Hardy, 2019 WL 2211210, at + +4'10 (D.D.C. May 22, 2019). The presumption of remand "reflects Congress's substantive judgment that particular classes of offenders should ordinarily be detained prior to trial." United States v. 608 F.3d 939, 945 (6th Cir. 2010). Other serious offenses that are accompanied by the presumption of remand are: Kidnapping (18 U.S.C. § 1201); Aggravated Sexual Abuse (18 U.S.C. § 2241); Sexual Abuse (18 U.S.C. § 2242); Offenses Resulting in Death (18 U.S.C. § 2245); Sexual Exploitation of Children (18 U.S.C. § 2251); Selling or Buying of Children (18 U.S.C. § 2251); Production of Sexually Explicit Depictions of a Minor for importation into the United States (18 U.S.C. § 2260); Coercion and Enticement (18 U.S.C. § 2422); Transport of Minors (18 U.S.C. § 2423); Use of Interstate Facilities to Transmit Information About a Minor (18 U.S.C. § 2425). 18 U.S.C. § 3142(e)(3)(E). + +The presumption of remand does not disappear even when rebutted. Martir, 782 F.2d at 1144. If the defendant comes forward with evidence that he will not endanger the community or flee the jurisdiction, the presumption "is not erased." See United States v. Dominguez, 783 F.2d 702, 707 (7th Cir. 1986). "Rather, the presumption remains in the case as an evidentiary finding militating against release, to be weighted along with other evidence." United States v. Hir, 517 F.3d 1081, 1086 (9th Cir. 2008); see also Martir 782 F.2d at 1144 ("The concern underlying the presumption applies to the general class of defendants charged with one of the specified offenses—not merely to defendants who fail to produce rebuttal evidence. Were the presumption ... to vanish upon any showing . . ., courts would be giving too little deference to Congress' findings regarding this class) (emphasis in original). + +#### • The U.S. Pretrial Services Department Recommends To The Court That Mr. Epstein Continue to Be Remanded + +The Pretrial Services report, dated July 8, 2019, concludes, following Pretrial Services' interview of Mr. Epstein, that "[t]here is no condition or combination of conditions that [can] + +reasonably assure ... the safety of the community" if Mr. Epstein is released. Pretrial Services Report, dated July 8, 2019, at 4. Pretrial Services also concluded that Mr. Epstein is a flight risk and recommends that he be detained for that reason as well. Id. + +In support of its assessment of Mr. Epstein's dangerousness, Pretrial Services cites the following: the "Nature of [Mr. Epstein's currently charged] Instant Offence," i.e., sex trafficking and conspiracy involving minor girls; Mr. Epstein's "Prior Arrests," tps, in Florida in 2006; Mr. Epstein's "History [and] Conviction Involving [a] Sex [Offense]," which principally refers to Defendant's 2008 conviction(s) for procuring a person under the age of 18 for prostitution (a felony) and for solicitation of prostitution (also a felony); Mr. Epstein's status as a registered sex offender in New York, Florida and the Virgin Islands; and Mr. Epstein's "Pattern of Similar Criminal Activity History." Id. + +- The Seriousness Of The Crimes That Mr. Epstein Has Been Charged With Is Also Reflected In The Fact That The Crimes Involve Minor Children + +Mr. Epstein is said by the Government to be "a serial sexual predator" who allegedly victimized dozens (or more) of minor girls, including a 14 year old.' He was involved in and undertook the alleged sexual activity in several locations, including, his mansion in Manhattan and his estate in Palm Beach, Florida. Indictment 1 2. By "actively encourage[ing] certain of his [minor] victims to recruit additional girls to be similarly sexually abused," Mr. Epstein is said to have "created a vast network of underage victims for him to exploit." Dkt. 11, Ex. 1 at 2. + +The Government alleges that Mr. Epstein "intentionally sought out—and knew that he was abusing—minors. Indeed, in some instances, his victims expressly told him they were + +I Mr. Epstein is reported to have remarked that: "I'm not a `sexual predator,' I'm an `offender' . . . It's the difference between a murderer and a person who steals a bagel." Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a nredator,New York Post, Feb. 25, 2011. + +underage before or during the period in which he abused them." Id. The crimes with which Mr. Epstein is charged carry a maximum sentence of 45 years of incarceration. Id. at 5. "[T]he deprivation of liberty imposed by imprisonment makes that penalty the best indicator of whether the legislature considered an offense to be ... 'serious."' United States v. Dugan, 667 F.3d 84, 86 (2d Cir. 2011) (quoting v. United States, 518 U.S. 322, 326 (1996)). + +And, the crimes Mr. Epstein has been charged with are among the most heinous in the law principally, in the Court's view, because they involve minor girls. 18 U.S.C. § 3142 (e)(3)(E); see also Roger Przybylski, Chanter 5: Adult Sex Offender Recidivism, Sex Offender Management Assessment and Planning Initiative ("[R]esearchers widely agree that observed recidivism rates are underestimates of the true reoffense rates of sex offenders. Hidden offending presents significant challenges for professionals working in sex offender management as it is difficult to know whether offenders who appear to be nonrecidivists based on official records are truly offense free.") (emphasis in original). + +- Mr. Epstein Or His Representatives Have Intimidated, Threatened, And/Or Made Payments To Potential Witnesses + +The Government's evidence includes: (i) Florida police reports describing harassment and intimidation of witnesses involved in the Florida state criminal investigation of Mr. Epstein in 2006, and (ii) emails, dated September 13, 2007 and September 19, 2007 (attached hereto), from Mr. Epstein's former counsel to Federal prosecutors in Florida discussing the "option" of Mr. Epstein pleading guilty to witness tampering, harassment, and/or obstruction of justice. + +A Palm Beach Police Incident Report, dated July 19, 2006, states that one of Mr. Epstein's victims reported that Mr. Epstein's representative said to her: "Those who help [Mr. Epstein' will be compensated and those who hurt [Mr. Epstein] will be dealt with." Dkt. 11. Ex. 3 at 2 (emphasis added.) The Report also states: "[Mr. Epstein's representative] assured [the + +victim that] she would receive monetary compensation for her assistance in not cooperating with law enforcement." Id. Another (undated) Palm Beach Police Incident Report states that the parent of one of Mr. Epstein's alleged victims contacted the Palm Beach Police to report that Mr. Epstein's private investigator had aggressively driven the parent's car off the road. Dkt. 11, Ex. 2 at 1. This same Report states that the parent of another victim reported being "followed aggressively" by Mr. Epstein's private investigator. Id. + +The Government contends that these reports together "suggest that an associate of Epstein's was offering to buy victims' silence during the course of the prior investigation," and demonstrate Mr. Epstein's "willingness to use intimidation and aggressive tactics in connection with a criminal investigation." Dkt. 11 at II. + +The Government also submits e-mail evidence (attached to this Order as Exhibit 1) of plea discussions in 2007 between Florida federal prosecutors and Mr. Epstein's attorneys that confirm that Mr. Epstein considered pleading guilty to witness tampering, harassment and/or obstruction of justice in a case involving alleged sex crimes with minor girls. On September 13, 2007, prosecutors wrote to Mr. Epstein's counsel that they have been "spending some quality time . . . looking for misdemeanors [that Mr. Epstein could plead guilty to]," including 18 U.S.C. § 1512(d), a Federal witness tampering statute (a felony) and 18 U.S.C. § 403, a Federal statute criminalizing the violation of the privacy protection of child victims and child witnesses (a misdemeanor). Doe v. United States, 08 Civ. 80756, (S.D. Fla.), Dkt. 361-11. Epstein's counsel replied: "Already thinking about the same statutes." M. On September 18, 2007, a Federal prosecutor told Mr. Epstein's counsel that if Mr. Epstein pled guilty to obstruction of justice, the factual proffer "could rely on the incident where Mr. Epstein's private investigators followed [a victim's] father, forcing [him] off the road." 11, Dkt. 361-10; see also supra p. 15. On September + +19, 2007, Mr. Epstein's counsel proposed that Mr. Epstein admit that he verbally harassed victims or the family of victims in connection with his "attempt to delay their voluntary receipt of process" in a civil action against Mr. Epstein, in violation of a Federal witness tampering statute. Doe, Dkt. 361-9. + +And, the Government has recently contended that, on November 28, 2018 and on December 3, 2018 — very soon after the publication of a 3-part investigative report in the Miami Herald (authored by Julie K. =) relating to Mr. Epstein's Florida Non-Prosecution Agreement, dated September 24, 2007 — Mr. Epstein paid \$100,000 to "a company founded and run by [Individual I]," and he paid \$250,000 to [Individual II]. Dkt. 23 at I. The Government states that Individual I was "a potential co-conspirator—[] for whom Epstein obtained protection in a the NPA." Id. Individual I was named and featured prominently in the Miami Herald. ee Lg" Julie K. , "Even From Jail, Sex Abuser Manipulated The System. His Victims Were Kept in The Dark, Miami Herald, Nov. 28, 2018. + +The Government states that Individual 11 was also "a potential co-conspirator—[] for whom Epstein also obtained protection in a the NPA." Dkt. 23 at 2. She is "one of the employees identified in the Indictment, which alleges that she and two other identified employees facilitated the defendant's trafficking of minors by, among other things, contacting victims and scheduling their sexual encounters with the defendant at his residences in Manhattan and Palm Beach, Florida." Id. at 2. Individual II was also named and featured prominently in the Miami Herald report. + +The Government states there is good reason to infer that Mr. Epstein was attempting to "influence [these two] individuals who were close to him during the time period charged in this case and who might be witnesses against him at a trial." Dkt. 11 at 11. "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." Id. + +A court may order detention if there is a serious risk that the defendant will attempt to threaten. injure, or intimidate a prospective witness or juror. 18 U.S.C. § 3142(f)(2XB). Even a single incident of witness tampering has been a "traditional ground for pretrial detention by the courts." LaFontaine 210 F.3d at 132-34 (affirming then-U.S. District Judge Michael B. Mukasey's denial of bail to a defendant who had met with a prospective witness in an effort to persuade the witness to give untruthful testimony and where there was "no evidence of influence, harassment or intimidation"); see also United States v. Singh, 2012 WL 3260232, at \*3 (E.D.N.Y. Aug. 8, 2012). + +- Mr. Epstein Has Not Always Been Compliant With His Legal Obligations As A Registered Sex Offender + +Defense counsel has contended that Mr. Epstein has been "scrupulously fulfill[ing] his obligations in every jurisdiction in which he was required to register [as a sex offender]," since his 2008 Florida convictions. Counsel argues that this shows that he "is no longer a danger to anyone and will faithfully obey all conditions of release if ordered." Dkt. 6 at 3. + +The record shows that Mr. Epstein has challenged his sex offender "level" in at least one jurisdiction since 2008 in an effort to minimize his reporting obligations. And, one recent press account states that Epstein is not in compliance in New York State. See Elizabeth Rosner, Tina Moore, Larry Celona, and Bruce Golding NYPD let convicted pedophile Jeffrey Epstein skin iudae-ordered check-in,New York Post, July 10, 2019 ("July 10, 2019 NY Post Article") + +("Jeffrey Epstein never once checked in with City cops in eight-plus years since a Manhattan judge ordered him to do so every 90 days"). + +Mr. Epstein is a Level III sex offender in New York State which is the highest category of risk to reoffend. This designation requires that Mr. Epstein report his presence in New York to law enforcement authorities every 90 days. As discussed at the July 15, 2019 bail hearing, counsel for Mr. Epstein made an application in New York State Supreme Court in 2011 to reduce Epstein's sex offender registration status from Level III to Level I. If granted, this reduction would have allowed Mr. Epstein to avoid his reporting obligations. In a Sex Offender Registration Act Hearing on January II, 2018, held before the Honorable Ruth Pickholz, Mr. Epstein's application was (firmly) denied, principally because it had been established by the Board of Examiners of Sex Offenders. See People v. Epstein, Indict. # 30129/2010, (N.Y. Sup. Ct.), SORA Hearing Transcript, dated Jan. 18, 2011. + +At the hearing, New York County Assistant District Attorney Jennifer Gaffney joined in Defense Counsel's appeal to review and overturn the decision of the Board of Examiners of Sex Offenders and achieve a downward modification of Mr. Epstein's sex offender status. M. at 2-15. Judge Pickholz appeared to be stunned by the joint Defense Counsel/District Attorney application, stating: "I am just a little overwhelmed that the People are making this application.. . . I have done many SORAs much less troubling than this one where the People would never make a downward [adjustment] argument like this. . I have never seen the prosecutor's office do this. I have to tell you, I am shocked." Id. at 4-5. Judge Pickholz also ordered Mr. Epstein to report as a Level III sex offender every 90 days in New York. Id. at 12. "I am sorry [Mr. Epstein] may have to come here every 90 days. He can give up his New York home [on East 71st. St.] if he does not want to come every 90 days." Id. Epstein appealed but Judge Pickholz's decision + +was unanimously affirmed, on November 17, 2011, by a panel of five judges of the Appellate Division of the New York State Supreme Court. People v. Epstein, 89 A.D.3d 570, 933 N.Y.S.2d 239 (N.Y. App. Div. 2011). + +Notwithstanding Judge Pickholz's order, according to a July 10, 2019 investigative report by the New York Post, as noted, Mr. Epstein has never reported as a sex offender to New York law enforcement. See July 10, 2019 NY Post Article. "The NYPD cop assigned to monitor Epstein has repeatedly complained to [the New York County District Attorney's] Sex Crimes Unit that Epstein wasn't in compliance, according to a source familiar with the matter." Id. Mr. Epstein's alleged failure to comply with his New York sex offender obligations would appear to undermine defense counsel's premise that Mr. Epstein's "perfect compliance" and "meticulous obedience," Dkt. 6 at 1, 5, to his sex offender registration obligations should lead to his release. See LaFontaine 210 F.3d at 135 n.6 (where the Court ordered detention noting that the defendant "had previously disregarded court orders"). + +The Court has also read the story in the July 17, 2019, New York Post in which attorney Brad contends that while Epstein was serving his Florida state sentence (after pleading guilty to procuring a minor under 18 for prostitution and solicitation of prostitution), Epstein was allowed to leave the jail on work release. While on work release "[h]e was having ... female visitors . . . and continuing to engage in ... [sexual] conduct . . . while he was in lair." Mr. is counsel to one of Mr. Epstein's victims. Reuven Fenton and Kate Sheehy, Jeffrey Epstein had sex den while serving time: lawyer, New York Post, July 16, 2019. The Court is also aware of an article published by Palm Beach CBS local news which reports that the Palm Beach County Sherriff's Office "disputes [the] claim that Jeffrey Epstein had sex on work release." A spokeswoman for the sheriff's office is quoted as saying "If he violated any conditions of his + +release he would have been brought back to the Stockade and work release would have been terminated." Chuck PBSO disputes claim that Jeffrey Epstein had sex on work release, CBS 12 News, July 17, 2019. + +#### • New Mexico, Florida And The Virgin Islands + +With respect to Mr. Epstein's sex offender status in New Mexico, Defense Counsel has submitted a letter, dated August 19, 2010, from Regina Chacon, Assistant Bureau Chief, Law Enforcement Record Bureau of the New Mexico Department of Public Safety, which states that Mr. Epstein "is not required to register [as a sex offender] with the State of New Mexico at this time for [his] 2008 Florida conviction of Procuring [a] Person Under 18 for Prostitution." Dkt. 25, Ex. A. The Court requested from the Defense all application materials that Mr. Epstein may have submitted to the New Mexico Department of Public Safety, believing that the Department would not initiate the waiver of Mr. Epstein's sex offense registration on its own. No such materials have been received by the Court as of this date. + +The Court understands that Mr. Epstein is also registered as a sex offender in the Virgin Islands (Level I) and in Florida (Level I). It has received no materials from the Defense regarding sex offender applications or proceedings in those two jurisdictions. + +In sum, based upon all of the proffers and evidence set forth at pp. 10-21 above, the Court finds by clear and convincing evidence that Mr. Epstein poses a danger to other persons and to the community. + +## G. Mr. Epstein Also Poses A Risk Of Flight + +In the section that follows, the Court considers "risk of flight" even though it has already determined that Mr. Epstein presents a danger to the community. "[A] finding of either danger to the community or risk of flight will be sufficient to detain the defendant pending trial." + +United States v. 849 F.2d 485, 488 (11th Cir. 1988) (quoting United States v. Pones, 786 F.2d 765 (7th Cir. 1985)). The Court finds that the Government has shown by a preponderance of the evidence that Mr. Epstein is a flight risk. + +The factors to be considered in analyzing risk of flight are the same factors that apply when analyzing dangerousness. They are: (1) the nature and circumstances of the crimes charged; (2) the weight of the evidence against the defendant; (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." 18 U.S.C. § 3142(g). "The weight afforded to each factor under section 3142(g) is within the `special province' of the district court." Paulino, 335 F. Supp. at 610. + +At the outset, it should be noted that the Pretrial Services Report, dated July 12, 2019, concludes that: "The defendant poses a risk of nonappearance for the following reasons: + +- 1. [Mr. Epstein's] Extensive foreign travel and possession of travel documents +- 2. [Mr. Epstein's] Residential and Financial Ties outside this District and Country +- 3. [Mr. Epstein's] Employment ties outside this country +- 4. [Mr. Epstein's] Unexplained assets +- 5. [Mr. Epstein's] Criminal History including [his] conviction for a [] sex offense [with minors in Florida in 2008]." Pretrial Services Report, dated July 12, 2019 at 4. + +## • The Crimes Charged Against Mr. Epstein + +Mr. Epstein has been charged with among the most serious crimes recognized by U.S. Federal law. The Government has alleged that Mr. Epstein intentionally sought out and sexually abused minor girls, including those "particularly vulnerable to exploitation." Dkt. II, Ex. 1, at 2. He did this in multiple locations, including New York and Palm Beach. Id. And, Mr. Epstein allegedly "worked and conspired with others, including employees and associates who facilitated his [unlawful] conduct, by ... contacting victims and scheduling their sexual encounters." Indictment ¶ 4. These crimes, as already noted, carry a maximum sentence of 45 years of incarceration and give rise to a presumption of pre-trial remand. 18 U.S.C. § 3142 (eX3XE); see United States v. Hardy, 2019 WL 2211210, at \*10 (D.D.C. May 22, 2019) ("The significant harms and dangers of these crimes animated the Congress to create the statutory presumption of detention."). The nature and circumstances of the crimes charged and the severity of the potential punishment support a finding that Defendant poses "a serious flight risk and that no conditions can be set to reasonably assure his appearance for trial." United States v. Cilins 2013 WL 3802012, at •2 (S.D.N.Y. July 19, 2013). + +#### • Weight Of The Evidence + +The Government's evidence against Mr. Epstein appears strong. The evidence includes testimony of victims, some of whom were minor girls when they were allegedly sexually abused by Mr. Epstein; other witnesses, including potential coconspirators; physical evidence, including passports reflecting extensive foreign travel; sexually suggestive photographs of nude underage girls; plea discussions; and police reports describing witness tampering and intimidation. See gs" United States v. Fama, 2013 WL 2467985, at •3 (S.D.N.Y. June 7, 2013) ("the Court recognizes the difficulty inherent in assessing the Government's case before trial, and is mindful not to reach any conclusions about [the Defendant's] guilt or innocence. Indeed, some courts have described the weight of the evidence factor as the `least important' of the § 3142(g) factors for these reasons."); see also Hit 517 F.3d at 1090. + +## • History And Characteristics Of The Defendant Including His Financial Resources + +Mr. Epstein pled guilty to two state felonies involving minor girls in Florida. He also held plea discussions regarding witness tampering in Florida in 2008. He is a registered Level III sex offender in New York and a registered sex offender in Florida (Level I) and the Virgin Islands (Level I). Mr. Epstein is 66 and is reported to be a self made multi-millionaire. He did not graduate from college. Mr. Epstein's vast wealth, including substantial liquid assets, multiple residences, private plane(s), a \$8,672,823 residence in Paris, France, and relatively limited family ties to the United States in the sense that he is single with no children and his parents are deceased. He has a brother who Defense counsel asserts has offered to serve as a guarantor for Mr. Epstein by pledging his home in West Palm Beach, Florida. (The Court notes that the Pretrial Services Report, dated July 12, 2019, states that "[t]he defendant stated he maintains minimal contact with his brother, Mark Epstein, and that his exact location is unknown at this time." Pretrial Services Report at 2.) + +Mr. Epstein engages in extensive overseas travel often relying on his own plane(s). The Government argues persuasively that "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." Dkt. 11, Ex. 1 at 1. "[I]n 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." Id. at 3. + +In a recent search of Defendant's New York City home, law enforcement seized an expired Austrian passport bearing Mr. Epstein's photo but not his name. (The passport is in another name.) The Austrian passport lists residence in Saudi Arabia According to the Government, Defense counsel declined to respond when asked by the Government if the + +"Defendant is currently, or has been in the past, a citizen or legal permanent resident of a country other than the United States." Dkt. 23 at 2. + +Defense counsel contends that Defendant has one active passport that was surrendered and that "Mr. Epstein has no foreign passports." Dkt. 6 at 3 n. 3. With regard to the Austrian passport, the Defense explains that "Epstein ... acquired the passport in the 1980s, when hijackings were prevalent, in connection to Middle East travel. The passport was for personal protection in the event of travel to dangerous areas, only to be presented to potential kidnapers, hijackers or terrorists should violent episodes occur." Dkt. 24 at 8. Details about how the passport was procured by Mr. Epstein in the name of another individual were not provided and are not known to the Government. See Dkt. 23 at 2 ("The Government is attempting to obtain additional information about the Foreign Passport, including how it was obtained and whether the passport is genuine or fabricated. But the defendant's possession of what purports to be a foreign passport issued under an alias gives rise to the inference the defendant knows how to obtain false travel documents and/or assume other, foreign identities. This adds to the serious risk of flight posed by the defendant."). The Government also argues that "the passport contains numerous ingress and egress stamps, including stamps that reflect use of the passport to enter France, Spain, the United Kingdom, and Saudi Arabia in the 1980s." Dkt. 30. By submission dated July 18, 2019, the Defense explains: "Epstein was given the passport at issue by a friend . . . He never used the document to travel internationally and never presented it to any immigration or customs authority. The passport stamps, predating his receipt of the document, do not reflect Mr. Epstein's entries or exits." Dkt. 31. + +Defense counsel has submitted a one page document called "Asset Summary - June 30, 2019." It indicates that Epstein has cash in the amount of \$56,547,773; fixed income valued at + +\$14,304,679; equities valued at \$112,679,138; hedge funds and private equity valued at \$194,986,301; properties located at 9 East 71st Street, NY, NY 10021 valued at \$55,931,000, 49 Zorro Ranch Road, Stanley, New Mexico 87056 valued at \$17,246,208, 358 El Brillo Way, Palm Beach, Florida 33480 valued at \$12,380,209, 22 Avenue Foch, Paris France 75116 valued at \$8,672,823, Great St. James Island No. 6A USVI 00802 (parcels A, B, and C) valued at \$22,498,600 and Little St. James Island No. 6B USVI 00802 (parcels A, B, and C). Dkt. 14 at 18. The Court has advised Defense counsel that this "cursory" asset statement is insufficient to support a bail package for the reasons, among others, that it is not verified and does not show expenses, indebtedness, or liabilities. + +Law enforcement has informed the Government that a safe in the Defendant's New York home very recently contained "more than \$70,000 in cash ... 48 loose diamond stones, ranging in size from approximately 1 carat to 2.38 carats, as well as a large diamond ring. The Government is currently unaware of whether the Defendant maintains similar [amounts] of cash and/or jewels at his multiple properties, or in other locations. Such ready cash and loose diamonds are consistent with the capability to leave the jurisdiction at a moment's notice." Dkt. 23 at 3. + +The Defendant's vast wealth and influential contacts have provided him with the means to pay individuals to assist him in unlawful endeavors, including potentially fleeing the jurisdiction. In the past, "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." Dkt. 11, Ex. I at 2. + +David Boies, who, as noted, represents identified victims in this case, advised the Court that while a civil case was proceeding against the Defendant "we had situations in which we had witnesses who were cooperating with us and then were contacted by either Mr. Epstein or his lawyers and who then stopped cooperating with us." 7/15/19 Tr. at 7P see also United States v. Boustani 356 F.Supp.3d 246 (E.D.N.Y. 2019) ("[T]he combination of Defendant's alleged deceptive actions, access to substantial financial resources, frequent international travel, complete lack of ties to the United States, and extensive ties to foreign countries without extradition demonstrates Defendant poses a serious risk of flight." ); United States v. Epstein, 155 F.Supp.2d 323, 326 (E.D. Penn. 2001) ("The crucial factor, however, is defendant's lack of ties to the United States and his extensive ties to Brazil with which no extradition treaty exists. In our view, his forfeiture of Slmillion worth of assets in the United States would not deter him from flight when in Brazil he has significant wealth, a lucrative job, the presence of his family, and insulation from ever being forced to stand trial."). + +Viewing the totality of the circumstances, the Court finds that the Government has shown by a preponderance of the evidence that Defendant is a serious risk of flight and that no conditions can be set that will reasonably assure his appearance at trial. "While other judges in this district have found that an armed security guard may be sufficient to assure a defendant's appearance, even when he is a serious risk of flight ... this Court does not believe that that condition, even coupled with the additional conditions proposed, would be sufficient." United Cilins,2013 WL 3802012, at •3. + +## • The Danger Posed By The Defendant's Release + +As demonstrated infra, Mr. Epstein's dangerousness is considerable and includes sex crimes with minor girls and tampering with potential witnesses. The discussion at pp 10-21 is incorporated here by reference. See Minnici 128 F. App'x at 829-30 ("the alleged activities [wejre of an addictive sexual nature that cannot be suppressed simply by a restrictive set of bail conditions"); see also Milian, 4 F.3d at 1049 ("[T]he protection of the community can be assured only by continued detention."). + +The Court has carefully considered the issue of Defendant's ability and motivation for fleeing U.S. jurisdiction. The Court finds that the Government has proven by a preponderance of the evidence that, among other things, the Defendant's limited family ties to the United States, his residence in Paris, his extensive overseas travel, his significant wealth and his substantial resources (including private planes), and the potential 45 year term of imprisonment that may be imposed should there be a conviction in this case, provide incentive, motive and wherewithal to flee. Indeed, these factors render him a "classic" flight risk. Sec. e.g.. United States v. Abdullahu, 488 F.Supp.2d 433,445 (D.N.J. 2007) ("After reviewing the totality of the evidence, the Court has reached the inescapable conclusion that the government has proved by a preponderance of the evidence that no condition or combination of conditions exist that will reasonably assure the defendant's appearance at trial. The defendant faces serious criminal charges . . . The defendant faces a potential ten year prison sentence and involuntary deportation. The defendant does not have permanent and longstanding ties to this area, he has the means and incentive to flee and he has family ties and a place to live in an overseas country that will not extradite him to the United States."). + +# H. Defendant's Proposed Bail Package + +Having determined that Mr. Epstein is a flight risk (and also a danger to the community), the Court next examines the Defendant's proposed bail package. ate 18 U.S.C. § 3142(b)-(f)(2). + +The Court finds that the Defendant's proposed bail package is inadequate. Among its deficiencies are these: + +(1) The bail package is not accompanied or supported by audited or certified financial statements, including details of income and expenses and debt obligations. There is no affidavit from Mr. Epstein. As noted, Defense counsel submitted a cursory one page "Asset Summary - June 30, 2019" on Mr. Epstein's behalf in which he discloses several categories of assets totaling \$559,120,954. The Defense states that it "would be impossible for Epstein — given, among other impediments, his detention, inability to quickly access pertinent records, and inability to quickly make a precise valuation of particular assets — to provide a sufficient financial statement by the Court's 5 pm deadline." Dkt. 23 at 4. + +The absence of accurate and comprehensive financials, sworn to by the Defendant, does not allow the Court meaningfully to assess Defendants' own proposed bail package nor would it enable the Court to fashion a bail package on its own. The Court would not be able to determine what level of bail — in relation to Epstein's finances — would reasonably assure the Defendant's appearance. Defense counsel proposed at the bail hearing on July 15, 2019 that it would take a few days to prepare accurate financials for Mr. Epstein. He also suggested that he would do so (only) if the Court were agreeable to granting bail. This "offer" appears disingenuous for a person as wealthy and experienced in financial matters as Mr. Epstein. She Tr. 7/15/19 at 50 (Court: "There needs to be a fuller financial picture to know what would be appropriate." Defense Counsel: "Let me be blunt. It was our first effort . . . ."). That Mr. Epstein does not have a financial statement, including liabilities and expenses, readily available is difficult to understand. + +(2) The defense bail package proposes excessive involvement of the Court in routine aspects of Mr. Epstein's proposed home confinement. This is not the Court's function. ite United States v. Zarrab, 2016 WL 3681423, at \*10 (S.D.N.Y. June 16, 2016) ("The [bail package] . . . proposed by the defense is not reasonable because, in too many respects, it substitutes judicial oversight and management for (more appropriate) reliance upon trained, experienced, and qualified professionals from the U.S. Bureau of Prisons and the U.S. Marshals Service."). The Defense package components would embroil the Court in issues, among others, relating to the level of force that may be used to secure the Defendant, who may enter the residence, daily reporting by Mr. Epstein, and reporting by so-called Trustee(s) designated to live with and supervise Mr. Epstein. See United States v. Valerio 9 F. Supp. 3d 283, 295 (E.D.N.Y. 2014) ("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."). + +(3) The Defense proposal to give advance consent to extradition and waiver of extradition rights is, in the Court's view, an empty gesture. And, it comes into pay only after Mr. Epstein has fled the Court's jurisdiction. According to the Government, "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." Dkt. 11 at 7. + +(4) Although the Defense has stated that Mr. Epstein would be agreeable to putting up "any amount" of collateral or signing "any bond" the Court would require, there has, to date, + +been no concrete pledge of any real assets or any concrete proposal to turnover deeds to real property, or to provide a specific amount of cash. 7/15/19 Tr. at 50 ("I am authorized to say to the Court that whatever bond you want Mr. Epstein to sign, whether it's \$100 million or an amount close to the amount of the assets that we have provided, Mr. Epstein is prepared to sign it."). + +The Court, as noted, has no detailed information regarding the extent of the Defendant's assets, including the nature, value and location of all of his assets. There is no mention of any expenses, liabilities, or indebtedness. And, there has been no persuasive Defense counter to the Government's argument that "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-I, 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." Dkt. 11 at 5 (emphasis omitted). The Defendant, it should also be noted, is already at risk of losing some of his real property because the Indictment contains a forfeiture allegation regarding any property that was used or intended to be used to commit or to facilitate the sex trafficking offenses and that includes, but it is not limited to, the property located at 9 East 71st Street, New York, New York. + +(5) The appointment and role of "trustees" who will presumably live with Mr. Epstein and monitor his compliance with bail conditions are unacceptably vague. They do not, for example, address the conflict that is created by the salary the "trustees" are earning from the + +Defendant and their purported role as independent monitors. (The same problem arises in relation to private 24/7 security guards.) This is especially problematic where, as here, it is alleged that employees of the Defendant may have engaged in unlawful acts with and on behalf of the Defendant. According to the Government, "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." Dkt. 11, Ex. 1 at 2. + +(6) "As a fallback," the Defense suggests the utilization of and the funding of a private security guard agency to "virtually guarantee" Mr. Epstein's presence in court and, presumably, also to supervise his behavior. This contingency plan is not a part of Mr. Epstein's 14 point proposal. Nevertheless, the Court is asked by the defense to "revisit" its legal viewpoint as expressed in an earlier decision concerning 24/7 private home security guards. + +Each bail package in each case is considered and evaluated on its individual merits by the Court. And, in view of the Court's finding of dangerousness, a new bail proposal likely would be futile. See. e.g. United Ferranti 66 F.3d at 544 ("No conceivable conditions could ensure the safety of the community."); Orena, 986 F.2d at 632 ("We do not agree that the bail conditions set by the district court eliminate the danger to the community or are superior to detention for purposes of the Bail Reform Act."); United States v. Colombo, 777 F.2d 96, 100 (2d Cir. 1985) ("These conditions are clearly inadequate to protect the public from one found for bail purposes to be a danger to the community."). + +#### Conclusion & Order + +Based upon the forgoing, the Government's motion for remand (detention) is granted and the Defense motion for pretrial release is denied. + +Dated: New York, New York July 18, 2019 + +RICHARD M. 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OF N.Y. + +NOTICE OF APPEAL + +United States District Court + +Southern District of New York + +Caption: + +United States + +Jeffrey Epstein + +Docket No.: 19-cr-00490 (RMB) +Hon. Richard M. Berman +(District Court Judge) + +Notice is hereby given that Defendant Jeffrey Epstein appeals to the United States Court of Appeals for the Second Circuit from the judgment other ✓ Decision & Order Remanding Defendant entered in this action on July 18, 2019 (date) (specify) + +This appeal concerns: Conviction only | Sentence only | Conviction & Sentence | Other | ✓ +Defendant found guilty by plea | trial | N/A | ✓ +Offense occurred after November 1, 1987? Yes | ✓ No | N/A | +Date of sentence: N/A | ✓ +Bail/Jail Disposition: Committed | ✓ Not committed | N/A | + +Appellant is represented by counsel? Yes ✓ | No | If yes, provide the following information: + +Defendant's Counsel: Reid Weingarten +Counsel's Address: 1114 Avenue of the Americas +New York, NY 10036 +Counsel's Phone: (212) 506-3900 +Assistant U.S. Attorney: Alex Rossmiller +AUSA's Address: 1 Saint Andrew's Plaza +New York, NY 10007 +AUSA's Phone: (212) 637-2415 + +*Reid Weingarten* +Signature + +*4/22/19 +\$ 505.00 +Hereby accepts* \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824387/EFTA02824387.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824387/EFTA02824387.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..07e088fdea2d3aa7d99156e663bc69f5ca868533 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824387/EFTA02824387.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824387.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1282, + "elapsed_seconds": 5.83, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Criminal Notice of Appeal - Form A", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 78.33600000000001, + 55.08000000000001 + ], + [ + 224.60399999999998, + 55.08000000000001 + ], + [ + 224.60399999999998, + 67.23 + ], + [ + 78.33600000000001, + 67.23 + ] + ] + }, + { + "title": "NOTICE OF APPEAL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 246.02400000000003, + 85.85999999999999 + ], + [ + 361.08, + 85.85999999999999 + ], + [ + 361.08, + 98.82 + ], + [ + 246.02400000000003, + 98.82 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 118 + ], + [ + "Line", + 43 + ], + [ + "Text", + 37 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824387" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824388/EFTA02824388.md b/marker2/court-us-v-epstein-cr/EFTA02824388/EFTA02824388.md new file mode 100644 index 0000000000000000000000000000000000000000..45a887dd5e0da31c8d601f8e9e667877b79763ff --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824388/EFTA02824388.md @@ -0,0 +1,27 @@ +## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA + +USA / Plaintiff(s) + +case No.: 19CR490 + +JEFFREY EPSTEIN, + +Defendant(s) + +## NOTICE OF FILING OF OFFICIAL TRANS(' R I I + +CONFERENCE Notice is hereby given that an official transcript of a held on has been filed by the court reporter/transcriber in the above-captioned matter. 7/15/19 + +Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting the transcript is a judge or a member of the public or media. + +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically available to the public without redaction after ninety (90) calendar days. + +This process may only be used to redact the following personal data identifiers: Social Security numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information may proceed by motion. + +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. + +/s KELLY SURINA + +Court Reporter/Transcriber Date \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824388/EFTA02824388.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824388/EFTA02824388.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..77ca61fc1492a7d92a8b781c8715cef6322199c6 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824388/EFTA02824388.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824388.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1446, + "elapsed_seconds": 0.83, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "IN THE UNITED STATES DISTRICT COURT \nFOR THE SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 153.612, + 67.23 + ], + [ + 418.71282958984375, + 67.23 + ], + [ + 418.71282958984375, + 96.363037109375 + ], + [ + 153.612, + 96.363037109375 + ] + ] + }, + { + "title": "NOTICE OF FILING OF OFFICIAL TRANS(' R I I", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 167.688, + 308.6015625 + ], + [ + 446.76, + 308.6015625 + ], + [ + 446.76, + 322.4830627441406 + ], + [ + 167.688, + 322.4830627441406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 28 + ], + [ + "Text", + 15 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824388" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824389/EFTA02824389.md b/marker2/court-us-v-epstein-cr/EFTA02824389/EFTA02824389.md new file mode 100644 index 0000000000000000000000000000000000000000..ff14518fd9338fe1ba1625723a1361c20accff2a --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824389/EFTA02824389.md @@ -0,0 +1,1545 @@ +1 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x + +3 UNITED STATES OF AMERICA, + +4 v. 19 CR 490 (RMB) + +5 JEFFREY EPSTEIN, + +6 Defendant. + +7 x + +8 9 New York, N.Y. July 15, 2019 10:05 a.m. + +10 Before: + +11 HON. RICHARD M. BERMAN, + +12 District Judge + +13 + +14 + +15 16 17 GEOFFREY S. BERMAN United States Attorney for the Southern District of New York BY: ALEXANDER ROSSMILLER ALISON G. MOE Assistant United States Attorneys + +18 G. Weinberg, PC Attorney for Defendant + +19 + +20 Steptoe & , LLP (NYC) Attorneys for Defendant BY: REID WEINGARTEN + +21 + +22 MARC FERNICH Attorney for Defendant + +23 JAMES BROCHIN Attorney for Defendant + +24 + +25 JAFFE Attorney for Defendant Conference + +## APPEARANCES + +2 Also Present: David Boies 3 Brad Paul Byrne, NYPD 4 Amanda Young, FBI + +5 Bernisa Mejia, Francesca U.S. Pretrial Services nl and Dennis Khilkevich, + +2 3 4 5 For your information and for the people sitting in the overflow courtroom, we have tried to accommodate everybody into this proceeding either here in my usual courtroom or in the overflow room. So I hope everybody can hear me. + +6 7 8 9 10 11 The purpose of today's proceeding, as I'm sure you're all aware, is to conduct a bail hearing. In this matter, as I think you know, the government is seeking continued pretrial remand of Mr. Epstein and the defense is arguing for pretrial release. The parties have submitted helpful written submissions, and they have been placed on the docket. + +12 13 14 You should also be aware, if you weren't I don't think you are -- that there is what's called a pretrial services report. One has been filed with me today. + +15 16 17 Typically the purpose of such a report is to make a recommendation to the Court as to whether there should be bail or detention. + +18 19 20 21 There was an additional report -- I think they've gotten additional information in today's report -- and the representatives of pretrial services are here in the court today. + +22 23 24 25 The report itself is typically not filed on the docket, but it does conclude as follows. This is a quote. It says that "There is no condition or combination of conditions that will reasonably assure the appearance of the defendant as 1 2 3 required and the safety of the community." It goes on to conclude that: "Therefore, pretrial services respectfully recommends the defendant be detained." + +4 5 Now, of course this ultimately is the issue that I have to decide and will do so with your help. + +6 7 8 9 10 11 12 13 You should be aware, incidentally, that I have not yet reached a decision on this matter, and I do not intend to do so today. I need a little bit more time to absorb everything that's been submitted, and I will probably do so, that is to say, give my decision here in the courtroom, on Thursday, July 18, at 9:30 here in Courtroom 17B. I will endeavor to finish by then and to be able to share with you my determination. + +14 15 16 17 18 We also have in the court today several persons who are contending that they are victims in the legal context of Mr. Epstein's conduct. They're welcome in these proceedings. Indeed, they have the right to be present, and they also have the right to be heard under federal law. + +19 20 21 22 As I understand it, they have advised the Court, through counsel and through the government counsel, that they oppose bail for Mr. Epstein. They may also be heard today in court if they wish to be heard. + +23 24 25 So for today, I thought, if this is agreeable to the government and the defense, I would give each side say up to 20 minutes, if they wish to have it and if they do wish to be + +2 3 4 The government always has the burden of proof. So I would start with them. They made the first application which was for remand. + +5 6 7 8 9 10 I should tell you -- and I will right now -- that I have some questions for each side. And I'm going to go over them with you right now so that before the government and the defense speaks, they will know what questions I would like them to address, if they wish to. Otherwise, they can say whatever they wish. But these are questions that I have on my mind. + +11 12 13 So the first question is this. It involves some discussion that I would like each side to address. As you know, this case involves two counts or two charges. + +14 15 16 17 18 19 These are allegations contained in the indictment. One is conspiracy to commit sex trafficking. And the other, the second count, is the substantive count of sex trafficking. The referenced statute is 18 U.S. Code, Section 1591. And for our purposes, since this is a bail proceeding, also the Bail Reform Act. + +20 21 22 23 24 Section 1591, as is relevant here -- those cases are unusual in the criminal law insofar as they carry with them a presumption that "No condition or combination of conditions will reasonably assure the appearance of the person as required and the safety of the community." + +25 As you probably know already, most cases carry a + +1 2 presumption that bail will be granted. That is not true with respect to the charges here. + +3 4 5 6 7 The presumption of remand, as in this case, may be rebutted by the defense. And if it is, the government has the burden of proving that remand is nevertheless warranted. Indeed, the government bears this burden of persuasion throughout. + +8 9 10 The burden with respect to the safety of the community is clear and convincing evidence, and the burden with respect to risk of flight is preponderance of the evidence. + +11 12 13 14 The defense argues that the presumption of remand is rebutted here. And I refer to several places where they say that, but one is at page 6 and following of their letter application for release of Mr. Epstein. + +15 16 17 18 So my question as relates to this burden and presumption is for the defense particularly, how was the burden rebutted in this case which is something that they contend they've been able to do. + +19 20 21 And my question for the government is whether that presumption has been rebutted and, if so, how has the government been able to prove remand is appropriate, if it has. + +22 23 24 25 So here is another question. Actually, I have a lot of questions. But the ones that are on top of my mind are five. We have all the time in the world. So if you have more questions, I'd be happy to have them answered. + +1 2 3 4 So the question is the following: Mr. Epstein has been required to register as a sex offender in several states going back I believe to 2008 when he pled guilty to an offense in Florida. + +5 6 7 Those states include New York, Florida, and the Virgin Islands. So one question I have for each side is what about New Mexico. That's half of the question. + +8 9 10 11 12 The rest of the question is as follows: Mr. Epstein has applied in New York state to lower his sex offender status from what's called a level 3, which is the highest level which I think carries with it a high risk of recidivism, according to these levels and to sex offender regulation. + +13 14 15 16 17 18 19 And he sought to have that lowered to level 1. His application was denied, as I understand the proceedings, by the Board of Examiners of Sex Offenders New York state and then in state court by the courts and, particularly, a decision of the Honorable Justice Ruth Pickholz on our about January 18, 2011. I believe that decision was appealed to the New York State Appellate Division and was unanimously upheld. + +20 21 22 23 24 I read this morning a copy of the transcript of the proceedings before Judge Pickholz which I'm likely to place on the docket after today's session. And the question is for each side. First of all, they're free to comment on my description of the proceeding before Judge Pickholz. + +25 But the question is whether there were or are other + +1 2 3 legal or administrative proceedings in Florida, the Virgin Islands, New Mexico, and any other jurisdiction comparable to the one before Judge Pickholz in which she ruled on 1-18-2011. + +4 5 6 7 So I'm not suggesting that there are, although I think I did read someplace that there may be some proceeding pending in New Mexico. I'm not quite sure. That's what I hoped you could help me out on. + +8 9 10 11 12 It doesn't have to be precisely the same proceeding that Judge Pickholz had. I'm looking for any transcripts in particular and administrative or legal proceedings in other states relating in any way to Mr. Epstein's sex offender status. + +13 14 15 16 17 The third question on my mind is this: The defense has submitted a brief financial summary to the Court of Mr. Epstein's assets. And I, as you know, permitted that it be submitted under seal for, among other reasons that were on my mind, not to slow the proceedings down. + +18 19 20 21 22 23 The summary is cursory I would say, short, less than a page and does not fully assist me in rendering the bail/remand decision, that is to say, in its detail or absence of detail. And moreover, the information provided in that summary seems to be known already to the government in other ways. They seem to have gotten that information from other sources. + +24 25 So I am inclined to place the summary on the docket, but I want to hear from both sides whether I should or should + +2 3 4 5 Four, the government, as you probably know, has conducted a search of Mr. Epstein's home on East 71st Street on the Upper East Side a little over a week ago in tandem, as it were, or in connection with Mr. Epstein's arrest. + +6 7 8 The government contends in its submission that the information uncovered as a result of that search supports detention, pretrial detention, in this proceeding. + +9 10 11 12 13 And I would like to know from the government particularly what that information is and whether it would be feasible -- it certainly would be helpful if there is such information, that a sample of that evidence in some form be included in this bail remand proceeding. + +14 15 16 17 18 19 20 Lastly for now, this fifth question. The government contends that there is evidence of recent what appears to be or what could be alleged witness tampering or obstruction of justice in connection with two recent payments, one in the amount of \$250,000 and another in the amount of \$100,000 to, as I understand it, to two employees or associates of Mr. Epstein's. + +21 22 23 24 Those payments were made soon after a Miami Herald story about this case and particularly the role of the Florida United States Attorney, Mr. Acosta at the time, and the U.S. Attorney's Office. + +25 And I would like to hear from the government and/or + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +the defense what additional insight about this episode they can share with us to support their position in these proceedings. + +So, as all good lawyers, I reserve the right to have more questions, and I probably will. + +But I'm happy to begin with Mr. Rossmiller and have you heard on the issue of remand versus bail. If you can include some or all of these questions in your presentation, that would be great. + +MR. ROSSMILLER: Yes, your Honor. + +Your Honor, the government seeks pretrial detention in this case due to the extraordinary risk of flight and the danger presented by the defendant to the community, a danger that is not speculative but, rather, is evident from his prior actions. As a result, we join with the recommendation from pretrial services and the requests of the victims that the defendant be detained. + +As the Court pointed out, with the sex trafficking offense charged here, there is a presumption that no combination of release conditions could reasonably assure the defendant's appearance and the protection of the public. + +The Court asked whether the presumption has been rebutted, and the answer is no. There has been no information provided by the defendant to rebut that presumption in this case. + +And in particular, as the Court noted, the defendant + +1 2 3 provided no specific detailed financial information in its submission. I'll get into that in a little bit more in a moment. + +4 5 6 7 8 9 But certainly the first question for a defendant of this tremendous means is how much money does he have, where is it, what are the accounts, is it in foreign accounts, how much is in diamonds or art. These are all details that would be necessary for the Court to even begin to consider this type of application. + +10 11 12 13 14 So, no. The presumption has not been rebutted. However, your Honor, even if the defense were able at some point to rebut the presumption by providing some more information, there simply is no way that they can meet the standard here. + +15 16 17 The evaluation of the Bail Reform Act suggests that all of those factors counsel in favor of remand, which we'll go into in a little more detail. + +18 19 20 THE COURT: It is accurate to say that you as the government has the burden of persuasion or proof in this instance. Right? + +21 22 23 24 MR. ROSSMILLER: Yes, your Honor. There are good reasons why sex trafficking has a presumption of detention and even more so where a defendant, as this defendant has, has previously been convicted of a sex offense. + +25 And in connection with that, his dangerousness is + +1 2 3 4 5 clear from his willingness to tamper with witnesses and victims as the Court can see from the two police reports produced to the Court and from the defendant's payments just months ago to individuals associated with the defendant during the relevant time. The Court asked a question about that. + +6 7 8 9 10 11 Your Honor, we just became aware of those payments late last week. We, frankly, don't have additional information other than that they were paid, that they were paid to two individuals who were associated with the defendant at the time, and that those two individuals are both listed in the non-prosecution agreement. + +12 13 14 So there is certainly an inference there that the defendant was attempting to influence them right around when he came back into public consciousness. + +15 16 17 18 19 20 Your Honor, the victims in this case seek detention and fear his release. And most of all, he is an extraordinary flight risk. As the government has discussed, he has six homes. He owns two private islands. He owns a residence in France. And he has told his own financial institution that he is worth more than \$500 million. + +21 22 23 24 In the government's filing last Monday, we described the defendant as being extraordinarily wealthy which was confirmed by the defense even in his very minimal financial disclosure. + +25 Since the government's initial filing, we have + +1 2 3 4 5 6 obtained records from a financial institution that has been associated with the defendant confirming that the defendant represented his net worth as more than \$500 million. Your Honor, just as one example, the defendant had a single account at that financial institution totaling more than \$110 million. + +7 8 9 There can be no dispute whatsoever that this defendant has vast assets and every incentive in the world to use those assets to flee from justice. + +10 11 12 13 14 15 Your Honor, the government seeking detention in this case is not unusual. Defendants are routinely detained in this district when facing such charges, and this defendant should be treated no differently. The fact that he has considerable resources to flee prosecution only makes the case for his detention stronger. + +16 17 18 19 20 21 On that note, with respect to the strength of the evidence, again, last Monday, the government described its evidence as "strong." Just a week later, after seven days of this case being public following months of a covert investigation, the evidence is already significantly stronger and getting stronger every single day. + +22 23 24 25 Many individuals identifying themselves as victims and witnesses have contacted the government, and we are in the process of receiving and corroborating this additional evidence. + +1 2 3 4 5 6 7 8 Your Honor, with a case that's no longer covert, we have been able to dramatically expand the scope of our investigation in just the last week. And that additional evidence builds on a case that was already indicted by a grand jury, that already included evidence of dozens of alleged victims, that already included significant corroborated evidence, evidence that led to the charges for which this 66-year-old defendant could serve up to 45 years in prison. + +9 10 11 12 13 14 The defendant has essentially conceded that the government will be able to prove the elements of the crimes currently alleged. They acknowledged in their submission that the government likely will be able to show that the defendant engaged in sex acts for money with girls he knew were under age. + +15 16 17 18 Now, in the face of all of this evidence and the extraordinary incentives for the defendant to flee, what does the defendant propose? Nothing that would meaningfully mitigate the risks of danger and especially flight. + +19 20 THE COURT: Are you talking about the bail package now? + +21 MR. ROSSMILLER: Yes, your Honor. + +22 23 24 25 So in the first instance, the defendant's one-page financial disclosure form is more significant for what it does not include than what it does. It is cursory, as the Court said, at best. + +1 2 3 4 5 6 7 It does not include a list of accounts. It does not include a list of financial institutions. It does not identify what types of currencies the defendant holds. It does nothing to identify the location of his holdings. It does nothing to identify high-value property such as diamonds or art, both of which were observed in abundance in just the government's search of his Manhattan mansion. + +8 9 10 11 The other thing, your Honor, is we're just relying on the defendant's word for all of this. This is not sworn. It's not under penalty of perjury. There are no account statements. There are no bank records. There is nothing to validate this. + +12 13 14 15 16 That's not to say that if this were validated, that this would somehow rise to the level of being granted bail, but it's notable with respect to the presumption in particular and also with respect to how the Court evaluates the defendant's assets that we are relying on him. + +17 18 19 20 The defendant's financial disclosure form should alarm the Court, your Honor, not give it comfort that there are conditions that would keep the defendant from fleeing and prevent him from being a danger. + +21 22 23 24 25 With respect to the proposed package, the defendant proposes the Court accept his Manhattan mansion as security for a bond. Now, the government has already designated that property for seizure making it worthless to the defendant. He proposes cosigners who couldn't possibly secure a package + +2 3 THE COURT: I don't know that we know that because we don't really know what their financial situation is. + +4 5 6 7 MR. ROSSMILLER: I suppose that's true, your Honor. Based on the government's preliminary research, it seems like they wouldn't be able to, but we have no idea. That's exactly right. + +8 9 10 11 The defendant's proposal of home confinement and electronic monitoring is also meaningless for an individual with his financial resources. Reducing this defendant's head start in fleeing should be of no comfort whatsoever. + +12 13 14 15 16 17 In connection with that factor, your Honor, just this morning, the government became aware that in a locked safe in the defendant's mansion there were piles of cash, dozens of diamonds, and a passport appearing to be issued from a foreign country with a photo of the defendant and a name on that passport that is not the defendant's name. + +18 THE COURT: Say that again. + +19 You found that today? + +20 21 22 MR. ROSSMILLER: We became aware of it today. It was seized in connection with a warrant, and we became aware of it just this morning, the particular details this morning. + +23 24 THE COURT: When you say "piles of cash," did you count it? + +25 MR. ROSSMILLER: No. We have not counted the cash, 1 2 your Honor. It does raise the question of how many other safes are there in how many other locations with items like these. + +3 4 5 6 The defendant also makes proposals that highlight, rather than mitigate, the dangers of granting bail. His offer to consent to extradition is unenforceable, and it highlights his extensive connections abroad. + +7 8 9 I should say, your Honor -- I forgot to mention -- the passport that I just referenced listed at the time his residence as Saudi Arabia, and this was from the 1980's. + +10 11 THE COURT: Would you describe that passport again. I'm not sure I caught it. + +12 MR. ROSSMILLER: I can, your Honor. + +13 14 15 16 17 The passport was issued in the name of a foreign country. It appears to have been issued sometime in the 1980's. It is expired currently. It has a photo that appears to be the defendant, and it has a name that is not Jeffrey Epstein. + +18 19 20 21 22 In connection with that, I also want to note that the defendant's proposal for private security is inadequate and impractical and would put the defendant in the position of having complete financial control over the people who are supposed to guard him. + +23 24 25 As this Court has written: "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 + +1 2 assure the defendant's appearance."So that's just on flight, your Honor. + +3 4 5 6 With respect to danger to the community, none of the defendant's proposals address the very significant danger this defendant proposes, both to victims and witnesses and to the proper administration of justice. + +7 8 9 10 The government has heard from more than one victim that in connection with the prior investigation, they believed they were being instructed by the defendant or his associates to avoid or lie to law enforcement. + +11 12 13 The defense said in its submission that it was without knowledge as to the basis of the incidents referenced by the government in our initial filings. + +14 15 16 17 So, as the Court saw, we submitted the underlying police reports. Those police reports are detailed, they're credible, and they're supported by corroborating evidence such as phone records. + +18 THE COURT: These are from Florida; right? + +19 20 21 MR. ROSSMILLER: That's correct, your Honor. These are very real concerns, and they cannot be mitigated if the defendant is released. + +22 23 24 25 And as the government noted in its submission and as the Court asked about, even recently the defendant has sent hundreds of thousands of dollars to two individuals just days after the publication of significant news articles about the + +2 3 THE COURT: Could you go back to those Florida police reports and tell us what you think they demonstrate. + +4 MR. ROSSMILLER: Yes, your Honor. + +5 6 7 8 9 They certainly suggest that there were individuals who believed that they were being harassed and interfered with by the defendant or his agents. That was investigators or other individuals working on behalf of or at the behest of the defendant. + +10 11 12 13 Now, those aren't charges proven in court. Those aren't convictions. But they certainly are factual occurrences that people reported contemporaneously and that are significant and concerning. + +14 15 16 17 18 19 20 With respect to just a couple of the Court's questions, bouncing around just slightly, with respect to the financial information which, again, is limited at best, the government took no position on the defendant's sealing application for, among other reasons, the fact that we did not know what they were going to submit. We imagined that it would be more detailed. + +21 22 23 24 Secondly, the government obviously had just hours to respond to the defendant's at that point. So we took no position and of course defer to the Court as to whether there is a valid reason to seal such limited and summary information. + +25 We will confer, your Honor, on whether we're able to + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +provide a sample of the search warrant materials. Those materials remain under review. They are, generally speaking, many, many, many photographs of nude and partially nude women and girls who appear to be young. + +The government has identified at least one individual in those photos who has self-identified as a victim of the defendant. And, frankly, it is a lot of material that we are continuing to work through. + +With respect to the sex offender registration of the defendant in other states, your Honor, following up on the Court's question last week, we did confer with New York state authorities. + +There is no particular result from this case in terms of his registration in New York. He remains registered, but there is no specific consequence as to him being charged or arrested in this case and no change of his status. He is already, of course, at the highest status of risk for re-offense. + +Just very briefly, your Honor, with respect to some of the other arguments that defense counsel made -- + +THE COURT: Are you familiar with whether or not there are other proceedings in other jurisdictions of a similar nature to Judge Pickholz's decision? + +MR. ROSSMILLER: We are not aware of any similar proceedings. That's not to say that there aren't any, but the + +2 3 4 5 Now, turning just very briefly to some of the legal arguments that defense counsel raised in their submission, the defendant raised legal arguments that he says he intends to argue later. + +6 7 8 9 10 The Court should have no confidence whatsoever that the defendant would stick around to pursue long-shot, dubious legal arguments at some future time. As set forth in the government's submission, the non-prosecution agreement does not preclude this prosecution. + +11 12 13 14 15 And even if that agreement were applicable to this district, which it is not, the defense itself acknowledges that the indictment included evidence beyond the initial investigation. That effectively moots this issue for the bail argument. This case will go forward. + +16 17 18 19 The defendant will lose any argument about due process. He will lose any argument about pre-indictment delay. And if he choses to be tried before a jury of his peers, we are confident he will be convicted. + +20 21 The Court should ensure he is here when that time comes by ordering his detention. + +22 THE COURT: Counsel. + +23 MR. WEINBERG: Thank you, your Honor. + +24 25 If I can, your Honor, before responding to the Court's questions, put this case in some context. + +1 2 3 4 5 Before 1984, before the Bail Reform Act, there was an Eighth Amendment that the United States Supreme Court guaranteed bail to anyone who wasn't charged with a capital offense, and the justices wrote continuously that was because detention impairs a defendant's ability to prepare a defense. + +6 7 8 9 In this case, the government has told us there's going to be an enormous amount of discovery. The stakes are grave, and one of the most important reasons for Mr. Epstein's release is to permit him the right to fully prepare a defense. + +10 11 12 13 14 15 The second reason that before 1984 there was an entitlement to bail was because of the presumption of innocence and because of the basic premise of the American criminal justice system that you don't punish first and have a trial second; that non-convicted citizens don't get detained which is essentially a label for punishment. + +16 17 18 19 20 21 22 23 There is no way to replace the freedom if Mr. Epstein is to prevail on these charges. If the government's over a decade of delay is found prejudicial by the Court which thereafter dismisses the charges, if the Court determines that the nonpros agreement was circumvented by the prosecutors in Florida when they encouraged their witnesses and their witnesses' lawyers to go to the Southern District and catalyze and create a case. That's unique. + +24 25 These were not two silos, the Southern District of Florida and the Southern District of New York. It is more than + +1 2 3 coincidental that on the Saturday before the Monday filing by Mr. Epstein in Florida in the CVRA case Mr. Epstein is arrested. + +4 5 6 7 8 9 10 11 We have evidence not only of an enormous amount of overlapping evidence, but we have evidence of the involvement of the Department of Justice; the CEOS unit, the Child Exploitation Unit, both before the nonpros agreement was executed, they were involved with the Southern District of Florida. And after, they volunteered essentially to be part of a team in the event that Mr. Epstein did not conclude his obligations under the CVRA. + +12 13 14 15 THE COURT: You mentioned in your submissions -- and I think you mentioned or your colleague mentioned the last time that we were in court -- that high-level Department of Justice officials approved the non-prosecution agreement. + +16 MR. WEINBERG: Yes, your Honor. + +17 THE COURT: Who are they? + +18 19 20 21 MR. WEINBERG: First, the agreement was executed on September 24, 2007. Appeals were taken by Mr. Epstein challenging the federal interest in what was a potential state prosecution. + +22 23 24 25 The first level was the criminal division. The head of the criminal division, Alice Fisher, assigned to Sigal Mandelker. I may be mispronouncing her name, but she is the current Undersecretary of the Treasury. + +1 2 3 She received submissions from the defense that this was essentially a local crime without the necessary interstate elements that constitute the foundation of federal prosecution. + +4 5 6 We had a meeting in Washington with a number of the defense team with representatives of the criminal division and the representatives of the CEOS, the Child Exploitation Unit. + +7 8 9 10 11 12 They recognized that their position was not squarely within the precedence that had preceded this March 2008 meeting. They recognized the arguments were novel; that some of the provisions in the NPA were novels. But they endorsed the exercise of prosecutorial discretion that was at the heart of the NPA. + +13 14 THE COURT: Was there any proceeding at which their position is documented or any correspondence? + +15 16 17 18 MR. WEINBERG: Yes, your Honor. There are submissions by the defense to the criminal division in Washington that I believe were dated in March. And then there was a response in May which in essence authorized -- + +19 THE COURT: May of what year? + +20 MR. WEINBERG: May of 2008. + +21 THE COURT: What did it say? + +22 23 24 25 MR. ROSSMILLER: It endorsed the exercise of discretion after recognizing in about a six- or seven-page letter that the facts and circumstances surrounding the NPA were unusual; that these allegations were not within the + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +heartland of federal jurisprudence or the federal statutes that were targeted for Mr. Epstein. + +THE COURT: They actually said that and then endorsed the agreement -- + +MR. WEINBERG: They said that they were unusual arguments; that they essentially understood the arguments we were making. They didn't denounce the federal case. + +They, instead, said that they believed, after a review, that there was authority and that there was a sufficient discretion that should be accorded to the U.S. Attorney. + +An appeal was then taken to the Deputy Attorney General who at the time was Mr. Filip, F-i-l-i-p. Again, I may be butchering his name. + +THE COURT: That's his last name? + +MR. ROSSMILLER: That's his last name. Mark I think is his first name. + +He assigned John Roth, who was a former Florida prosecutor and was his deputy or the deputy to the Deputy Attorney General. And Mr. Roth received further written submissions. Again, there was the second endorsement of the discretion that Mr. Acosta in Florida exercised when he approved. + +And this was not a single-man approval. The negotiations in the Southern District of Florida included the + +2 THE COURT: In New York. + +3 4 5 6 7 MR. WEINBERG: Right. In the Southern district, there were six or seven prosecutors, including New York City prosecutors, in what was either the largest or second largest U.S. Attorney's Office. I don't know how the manpower compares to the Southern District of New York. + +8 9 10 11 This was well thought through. Again, it was with consultation of the Department of Justice before September 24 and then again after where the government continued to investigate. + +12 13 THE COURT: Is Mr. Filip the highest level official in the Department of Justice? + +14 15 MR. WEINBERG: Yes. He was just one step below the Attorney General. + +16 THE COURT: He was Deputy Attorney General? + +17 MR. WEINBERG: Deputy Attorney General. + +18 19 20 21 22 23 24 25 In May or June of 2008, he approved the discretion to enter the NPA and to essentially endorse the decision and implicitly endorsed that there was some federal interest in this case because we were contesting whether or not this was a case that warranted the weight of the federal government which required Mr. Epstein to go to the state which had returned an indictment for solicitation and actually urged the state of Florida to bring a second charge that would subject Mr. Epstein + +1 2 to registration which was part of the obligations that he accepted, and no one quarrels with his performance. + +3 4 5 He went to the state. They returned the higher charge. He went to jail. He did his strict probation with home detention. And he's been registered since 2010. + +6 7 8 9 10 I think these facts are important, not just because they are the cornerstone of a potential legal defense, and I won't go through all of the different factors that we believe on a principal basis will distinguish this case from the precedence that Mr. Rossmiller is relying on. + +11 12 13 14 15 These were not two silos. The Southern District didn't stand completely detached from the activities and the events in Florida. But that's a motion to dismiss that will be brought later. The premise is if we're right and they're wrong and he's detained, he's lost freedom without punishment. + +16 17 18 Your Honor asked about the rebuttable presumption, and I think this also goes back to the events of the 2007 and 2008 era. + +19 20 21 22 THE COURT: So the presumption, first of all, the people who wrote that presumption into law clearly know about bail and history and the need for defendants to consult with their counsel, etc. + +23 24 25 But in this rather narrow class of cases, almost all of them I think relating to children or young people, there are a whole series of cases, exceptions to be sure, where the + +1 2 presumption of remand maintains. And this is one of those cases. + +3 MR. WEINBERG: Yes, your Honor. + +4 THE COURT: So why is that? + +5 6 7 8 9 10 11 12 MR. WEINBERG: Interestingly, if I can point out another provision in the Bail Reform Act, and this is 3142(c). At the very end of the set of conditions, the Congress in 1984, which was essentially revolutionizing the criteria for release, says that: "In any case that involves a minor victim under" - and they quote a series of statutes, including 1591 -- "any release order shall contain at minimum a condition of electronic monitoring, a curfew, and other conditions." + +13 14 15 16 17 18 So Congress recognized that despite the presumption, which the law says is rebuttable and is more a burden of production than an ultimate burden of persuasion issue, Congress understood that defendants charged with 1591 would be released under conditions at the discretion of the court and that if they were -- + +19 20 21 THE COURT: I think they understood that they could be released, not that they would be, otherwise, they wouldn't have written that presumption. + +22 MR. WEINBERG: Absolutely. + +23 24 25 THE COURT: So could you share any insight why, notwithstanding -- and I don't disagree with you. Bail is the norm rather than the exception. But we totaled up -- I don't + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +know if there are more -- 12 cases, all of which involve a minor victim -- kidnapping, sex trafficking of children, aggravated sexual abuse, sexual abuse, offenses resulting in death, sexual exploitation of children, selling and buying of children, the production of sexually explicit depictions of a minor for importation into the United States, crimes involving the transportation of minor victims, coercion and enticement, transport of minors, and use of interstate facilities to transmit information about a minor. + +All of those -- there may be others, but those are the ones we found -- also carried this presumption of remand instead of bail. + +MR. WEINBERG: Yes, your Honor. + +THE COURT: Presumption. + +MR. WEINBERG: Yes, your Honor. If we're looking at 1591 and I'm not here today to in any way diminish the gravity of the allegations against Mr. Epstein, but it's far away from the heartland of 1591 commercial sex trafficking that deals with servitude and deals with enslavement and deals with pimps, if I can use that word, selling women for commercial profit. + +We've provided the Court with some of the division in the law, including decisions by this Court, by Judge relying on a South Dakota opinion, by the chief justice that finds the statute inapplicable. + +2 3 4 5 MR. WEINBERG: Yes, your Honor. Again, today is not the day to be arguing Rule 29 issues or even the construction and scope of the statute. But I think lots of the detentions are for your quintessential traffickers. + +6 7 8 9 And I understand we don't have consent and, therefore, the government substitutes that language. But this is not quintessential commercial sex trafficking to third parties for profit. + +10 11 12 13 14 15 16 But more important or as important, if I can say that, the presumption is rebuttable. Even in those cases that your Honor listed, the statute contemplates that some 1591 defendants will be released under conditions, and I believe that the rebuttal to the presumption -- one is the danger prong; one is the flight prong. If I can address them separately. + +17 THE COURT: Sure. + +18 MR. WEINBERG: I apologize if I'm using the time. + +19 THE COURT: No. You have the right. + +20 MR. WEINBERG: Thank you, Judge. + +21 22 23 THE COURT: I think that is interesting. So those prongs have different burdens of proof for one thing, clear and convincing in one instance and preponderance in the other. + +24 25 It's either/or or both one could find. But if one found one of those, either a danger to the community or flight + +2 3 4 5 MR. WEINBERG: I think I have to bear the burden of rebutting the presumption as to each prong, although I think once rebutting the burden falls on the government, and then they have different substantive burdens of proof. + +6 7 8 9 10 So danger. There are two categories of the dangers that have been identified by the government. Number one is simply the danger of recidivism which is the classic danger that results in detention when detention is predicated on danger. + +11 12 13 14 15 16 And Congress was very clear that they -- because the danger prong is predictive. It is not just was he a bad guy. Did he do things in the past. That's what a trial is for. That's what legal issues are for. It's can we infer from the past that he is a future danger and can we do it by clear and convincing evidence. + +17 18 19 20 21 22 23 In terms of rebutting and the burden of production as to that part of the danger prong, 14 years, since 2005 until 2019. And the government, despite a website, despite their enormous ability to investigate -- and they've been investigating for months -- there is no allegation that Mr. Epstein, after 2005, engaged in illegal sexual activity with a minor. + +24 25 Again, I'm not diminishing the gravity of the allegations in 2005 and 2004, but once he knew that he was + +1 2 being investigated, he wasn't a predator that couldn't control his conduct. He disciplined himself. + +3 4 5 There has been no allegation since the commencement of that investigation that Mr. Epstein again endangered a minor. Putting aside consent, there is just no allegation. + +6 7 8 9 10 11 The witnesses that Mr. Rossmiller will offer to the Court in the future, at least to the extent that they've been characterized by the government, are more witnesses with a kind of a parallel group of witnesses to the 2002 and '05 allegations. So I think a 14-year gap is an eloquent rebuttal to a burden of production presumption as to danger. + +12 13 14 THE COURT: So I have a question about that too because I'm not so sure. I don't purport to know, but I'm not so sure. + +15 16 17 18 19 So in your letter to the Court -- I think it's at page 6 -- is one of a series of strong statements. This one in particular says: "Any danger that Mr. Epstein may have once posed to the community has long since abated." Another sentence used the word "evaporates," but let's say "abated." + +20 21 22 23 24 The defense submission goes on to say: "At the very least, this enormous gap in time precludes a finding," "precludes a finding by clear and convincing evidence that no conditions of release can reasonably assure the community's safety." + +25 Right? That's your position as a matter of law. You + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +don't find any case where that says 14 years, and it's over or it evaporates, etc. + +The argument though is that 14 years ought to be enough of a period of time. Right? + +MR. WEINBERG: I think the premise is that when the man was not under conditions of release, if your Honor was to exercise your power to release him, he didn't re-engage in this activity that constitutes the heart of both the Florida and the current New York prosecutions. + +And at a certain point, when you're dealing with the government's burden to prove by clear and convincing evidence going forward in the future, the idea that he would abandon his 14 years of self-discipline when he's under conditions of bail that can result in his rearrest and re-detention -- I don't think the government can carry that weight or carry that burden. + +THE COURT: So I'm very interested in this question. It's a very interesting question. As you may or probably know, there are studies of recidivism, studies of recidivism directly related to sex offenders. + +I'll share with you what I've looked at because I don't want you to think I'm researching on my own anything that you are not aware of. These are, I think, government-supported studies that measure recidivism beyond 10 or 14 or 15 years and that purport, if I read these studies, to show that the nature + +1 2 3 of recidivism is not always that, II, I'm not going to do this conduct anymore. It's more of a psychological aspect I would say. + +4 5 6 7 But they measure recidivism rates -- for example, one study that I saw -- and I'll put this up on the docket so you'll know what I was looking at -- measures recidivism at five years, at ten years, and at fifteen years. + +8 9 10 11 12 And the response, the percentage of recidivism actually goes up at 15 years. I'm not going to quote the percent. I know it, but I don't know how accurate it is, but it is substantially higher than the recidivism rate at five years, for example. + +13 14 15 So all I'm saying is I don't think it's so clear that with the passage of time, the presumption, so to speak, evaporates or disappears. + +16 17 18 19 There is other discussion in some of these studies that sex crimes are the most difficult to evaluate in relation to recidivism and a lot of other concepts because in sex crimes, victims very often don't come forward. + +20 21 22 23 24 This is not a phenomenon when we hear in this case or even in another case on the news that where was the victim then, didn't come forward. That's not an uncommon phenomenon having to do with a whole complex number of factors. So a lot of these cases are never reported. + +25 I don't know that you can just draw the conclusion + +1 2 3 that -- by the way, you're suggesting that the measure of recidivism is a reported classic case by the prosecutor, state or federal, indictment, etc., etc. + +10 MR. WEINBERG: I guess I would have two responses. + +11 THE COURT: Sure. + +12 13 14 15 16 17 MR. WEINBERG: One, that the level of publicity brought to Mr. Epstein and brought in this case and even brought before the bringing of this case, his wealth which makes him an attractive civil defendant as well as a criminal defendant -- and there have been a number of complaints or threats or notices or demands by different civil lawyers. + +18 19 20 21 22 23 24 25 But there is an unprecedented amount of publicity that would mobilize and motivate people who were victimized by him. If there were any people victimized by him after 2005, it is utterly lacking in the average case where some victim doesn't know that they've got an ear, whether it's an ear of the civil bar or an ear of the United States Attorney, to receive, positively receive, and embrace an allegation against Mr. Epstein. + +That may not even occur in most instances because a + +lot of cases that are even referred to prosecutor offices are + +never formalized or never brought. + +So I'm not sure that the passage of time, without more and without more study and with let's say discipline of a defendant -- I'm not sure that that gets us there. + +1 2 3 4 5 6 And, two, again, without getting into in any way of appreciating the gravity of these charges, the government writes on page 2 of its submission, this was not a case - again, putting the age of these witnesses and putting the consent issue aside, it's not like he's an out-of-control rapist. + +7 8 9 He doesn't fit within the paradigm of many of the sex offenders that are the subject of the research that your Honor is accessing. + +10 11 12 THE COURT: And I don't mean this personally directed because I don't have any way of knowing one way or another of Mr. Epstein, but the question is: How do you know that? + +13 MR. WEINBERG: I know that because -- + +14 15 THE COURT: You may say, he's my client, and I know he's a good fellow and all that. + +16 17 18 MR. WEINBERG: i actually do think that if he was unable to control his conduct, given the level of publicity, we'd know it. The government would know it. + +19 20 21 22 But secondly, these 15 years have not been uneventful. I think this goes also to rebut the notion that he is a flight risk. His house was searched in 2005 giving him notice that the state authorities were conducting an investigation. + +23 24 25 It was an intensive investigation. It led in 2006 to the U.S. Attorney's investigation that itself was intensive. There were grand jury subpoenas. There was an enormous amount + +2 3 4 5 He didn't flee. This was all before the NPA while he was facing the very same 1591 and even additional statutes that carried additional potential federal penalties, interstate travel, interstate communications. + +6 7 8 Again, we have to infer from the past what the future conduct would be. I think it's important that he hired lawyers to defend him. He didn't run away. + +9 10 11 12 13 Despite the fact there was no bail, no conditions, he didn't have the publicity he has now, he could have, if he was a fleer, left at that time and done what the government fears he would do today if released under an enormous set of conditions that I will ask to supplement. + +14 15 16 17 Two is the next period was the NPA period. Again, he signed up to go to state jail, county jail. He went to county jail. He got out in 2010. He was subject to the registrations. + +18 19 20 21 And if I can go back in to try and answer your Honor's questions on registration. He has not reapplied challenging the New York Appellate Division or the New York Supreme Court decision. + +22 23 24 25 There was a legal dispute. Mr. Epstein's counsel at the time believed that the classification in New York should be restricted to the offense of conviction. And the Court determined that it would rely instead on an affidavit that it + +1 2 had presented in the state of Florida that talked about other allegations leading to the tier three classification. + +3 New Mexico, as I understand it -- + +4 5 6 7 8 9 10 THE COURT: Before you get to New Mexico, the court, as I read -- and I did this morning. So it's fresh in my mind -- Judge Pickholz -- she relied on the state administrative body that imposed, so to speak, or who in the first instance said that a level 3 was the appropriate level, after considering the series of factors which are reflected in this transcript. + +11 12 13 14 You know, judges often do just that. She says in this transcript that she's had many of these cases. They're called SORA hearings. I must say it's -- I don't know what the word is I'm looking for, but you'll read it yourself. + +15 16 17 18 19 20 21 She was taken aback I have to say, really taken aback, Judge Pickholz was, that this application was being presented to her. She says things like, I have never even the prosecutor's office do this. So the prosecutor joined in with defense counsel. I think Kirkland & Ellis and the ADA from Vance's office joined together, and they both argued for lowering the offense level from a 3 to a 1. + +22 23 24 25 She says a few things like that which are pretty unusual for a judge to say, in effect -- first of all, she said the board made a recommendation. And second, she seemed to be suggesting that this was unique. + +1 2 3 4 5 The prosecutor, the DA's office, and the defense joining together in making such an application is very unusual I think is what she said. And then on appeal, I think it was affirmed 5 to 0 actually. They sit on panels of five. So I was surprised. + +6 7 8 9 10 11 12 13 MR. WEINBERG: It was, to my recollection, a legal issue about whether or not the premise for a classification decision should be the offense of conviction which would have been consistent with a tier 1 or the overall investigation as reflected by a probable cause affidavit that ultimately six judges, the five on the appellate division and one on the Supreme Court, believed was the appropriate barometer of sex offender registration. + +14 15 16 17 What's important is that Mr. Epstein has complied with the registration imperatives of each state of his residence. He's got the unusual circumstance of having multiple residences. + +18 19 20 21 22 23 His principal residence is the Virgin Islands which has him at a tier 1 or the lowest level of classification. New Mexico he tried to register, and my understanding is that they said that his nexus to the state did not require further registration because his travels, his daily occurrences, were being monitored by his principal residences. + +24 25 THE COURT: That goes back to the question I have, but before I get there, we've gone far along. Normally by this + +1 2 3 4 5 time I would have said -- and I will say it now -- as you pointed out, what I said the other day at our conference is that when we get to the bail issue, we're going to have conversations and discussions that sound like merits discussions, and they aren't. + +6 7 8 9 And I very much agree with you that the presumption of innocence everybody has to bear in mind, although sometimes it's a little difficult when we have these conversations to separate them out. + +10 11 12 13 14 It's just fundamental that Mr. Epstein is presumed to be innocent now and until such time, if it comes, that a jury or a court makes a determination of guilt. So we always have to remind ourselves of that, even though we're having these conversations that seem to touch on merits discussions. + +15 16 17 18 19 Back to Judge Pickholz, she says, among other things, but the board found a level 3. Then she goes on to say: "I have to tell you, I'm a little overwhelmed because I have never seen the prosecutor's office do anything like this. I have never seen it." + +20 21 22 23 24 So I read it today. It came up, and I thought I'd share it with all of you. She's suggesting, although you're making plausible legal arguments, that there is really no basis, at least in her opinion, to reduce the level from level 3 to level 1. + +25 What is the practical difference between a 3 and a 1 + +1 2 in terms of the registrant's obligations to appear or submit reports or whatever? + +3 4 5 MR. WEINBERG: I don't think I can reliably respond except to say that there was some discussion about whether or not he was required to physically appear in New York. + +6 7 8 9 And my understanding from the lawyers with personal knowledge is he was told that unless he was here nine or more days a month, he was not required to conform to the physical 90-day appearance, despite being a tier 3. + +10 THE COURT: He wouldn't have to come. + +11 12 13 MR. WEINBERG: Right. Nobody has ever given him or noticed a violation in almost ten years of daily monitoring. He's not someone that just stays at one location. + +14 15 16 17 18 19 I've got a stack from one of his lawyers that I won't burden the Court with about putting on record with the Virgin Islands, which is the principal monitor of his travels every day, what is the transportation, where is he going to be. I see letters saying, we're delayed one day. We'll be coming into Palm Beach on a certain day. + +20 21 22 23 The point being, I think, two: One, there's been no violation in nine years; that he's being carefully monitored. He himself is extraordinarily careful not to trigger a federal SORA or a state SORNA violation, and he hasn't. + +24 25 Two, I think that speaks to his ability to be disciplined, his ability to regulate his conduct consistent + +1 2 with the mandates, whether it's an administrative agency or a court's bail release order. + +3 4 5 Three, I know of no other proceedings, in answer to the question your Honor asked -- I think it was question two like the proceedings in New York. + +6 7 8 9 10 I will verify that with the counsel in the different jurisdictions who can provide primary rather than secondary or hearsay evidence so we can give you in an additional submission some meaningful and particularized responses to your Honor's questions of this morning. + +11 THE COURT: That would be helpful. + +12 13 14 There are two things. One is another disclosure on my part. I did happen to read in the New York Post a story about the New York state sex offender registration. + +15 16 17 The thrust of that story was that Mr. Epstein or at least it appeared to me to be the thrust -- was not in compliance with his obligations in New York. + +18 19 Again, it's a newspaper story. I did see it. I share it with you. You probably saw it too. + +20 21 22 MR. WEINBERG: I think I did. I think that's where I checked with counsel, and that's where I learned of this nine-day rule which I was not familiar with before checking. + +23 24 25 But what I can say is nobody on the New York side has ever informed Mr. Epstein, despite the now ten-day deluge of publicity, that he has ever been in violation. + +1 2 3 4 5 6 There has been no notice to his New York counsel. And he has done everything in his power to meticulously conform to these multiple registrations and inform, through the Virgin Islands, of travel whether it's to Paris, whether it's to Florida, whether it's to New York. I don't think there is a complaint in nine years that he has been in violation. + +7 8 9 THE COURT: So is the point or one point that if he is not here for ten consecutive days or more, he does not have to report? + +10 11 12 13 MR. WEINBERG: Again, I don't want my credibility resting on what I haven't personally verified. I am told that that is the criteria for physical appearance, whether that's correct or not. + +14 15 16 i can tell you that from talking to counsel, there has been no notice that he should appear and no notice that he's been in violation, despite the recent media. + +17 18 19 20 THE COURT: When you put together the supplemental submission particularly about New Mexico, it was hard for me to imagine, would New Mexico reach out to someone and say, II, you don't have to register here? + +21 22 Or was there some form of application to be exempt or excused? I don't know for sure. + +23 24 25 MR. WEINBERG: My best knowledge is that registration kicks in when your criminal justice sentence ends. Therefore, as soon as he was within weeks or months of ending the Florida + +1 2 3 probation or community control part of the Florida state sentence, he tasked lawyers to go to these different registration boards in the states where he had residence. + +4 5 6 7 8 It was complicated because of the multiple residences. And the ultimate decision in New Mexico -- and I can't tell you whether there was a period where he did register, but I can tell you that at a point in time very close to the beginning, New Mexico said, you don't need to register. + +9 10 11 I know he made an effort to register because the concern was that the federal registration statute requires that you contact the states where you reside. + +12 13 14 It was complicated because of the multiple residences, and the last thing he wanted to do was to create a new offense through an omission of the obligations under the federal SORNA. + +15 16 17 18 19 So he went to New Mexico. And I will particularize the names of the people and the names of the lawyers, but he is not required to register. New Mexico knows he's there because the Virgin Islands tells the different places where he travels that he's coming. He's under close supervision. + +20 THE COURT: I got it. + +21 22 23 24 I think I sort of assumed something like that, that counsel in different jurisdictions would have had a meeting or filed an application or a letter or something or rather causing the administrative agency to respond. + +25 This is really now stretching my recollection. I + +1 2 3 thought I read in all of these papers somewhere that New Mexico was examining its decision that he needn't be registered in that state. + +4 5 MR. WEINBERG: It may be. And if they advise that he is to register -- + +6 THE COURT: He would I'm sure. + +7 8 9 MR. WEINBERG: -- it is just an incremental additional registration obligation because he's under so many in Florida, New York, and the Virgin Islands. + +10 11 The so other part of danger -- and I apologize. I will get to flight -- + +12 THE COURT: No apology needed. + +13 14 15 16 MR. WEINBERG: -- is the government allegation that as a result of the incident reports in Palm Beach dating back to 2006 that Mr. Epstein is a danger to others and should be detained. + +17 18 19 20 21 What I would respond to that is that the report -- and I showed Mr. Rossmiller a slightly better, unredacted version of page 86 of an incident report of Detective Recarey from the Palm Beach Police -- reflected that the date of the complaints by the parents was May 22 or May 23, 2008. + +22 23 24 25 It was the week that Mr. Epstein had hired new counsel there which was a Mr. Jack Goldberger from West Palm Beach. And Mr. Goldberger was scheduled, according to the incident report, to meet with the representatives of the State + +1 2 Attorney's Office. So Lanna Belohlavek who was the head of the sex offender unit of Mr. Kirshner's state attorney's office. + +3 4 5 Mr. Goldberger -- again, this is hearsay, and Mr. Goldberger can attest to it, if it's necessary -- was never asked about this alleged incident. + +6 7 8 9 10 11 The investigators, certainly not authorized by Mr. Epstein, to go and drive people off the road. There is simply no proof that he authorized it or until discovery knew it. There was no charge against an investigator which I contend there would be, given the intensity of this investigation in Florida. + +12 13 14 15 16 I can't explain what the facts are. i see the report. I see the claim. But if the state attorney believed that a representative of Mr. Epstein drove a parent off the road, I don't think that would be missing in the negotiations between his new counsel. + +17 18 19 20 21 22 Then Mr. Goldberger was joined by Roy Black, a Miami attorney who I know well. Mr. Black has never been asked about it or told about it and does not know the investigator. Mr. Goldberger doesn't know the investigator. I have no other explanation, other than it doesn't rise to clear and convincing evidence. + +23 24 25 In terms of the wires that the government -- I think that the government's language on page 11 of their submission, your Honor, is most telling in terms of whether these wires + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +THE COURT: The \$250,000 and the \$100,000? + +MR. WEINBERG: Yes, your Honor. + +The government says -- and I think they're being candid in their language in the last sentence on page 11 - that "Given the timing, it suggests" -- and I underline that word -- "the defendant was attempting to further influence coconspirators who might provide information." + +So the government -- and I think they've been candid today -- has not confirmed the witness testimony through corroboration, through any other corroborative mechanism whether this was an act of generosity or an act that somehow was connected to what the government suggests might have been a motive. + +But this occurring when there was no pending judicial proceeding and no knowledge of a pending investigation doesn't rise to the level of a federal obstruction which requires the pendency or the foreseeability of a federal investigation under the Supreme Court's decision in Aguilar, A-g-u-i-l-a-r, a judge in California. + +We just contend that even when you look backwards to whether this constitutes an obstruction, the payment of an employee or the payment of a friend is simply not witness tampering because the Miami Herald ran an article. + +It simply doesn't rise to the level of a past crime + +1 2 3 4 5 6 7 that your Honor has clear and convincing proof occurred, much less the predictive factor that if Mr. Epstein was released under the kind of combination of conditions, there would be any risk of his influencing adversely a witness, now that there is a federal prosecution. That would be self-destructive. It would constitute a crime with a nexus to what the statutes require. + +8 9 10 11 But the conditions also, your Honor, radically limit -- we've asked your Honor for home detention, and I will get to the monetary conditions and the risk of flight in a moment. + +12 13 14 15 We've asked for home detention. We've asked for the visiting list to be approved by pretrial, meaning almost nobody except Mr. Weingarten and myself, Mr. Fernich, lawyers on our defense team. + +16 17 18 19 20 We would rip out the cell phones. There is one line. We consent to the monitoring of that line. We consent to the waiver of search and seizure. These are the conditions that have been accepted and, again, not always, Judge. There are detention orders. + +21 22 23 24 I'm a Boston lawyer. I remember arguing before the Former Chief Judge Mark on behalf of a defendant who was arrested about two months after an induction ceremony for organized crime about 20 years ago. + +25 And Judge found that along with financial + +1 2 3 4 5 6 conditions, along with monetary conditions, the combination of home detention, monitoring, video cameras, a visiting list approved by pretrial, a waiver of search and seizure were more than sufficient to abate any danger, either of obstruction or of underlying criminal behavior in a case called, U.S. v. Patriarca. + +7 THE COURT: That reminds me of another question. + +8 9 10 Do you think that bail conditions equally apply to risk of flight and/or danger to the community? It strikes me that they're different kind of concepts. + +11 12 13 14 15 MR. WEINBERG: I think your Honor is completely correct. There is an overlap. I think the danger to the community is abated more by a lesser list of conditions that I don't even think the government would quarrel with, were they not seeking detention. + +16 17 18 19 20 21 22 We could work with the United States Attorney and agree to conditions that would essentially eliminate danger because he'd have no way to communicate, so long as the government trusted that the lawyers who were visiting him were not going to go and engage in license threatening misbehavior which I assure you that Mr. Weingarten, myself, and Mr. Fernich are not. + +23 24 25 The conditions for flight, if I can turn to flight, I contend deal directly with some of your Honor's questions about the monetary conditions and some of the government's objections + +2 So let me be as clear as I can. + +3 4 5 6 7 THE COURT: You might as well know what I'm thinking. So respectfully, I don't think that the financial summary tells me anything really. For one thing, it's some unverified list of assets, not audited, not certified, and not very detailed either. + +8 9 10 11 12 Mr. Epstein may be unusual, but there are no obligations, for example, no debts, no expenses. That, depending on if that's true -- maybe he's debt free and obligation free. But that would impact whatever the list of assets were if that were known too. + +13 14 It seems to me you have to know a -- there needs to be a fuller financial picture to know what would be appropriate. + +15 16 17 18 19 MR. WEINBERG: Let me be blunt. It was our first effort, and I am authorized to say to the Court that whatever bond you want Mr. Epstein to sign, whether it's \$100 million or an amount close to the amount of the assets that we have provided, Mr. Epstein is prepared to sign it. + +20 21 22 23 24 25 He intends to appear. Once he appears, the prejudice of a large bond is extinguished. He's met its conditions. The same with collateral. Whatever collateral your Honor believes would disincentivize him -- again, it's a temporary lien on property that would be extinguished upon his appearance in court, and he fully intends to appear. + +1 2 3 4 5 6 Whereas, in our bail submissions -- and they were admittedly rushed -- we did what we could amongst defense counsel. We want the Court to know that whatever monetary conditions, Judge, you believe are necessary and appropriate to meet the imperatives of the Bail Reform Act, which is to reasonably assure his appearance. + +7 8 9 10 11 12 And I would go farther, to virtually guarantee his appearance, in combination with the home detention and monitoring and limitation of communications he would accept. He would sign any bond, and he would give your Honor and the United States District Court clerk whatever collateral the Court ordered. + +13 14 15 16 17 Likewise, were your Honor to consider monetary conditions, we would provide a more particularized list believing that monitoring his accounts and making sure that they didn't fall beneath the level of the personal recognizance bail would be appropriate. + +18 19 20 Again, I think to some extent, I'm backing into the answer to question three which is the sealing question and whether the financial information should be public. + +21 22 23 24 I think if your Honor is to grant bail that includes the monetary conditions, then this becomes a judicial document that is at the heart of a bail release order, and the public is entitled to it. + +25 I think if your Honor is to determine that release is 1 2 3 4 5 not appropriate, despite all of the conditions that we argue provide a compelling basis for both safety and appearance, that I don't think the financial conditions information should be other than confidential because it wasn't at the heart of the judicial ruling that the public would want to understand. + +6 7 THE COURT: I'm not sure I understand why it comes in sort of heads, I win/tails you lose. Or no? + +8 9 10 11 If it's a public interest and no harm in releasing it and if you were to get bail you would happily release it. But if you didn't, you wouldn't, I don't really get why it wouldn't just be disclosable in either case. + +12 13 14 15 MR. WEINBERG: It's two reasons really. One is that the financial information, if provided to pretrial, is confidential and to be used by the Court for bail determinations. Two is there is an enormous public interest -- + +16 17 THE COURT: That's true even if I determined that there should be bail. + +18 19 20 21 22 MR. WEINBERG: Yes, your Honor. But I do think, as much as I'm not urging the Court to disclose it, I think there are overriding considerations that if your Honor were to release a man on bail, the public has a right to know the your bail conditions -- how they correlate to a man's wealth. + +23 24 25 If a man has a billion dollars -- and he doesn't. If your Honor were to set a \$20 million bail, that's an enormous bail for someone with \$21 million but not an enormous bail for + +2 3 4 I think in the First Amendment common law it would be a judicial document of importance to explain a judicial decision. + +5 6 7 8 9 10 However, there are countervailing weights, not only the bail, the pretrial statute and its confidentiality but also that we are facing a trial some day. And I know it's early, but there's an enormous amount of publicity, and every fact that is generated by this proceeding becomes the bases of an enormous amount of articles. + +11 12 13 14 15 It's one thing to say Mr. Epstein is wealthy. That's a kind of generic. It's another thing to be chasing down values and accounts. And for that reason, we ask the Court not to publish it unless it's a predicate for your Honor's release decision. + +16 17 18 19 20 And, similarly, if the government is to give you a sample of the seizures, we would make the same request, that this may be evidence some day and that it's the kind of evidence that would burden his future right to a fair and impartial jury in the Manhattan venue. + +21 22 23 24 Judge, unless there are other questions, I would just conclude by saying that in my many years at the bar, I've read many detention requests and I've heard many detention arguments. + +25 Mr. Rossmiller writes eloquently and speaks + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +eloquently. I've heard the government in different venues, including this one, talk about extraordinary risks of flight and extraordinary danger and to diminish the persuasiveness of the set of combination of conditions. + +Madoff was released on bail. He surrendered. Dryer called the colossal fraud by Judge Rakoff -- he surrendered and went to jail. Mr. Skilling from the Enron fame went to jail for 24 years. + +I recently had a case with Judge Furman where the government was arguing for detention that were associated with somebody in a different country. And he granted bail over detention, and those defendants came to court and were sentenced and went to jail. + +I'm sure there are examples that the government here can point to that certain people that can't comply with conditions. But an enormous amount of people facing detention requests honor their obligations, particularly when conditions are set such as the conditions that Mr. Weingarten, Mr. Fernich, and I have just mentioned to the Court. + +THE COURT: Of the cases you just mentioned, were any of them presumption cases like this one? + +MR. WEINBERG: I can't say they are, your Honor, but I do believe that presumption becomes just a factor when the burden of production is negated by in this case the 14 years of non danger to the community and the danger prong and by + +1 2 3 Mr. Epstein's compliance and not fleeing an almost elaboratory setting where in 2004, 2005, 2006, and 2007, Mr. Epstein was facing the same vigorous U.S. attorneys. + +4 5 6 7 It wasn't until the negotiations that he knew that they were open to a negotiated resolution. But until then, he was facing the same power of a very large, very resourced United States Attorney's Office. + +8 9 I did want to address the last point which is the private security point, your Honor. + +10 THE COURT: Sure. + +11 12 13 14 15 16 MR. WEINBERG: I'm familiar with your Honor's decision. I've read it several times regarding the citizen of Turkey and Iran and Macedonia that had foreign passports and no ties to the United States except he was arrested while visiting Disneyland, who lied to pretrial about his background which Mr. Epstein did not. + +17 18 19 20 21 22 23 24 He's not that man. Before we even get to the issue of whether or not your Honor would reconsider your strongly felt feelings about whether or not the additional condition, on top of all of the other conditions of money and home detention, the additional conditions -- I could frame it as a trustee, which is somebody that the U.S. Attorney would respect, be credible, living at Mr. Epstein's home, and making sure that there were no violations. + +25 I know the government would say that's like a + +2 THE COURT: I was going to ask about that. + +3 4 5 6 So there is a suggestion in the bail package that two trustees would be living with him. I have not experienced anything like that before, either in reality or in an application. + +7 8 9 10 Mr. Weingarten reminds me that a representative of the company that has been approved by other courts for the security prong is here and could speak to that condition, whether it's a trustee condition or whether it's a private guard condition. + +11 12 13 14 But I did want to make one point about the law because I know your Honor knows the law better than I. Judge Bianco and your Honor and maybe several other judges are on one side of a debate. Judge Rakoff and maybe other judges on another. + +15 16 17 18 19 I read carefully the Second Circuit decisions. There are three of them. The most recent one actually is the decision where the court says that a private guard in that case is appropriate because he wouldn't be a flight risk but for his wealth. + +20 21 22 23 24 So there isn't this kind of invidious discrimination between somebody who is poor and someone who is wealthy because if a person is poor, even someone in Mr. Epstein's position, the government would not be making the same kind of flight arguments that are predicated upon his wealth. + +25 So they uphold the private guard saying it doesn't + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +reach the decision some day the Second Circuit may have to address about whether or not a wealthy person should be denied release because the private guard condition somehow is more like detention than release. + +We need him released, Judge. This is an enormously challenging case for his defense counsel. The government is hugely resourced. They've got over a million pages of discovery. + +He's in the SHU unit. It's not a condition that somebody can defend themself. And Mr. Epstein's goal, like it was before, is to hire counsel to defend him and to work with counsel closely to exercise his presumption of innocence, to defend himself in a principled way in a courtroom, and not to flee. And I would urgently ask your Honor to consider our bail application. + +THE COURT: I will. + +MR. WEINBERG: Thank you, Judge. + +THE COURT: I will consider and reconsider. + +On that point, I noticed that was the last paragraph I think in your letter -- I'll examine that again too -- here is my reaction. I don't know if this is legally sustainable or not. I will look at the cases. + +You have all these people or have had on Rikers Island who can't make a thousand dollars bail, for example, and they have every right to consult with their lawyer, perhaps even + +1 2 more so than someone who is educated and privileged, and they might need it more. + +3 4 5 6 7 I think everybody has the same right, but it's very hard. If the test is consult with counsel, well, then all this other conversation we've been having is out the window because everybody has a right to consult with counsel, and we have to come up with a new set of cases and a new set of tests. + +8 9 10 11 12 13 14 By the way, don't think I don't appreciate that a defendant should be counseled and should be able to consult with counsel. But if that's the standard, then what are we going to tell all those people who can't make a \$500 or \$1,000 bail who say, I want to talk to my lawyer because the immigration authorities are going to come and take my wife away, etc., etc., separate the kids. + +15 MR. WEINBERG: I have three answers to that too. + +16 THE COURT: I'd like them. + +17 18 19 20 21 MR. WEINBERG: That's an important question. The first is that the defendants in Rikers Island, or at least the vast majority of them, are not facing a prosecution team as well resourced and as talented as this one. They're not facing a million pages of discovery. There may be exceptions. + +22 23 24 25 THE COURT: They might be facing a lot more serious consequences in terms of jail or incarceration for let's say assault or murder or rape or whatever, and many of them do face those consequences. + +1 2 3 4 MR. WEINBERG: I do understand, but it's the complexity and the magnitude of the pretrial preparation, not just the sentencing consequences that requires us to put that issue before the Court. + +5 6 7 8 9 Second, I'm not here to say there should be those kind of monetary conditions. I know, at least in my state, the Commonwealth of Massachusetts, there's a movement that I read regularly about in the Boston Globe -- maybe it's similar here -- to stop that state practice. + +10 THE COURT: It is. + +11 12 13 14 15 16 MR. WEINBERG: Third, the Bail Reform Act, the federal Bail Reform Act of 1984, has a provision saying that a defendant should not be denied release based on their inability to satisfy a monetary condition. So I think to some extent Congress disapproves of locking someone up because there's a \$500 bail that they can't make. + +17 18 19 20 21 22 I'm 73 years old. I grew up in the Court where life was different, and the criminal justice system got politicized to some extent. I think there is almost the reaction to the excess, the overcriminalization, the overimprisonment that characterized the 1980's and the war on crime and the war on drugs. + +23 24 25 So I at least stand here, as someone with over 45 years of observation, and believe and hope that one of the areas that we begin to reverse the excess is in keeping so many + +1 2 presumed innocent people in jail, whether it's Rikers Island or the MCC. + +3 4 I again passionately urge your Honor to consider Mr. Epstein's release. Thank you so much for the time, Judge. + +5 THE COURT: Thank you. + +6 Anybody else? Did you want to comment? + +7 8 MR. ROSSMILLER: If we could just briefly respond, your Honor. + +9 10 11 THE COURT: Also I know if there are going to be any more submissions in response to today, can you do them by noon tomorrow? Is that reasonable? + +12 13 14 15 16 MR. WEINBERG: 5:00 would be easier, given my travel obligations, Judge. And I do want to meet the government's reference today to a 1982 passport when he was 28 years old that expired over 30 years ago. I'd rather address that when I have some more time. + +17 THE COURT: 5:00. + +18 19 What about you, Mr. Rossmiller? Are you going to respond? + +20 21 22 23 I don't know if there are open issues, but there are some instances where you're entitled to rest on the record, but the search of the East 71st mansion, there might be some evidence from that. + +24 25 MR. ROSSMILLER: Your Honor, I can tell you certainly we'd be prepared to file anything additional by tomorrow at + +2 THE COURT: Fair enough. + +3 4 MR. ROSSMILLER: I can't say whether we will, but we'll certainly re-examine the record. + +5 6 7 THE COURT: So you'll look at the record, so to speak, and what we discussed here today and see where there could be some more strength in terms of evidence. + +8 MR. ROSSMILLER: Yes, your Honor. + +9 10 Just very briefly to respond, and I'll try to go sort of lightning round through some of these. + +11 12 13 14 Starting at the very beginning with this issue of being able to prepare a case having access to counsel, the idea that detention impairs the ability to prepare a defense -- this is certainly a challenging case. It's a significant case. + +15 16 17 18 19 20 This Court has significant experience with precisely that type of case with a detained defendant in Zarrab. In that case, I think the Court saw -- and the country and the world saw -- that it is eminently possible for a defendant to have excellent, excellent counsel and every opportunity to consult with that counsel while detained and while detained here. + +21 22 23 24 I'm not specifically familiar with the conditions of Mr. Zarrab's detention, but my general understanding is that there were concessions made with respect to his ability to review documents and have space. + +25 Those are certainly factors that we're willing to be + +1 2 in touch with the defense about. But there is a proven, existing example for how that works and how that works well. + +3 4 5 6 7 8 9 What the defendant is asking for here is for special treatment to build his own jail, to have his own private jail that he gets to stay in away from everybody else who is in jail and have him be limited in his own gilded cage surrounded by people with guns, surrounded by trustees with cameras on all sides of his house. A person who needs those conditions should be detained. + +10 11 12 13 Second, the issue of whether the case was brought to us, whether this was funneled to the Southern District of New York from anywhere else, your Honor, it was not. It was not brought to us by anyone else. + +14 15 16 17 18 19 We opened the case. We investigated the case. By "we," I mean the FBI, CBP, the NYPD, and of course the U.S. Attorney's Office. We opened the case. We investigated the case. And I can tell you that not one of the prosecutors sitting at this table has spoken with anyone at the Southern District of Florida. + +20 21 22 23 24 The issue of the Department of Justice appeal by the defendant is a distraction from the bail determination, your Honor. The chain of events that defense counsel describes makes clear that the Department of Justice did not have a role in negotiating the NPA. + +25 It didn't have any role in confirming if other + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +districts were aware of it, which there is no evidence that they were. The approval of jurisdiction to charges and a federal NPA, as the defendant of this agreement after it had been signed, contemplate federal tried to wiggle out is different from having the NPA apply outside of the Southern District of Florida which it does not. + +What they're describing is a normal appeal process, and there is an entirely separate process for getting coverage outside of the relevant district, and what they're describing ain't it. It didn't happen here. + +Your Honor, the defense has kept coming back to this idea of 1591 being enslavement, of pimping people out, of people servicing individuals 15 to 20 times a day as they mentioned in one of its submissions. Quintessential sex trafficking is sex trafficking that is met by the elements of the crime which we have here. + +The defense said we don't have consent here or putting the issue of consent aside. Your Honor, it's underage girls. It's underage girls that are involved in this case, and it's underage girls who are the victims. To say that consent is some sort of a separate issue that we should ignore is offensive, frankly, and it's not supported by the law. + +Moving along, with respect to compliance following a prior conviction rebutting the presumption, it's easy to figure out why that's not the case, your Honor. I'll explain why. + +1 2 3 4 Here's how we know that it's not the case that someone who doesn't commit a crime for 15 years, if that is the case here, but for someone who has not been convicted of a crime for 15 years, that that establishes the rebuttal of presumption. + +5 6 7 8 The reason we know that's not the case is because someone who is 70 years old who is arrested for the very first time who's lived a law-abiding life for 70 years is still subject to the presumption. + +9 10 11 12 So the idea that if you're convicted of a crime and then you're not convicted of a crime for a while, that that itself rebuts the presumption, really turns the presumption on its head. That simply doesn't make any sense, your Honor. + +13 14 15 With respect to the idea that it's old conduct which is related, the statute of limitations goes very far back. And in fact, there is no explanation for this type of crime. + +16 17 18 19 20 Congress has decided that if you commit sex crimes against children, you will have to look over your shoulder for the rest of your life. And that's as it should be, your Honor. Certainly there is no argument here from the defense regarding the statute of limitations. + +21 22 23 24 The defense has argued a couple different times about a couple different things that if there was a crime, it would have been charged. So in discussions of obstruction, in discussions of witness tampering. + +25 Your Honor, the idea that if there was misconduct it + +2 3 There are plumes of smoke as to those particular issues, and the Court can reasonably infer that there is fire. + +4 5 6 7 8 The idea that Mr. Epstein was feeling particularly generous to his old friends and associates days after the Miami Herald published a series of articles about his misconduct and the circumstances leading to his non-prosecution agreement is not credible, and the Court shouldn't find it to be credible. + +9 10 11 12 13 Finally and most importantly, this idea that the defendant has disciplined himself, the defendant is asking the Court to risk the safety of the community on the self-discipline of a man they appear to concede has a preference for underaged girls. + +14 15 16 17 This idea that he has disciplined himself is a concession that the defendant has a problem, that he has an appetite for children. Your Honor, the defendant keeps telling on himself here. + +18 19 20 21 They concede that the government will be able to show the elements of the crime. They concede that he has to discipline himself to avoid committing the types of crimes he has before. + +22 23 24 25 They say that he didn't flee because he thought that there was the potential he would be -- I'm sorry. They say he didn't flee despite the fact that he thought there was a potential to be charged. + +1 2 3 That's not consistent with the explanation that he had no idea that there was a federal case that would be brought when he made the payments to his old associates. + +4 5 6 7 The fact is, your Honor, the defendant thought he'd gotten away with it. And the government really put its money where its mouth is on this issue of notice and of the covert nature of the investigation. + +8 9 10 11 This investigation was going on for months, and the government took extraordinary efforts not to have the defendant find out about it, and he didn't. And neither did anyone else until the case was unsealed. + +12 13 14 15 Any number of people in this court who would have loved to have reported the fact of this investigation, and it didn't get out because the government was concerned that the defendant would flee as we continue to be now. + +16 17 18 Your Honor, this is the Southern District. The defendant is indicted. He is in a grave position, and he has every motive and every means to flee if he's released. + +19 THE COURT: I have one question of you. + +20 21 22 23 24 In your submission -- I think it was in your most recent submission -- you mentioned that you had been contacted by victims or their counsel probably or perhaps and that they were of the view that there should not be any bail, any release. + +25 Are you aware if any of them wish to be heard? + +2 MR. BOIES: Yes, your Honor. + +3 4 THE COURT: Hold on one second. Mr. Boies, just wait until we finish with them. + +5 I take it that the answer is yes? + +6 MR. BOIES: Yes, your Honor. + +7 THE COURT: Go ahead. + +8 9 10 11 MR. ROSSMILLER: Your Honor, my understanding, including from representatives of the Boies, Schiller law firm, is that victims have expressed the views that we conveyed to the Court. + +12 13 14 I was not aware of any victims or victims' counsel who wished to be heard today, though we have made efforts to reach out to a variety of victims and counsel. + +15 16 17 THE COURT: That's fine. I'm just asking you, and Mr. Boies wishes to be heard on behalf of them. I think that's perfectly fine. I think it's just fine. + +18 MR. ROSSMILLER: Understood, your Honor. + +19 20 THE COURT: Counsel, did you want to get the last word? + +21 MR. WEINBERG: Just two brief matters. + +22 THE COURT: Okay. + +23 24 25 MR. WEINBERG: First, the government has been repeatedly saying that Mr. Epstein concedes the elements or the evidence. That's simply not so. He's going to defend this + +2 3 4 5 Second, there's an inherent contradiction between the government's tying these two payments by Mr. Epstein in November and early December of 2018 to witnesses as if these are akin to an attempt to influence a witness. + +6 7 8 9 If the government's position has any reality to it, that Mr. Epstein reads an article and perceives that a friend may be a witness, then that provides pretty strong evidence that Mr. Epstein was concerned about an investigation. + +10 11 12 13 14 15 16 Even if the government kept it secret and yet he repeatedly flew not just out of the country but into the country with the knowledge, with the belief, again, if the government can tie these payments to an understanding, an intent to effect a future investigation, that provides fairly eloquent evidence, your Honor, that Mr. Epstein does not intend to flee. + +17 18 19 And his conduct between November and December 3, 2018, and the present is the antithesis of a defendant who wants to flee. He was arrested flying into Teterboro from Europe. + +20 21 22 23 24 Lastly, Mr. Jaffe is here, your Honor. If your Honor in any way wanted him to inform the Court what services he and his company can provide to better or to be one of the multiple conditions that we've offered the Court as a condition of release, he is here. + +25 THE COURT: I could ask you through him or him + +2 MR. WEINBERG: I'd rather you ask him, your Honor. + +3 Thank you. + +4 THE COURT: Then we'll get to Mr. Boies. + +5 6 7 By the way, before we do, does everybody here except me know who the two people are who got the \$250,000 and \$100,000 checks? + +8 9 MR. ROSSMILLER: Your Honor, we've advised defense counsel who those individuals were. Yes. + +10 THE COURT: Can you tell us. + +11 12 MR. ROSSMILLER: We're not prepared to make that statement currently, your Honor. + +13 14 15 MR. WEINBERG: Generically, your Honor, they're long-time friends and employees of Mr. Epstein. One is a friend. One is an employee. + +16 THE COURT: Okay. The only question I really have + +17 18 MR. ROSSMILLER: I'm sorry, your Honor. I apologize for interrupting. + +19 20 21 22 I should say the government is more than happy to advise the Court of that information in a sealed submission. I just don't want to reveal the names of potential witnesses and frankly potential victims in open court at this time. + +23 24 THE COURT: So you know them, and the defense knows them as well. + +25 MR. ROSSMILLER: We're happy for the Court to know + +1 2 them, but that's not something that we're prepared to file publicly. + +3 4 THE COURT: Is that okay with you if he submits something? + +5 MR. WEINBERG: Yes, your Honor. + +6 7 THE COURT: So the only question I have of you is these trustees or guards -- are they armed? + +8 9 10 MR. JAFFE: They will either be armed or unarmed as the U.S. Attorney and defense counsel agree, and we will follow that order, your Honor. + +11 THE COURT: Got it. + +12 Mr. Boies, you're going to get the last word here. + +13 14 15 MR. BOIES: May it please the Court, your Honor. I'll be very brief, and i apologize. I wasn't planning to speak today. + +16 17 18 19 But there was one thing that I wanted to clarify for the Court that came up, and I would like one of the victims that I represent who is here in court to be able to just speak to you for 60 seconds. + +20 THE COURT: Sure. + +21 22 23 24 MR. BOIES: The matter that I wanted to clarify is that counsel for the defendant indicated that there was no proceeding pending at the time that the payments of \$250,000 and \$100,000 were made. + +25 It's true that there was no federal criminal + +1 2 3 4 5 6 7 proceeding against him pending, but we had a case pending against him at that time. And we were in the middle of discovery, and we had situations in which we had witnesses who were cooperating with us and then were contacted by either Mr. Epstein or his lawyers and who then stopped cooperating with us. So I thought the Court ought to have that piece of information. + +8 9 10 THE COURT: So that sort of supports the idea that payments were made or at least the inference that one could draw to keep people silent. + +11 12 13 MR. BOIES: Yes. I don't personally know to whom they were made, and I have been given no explanation as to why they were made. + +14 15 16 What I do know is that this was a time when we had intensive evidence to take depositions and discovery and interview present and former employees of Mr. Epstein. + +17 18 19 20 21 We had experience where if we contacted somebody and we actually had some conversations with them, then Mr. Epstein would get them a lawyer, and they would stop cooperating. That proceeding was still going on at the time that these payments were made. + +22 23 24 If I could just introduce you to who is one of our clients who would just like to speak very briefly to the Court. + +25 THE COURT: Sure. + +2 3 THE COURT: Could you help us out and spell your first and last name. + +4 , A -n -n -e + +5 F-a-r-m-e-r. + +6 7 8 I was 16 years old when I had the misfortune of meeting Jeffrey Epstein here in New York. He later flew me to New Mexico to spend time with him there. + +9 10 11 12 13 14 I wanted to voice my support for the government's request that his bail not be set and also just my reaction to the fact that the defense was claiming that it would be perhaps easier for victims or more likely for victims to come forward given the publicity and some of the other issues surrounding this case. + +15 16 17 Well, I would say that it would be quite the opposite; that his wealth and privilege and the notoriety of the case would actually make it I think often more difficult. + +18 19 20 21 22 Also that they now were arguing that the discipline of this time, but yet we know that they have found photos of young women in his home and that if he's continuing to engage with pornography of young women, I would say that would be quite the opposite of disciplining. + +23 24 Also those victims in the photographs are continuing to be victimized. + +25 THE COURT: Are you in a position to answer this + +1 2 question? Are you saying that Mr. Epstein engaged in sexually inappropriate conduct with you? + +3 4 5 : He was inappropriate with me. He was inappropriate with me. I would prefer not to go into the details of that at this time. Yes. + +6 THE COURT: Thank you very much. + +7 : You're welcome. + +8 MR. : Your Honor, may I also be heard? + +9 THE COURT: Absolutely. + +10 11 12 MR. : Brad . I represent who wishes to make a statement today to the Court. Let me just give you a brief context. + +13 14 THE COURT: Could you just for a minute spell her name. + +15 16 MR. : Sure. Courtney, C-o-u-r-t-n-e-y, W -i -1 -d. + +17 18 19 20 21 22 Just for context, I have represented her since 2008 in a civil action as lead counsel that we filed against the United States Attorney's Office under the Crime Victims' Rights Act where we have alleged and now proven that the previous non-prosecution agreement was structured in violation of the rights of many of the victims. + +23 24 25 was the Jane Doe in that lawsuit. And for that reason, she has a particular interest in this case. We want to first say we appreciate your Honor's acknowledgment 1 2 3 of the Crime Victims' Rights Act and the rights of the victims, particularly the way in which they're being treated in this particular process which is different than last time. + +4 5 6 So with that, if your Honor had any questions to educate the Court on the CVRA case, I would answer them. But otherwise, she would just like to make a statement. Thank you. + +7 THE COURT: Absolutely. + +8 : Hi, your Honor. My name is + +9 10 11 12 13 14 I was sexually abused by Jeffrey Epstein starting at the age of 14. And I would just like to ask the Court to not grant him bond, to keep him in detention just for the safety of any other girls out there that are going through what I'm going through. It is a public case, and it's just -- he's a scary person to have walking the streets. + +15 16 THE COURT: Where did that occur? The sexual inappropriateness. + +17 : In Palm Beach, Florida. + +18 THE COURT: Great. Thank you so much. + +19 : Thank you. + +20 21 THE COURT: I think that concludes our work for today. I'll hopefully see you all on Thursday. 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"pdftext", + "block_counts": [ + [ + "Span", + 105 + ], + [ + "Line", + 51 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824389" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824463/EFTA02824463.md b/marker2/court-us-v-epstein-cr/EFTA02824463/EFTA02824463.md new file mode 100644 index 0000000000000000000000000000000000000000..40af0d76664a0d0c202e8aed9bc7d92d8eef78dd --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824463/EFTA02824463.md @@ -0,0 +1,104 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x UNITED STATES OF AMERICA JEFFREY EPSTEIN, Defendant. x + +PROTECTIVE ORDER + +19 Cr. 490 (RMB) + +RICHARD M. BERMAN, United States District Judge: + +WHEREAS the Government intends to produce to JEFFREY EPSTEIN, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely disclosed, the Government's ongoing investigation of uncharged individuals; (iii) would risk prejudicial pretrial publicity if publicly disseminated, and (iv) is not authorized to be disclosed to the public or disclosed beyond that which is necessary for the defense of this action, and other materials pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16") and pursuant to any other disclosure obligations (collectively, the "Discovery"), which contain sensitive, confidential, or personal identifying information; + +WHEREAS, the Government seeks to protect sensitive, confidential, or personal identifying information contained in the materials it produces consistent with Rule 16 or other disclosure obligations; + +WHEREAS the defendant, through his counsel, consents to the entry of this Order; + +IT HEREBY IS ORDERED: + +1. The Discovery disclosed to the defendant ("Defendant") and/or to the defendant's attorneys ("Defense Counsel") during the course of proceedings in this action: + +a) Shall be used by the defendant or his counsel solely for purposes of the defense of this action; + +b) Shall not be copied or otherwise recorded or transmitted by the defendant; + +c) Shall not be disclosed or distributed in any form by the defendant or his counsel except as set forth in paragraph 2(d) below; + +d) May be disclosed only by Defense Counsel and only to the following persons ("Designated Persons"): + +i. investigative, secretarial, clerical, or paralegal personnel employed full-time or part-time by the defendant's counsel ("Defense Staff"); + +ii. any expert, advisor, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); + +iii. such other persons as hereafter may be authorized by Order of the Court ("Other Authorized Persons"); + +e) May be shown to, but not disseminated to or provided copies of to, prospective witnesses and their counsel (collectively, "Potential Witnesses"), to the extent deemed necessary by defense counsel, for trial preparation. + +2. To the extent the Discovery is disclosed to Defense Staff, Defense Experts/Advisors, Other Authorized Persons, or Potential Witnesses, Defense Counsel shall instruct such individual(s) of the terms of this Order and that such individual(s) are bound by this Order. To the extent that Discovery is disseminated to Defense Staff, Defense Experts/Advisors, or Other Authorized Persons, Defense Counsel shall encrypt and/or password protect the Discovery. The provisions of this paragraph do not apply to communications exclusively between and among Defense Counsel. + +3. The Government, the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Witnesses, and Other Authorized Persons are prohibited from posting or causing to be posted any of the Discovery or information contained in the Discovery on the Internet, including any social media website. + +4. The Government (other than in the discharge of their professional obligations in this matter), Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Witnesses, and Other Authorized Persons are precluded from publicly + +disclosing or disseminating the identity of any victims or witnesses referenced in the Discovery. This Order does not prohibit Defense Counsel from publicly referencing individuals who have spoken on the public record in litigation - criminal or otherwise - relating to Jeffrey Epstein. + +5. The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing any of the Discovery or information contained in the Discovery, unless authorized by the Government in writing or by Order of the Court. Any filings that incorporate the Discovery by attachment, contain any excerpts of Discovery, or incorporate Discovery by reference must be filed under seal. Nothing in this Order precludes Defense Counsel from using the Discovery in judicial proceedings in this case. + +6. Copies of Discovery or other materials produced by the Government in this action bearing "confidential" stamps or otherwise designated as "confidential" and/or electronic Discovery materials designated as "confidential" by the Government, including such materials marked as "confidential" either on the documents or materials themselves, or designated as "confidential" in a cover letter, index, folder title, or + +other identifying designation, are deemed "Confidential Information." + +7. Confidential Information may contain personal identification information of specific individuals who are not parties to this action, and other confidential information; as well as information that identifies, or could lead to the identification of, witnesses in this matter. The Government's designation of material as Confidential Information will be controlling absent contrary order of the Court. + +8. Confidential Information disclosed to the defendant, or Defense Counsel, respectively, during the course of proceedings in this action: + +- a) Shall be used by the defendant or his counsel only for purposes of the defense of this action; +- b) Shall be maintained in a safe and secure manner solely by Defense Counsel; +- c) Shall be reviewed by the Defendant solely in the presence of Defense Counsel; +- d) Shall not be possessed outside the presence of Defense Counsel, or maintained, by the Defendant; +- e) May be disclosed only by Defense Counsel and only to Designated Persons; +- f) May be shown to, but not disseminated to or provided copies of to, Potential Witnesses, to the extent deemed + +necessary by defense counsel, for trial preparation, and after defense counsel and/or Defense Staff instructs such individual(s) of the terms of this Order and that such individual(s) are bound by this Order. + +9. Copies of Discovery or other materials produced by the Government in this action bearing "highly confidential" stamps or otherwise designated as "highly confidential" and/or electronic Discovery materials designated as "highly confidential" by the Government, including such materials marked as "highly confidential" either on the documents or materials themselves, or designated as "highly confidential" in a cover letter, index, folder title, or other identifying designation, are deemed "Highly Confidential Information." + +10. Highly Confidential Information contains images of nude or partially-nude individuals. The Government's designation of material as Highly Confidential Information will be controlling absent contrary order of the Court. Highly Confidential Information disclosed to Defense Counsel during the course of proceedings in this action: + +a) Shall not be disseminated, transmitted, or otherwise copied and provided to Defense Counsel or the Defendant; + +b) Shall be reviewed by the Defendant solely in the presence of Defense Counsel; + +c) Shall not be possessed outside the presence of Defense Counsel, or maintained, by the Defendant; + +d) Shall be made available for inspection by Defense Counsel and the Defendant, under the protection of law enforcement officers or employees; and + +e) Shall not be copied or otherwise duplicated by Defense Counsel or the Defendant during such inspections. + +11. The Defendant and Defense Counsel shall provide a copy of this Order to Designated Persons to whom they disclose confidential Information or Highly Confidential Information. Prior to disclosure of such information to Designated Persons, any such Designated Person shall agree to be subject to the terms of this Order by signing acopy hereof and stating that they "Agree to be bound by the terms herein," and providing such copy to the defendant's counsel. However, the defendant and his or her respective counsel need not obtain signatures from any member of the defense team (i.e., attorneys, experts, consultants, paralegals, investigators, support personnel, and secretarial staff involved in the representation of the defendants in this case), all of whom are nonetheless bound by this Protective Order. + +12. Except for Discovery that has been made part of the record of this case, Defense Counsel shall return to the Government or securely destroy or delete all Discovery, + +including but not limited to Confidential Information, within 30 days of the expiration of the period for direct appeal from any verdict in the above-captioned case; the period of direct appeal from any order dismissing any of the charges in the abovecaptioned case; the expiration of the period for a petition pursuant to 28 U.S.C. § 2255; or the granting of any motion made on behalf of the Government dismissing any charges in the abovecaptioned case, whichever date is later. + +13. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree otherwise, or (b) this Order is modified by further order of the Court. + +SO ORDERED: + +Dated: New York, New York , 2019 + +> HONORABLE RICHARD M. BERMAN United States District Judge + +AGREED AND CONSENTED TO: + +Dated: July 24, 2019 New York, New York + +> GEOFFREY S. BERMAN United States Attorney Southern District of New York + +By: /s/ Alison Moe / Alex Rossmiller / Maurene Comey Assistant United States Attorneys + +Dated: Lk as, 2019 New York, New York + +JEFFREY EPSTEIN + +BY: Tf r a tiO Weinberg, Esq. Reid Weingarten, Esq. 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Mollo Building One Saint Andrew's Plaza New York. New York 10007 + +July 25, 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 to request that the Court endorse a proposed protective order, which is enclosed. For the reasons set forth in the proposed order, and with the consent of defense counsel, the Government respectfully requests that the Court endorse the enclosed order. + +Respectfully submitted, + +GEOFFREY S. BERMAN United States Attorney + +By: /s/ Alison Moe Alison Moe / Alex Rossmiller / Maurene Comey Assistant United States Attorneys Southern District of New York Tel: (212) 637-2225 / 2415 / 2324 + +Enclosure + +Cc: Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824472/EFTA02824472.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824472/EFTA02824472.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ede0ad0de0430d78593821086c8359db7eb13d0d --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824472/EFTA02824472.metadata.json @@ -0,0 +1,115 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824472.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1036, + "elapsed_seconds": 0.8, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 318.85200000000003, + 25.92 + ], + [ + 463.6654968261719, + 25.92 + ], + [ + 463.6654968261719, + 41.2330322265625 + ], + [ + 318.85200000000003, + 41.2330322265625 + ] + ] + }, + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 168.48 + ], + [ + 124.12138366699219, + 168.48 + ], + [ + 124.12138366699219, + 182.9830322265625 + ], + [ + 68.544, + 182.9830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 32 + ], + [ + "Text", + 12 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824472" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824472/_page_0_Picture_1.jpeg b/marker2/court-us-v-epstein-cr/EFTA02824472/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..0ed2e7e35916e32f606fa388e720f687190d7f49 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824472/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:bd4bf608e1b1e20fe71e1d20eed9b59c77b44d0bab383ac3eb4f9ddfe7516c65 +size 3346 diff --git a/marker2/court-us-v-epstein-cr/EFTA02824473/EFTA02824473.md b/marker2/court-us-v-epstein-cr/EFTA02824473/EFTA02824473.md new file mode 100644 index 0000000000000000000000000000000000000000..a641a67bbc07962a46515216444d3900e2cfdc16 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824473/EFTA02824473.md @@ -0,0 +1,109 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA JEFFREY EPSTEIN, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: a644 + +## PROTECTIVE ORDER + +19 Cr. 490 (RMB) + +RICHARD M. BERMAN, United States District Judge: + +WHEREAS the Government intends to produce to JEFFREY EPSTEIN, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely disclosed, the Government's ongoing investigation of uncharged individuals; (iii) would risk prejudicial pretrial publicity if publicly disseminated, and (iv) is not authorized to be disclosed to the public or disclosed beyond that which is necessary for the defense of this action, and other materials pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16") and pursuant to any other disclosure obligations (collectively, the "Discovery"), which contain sensitive, confidential, or personal identifying information; + +WHEREAS, the Government seeks to protect sensitive, confidential, or personal identifying information contained in the materials it produces consistent with Rule 16 or other disclosure obligations; + +WHEREAS the defendant, through his counsel, consents to the entry of this Order; + +IT HEREBY IS ORDERED: + +1. The Discovery disclosed to the defendant ("Defendant") and/or to the defendant's attorneys ("Defense Counsel") during the course of proceedings in this action: + +a) Shall be used by the defendant or his counsel solely for purposes of the defense of this action; + +b) Shall not be copied or otherwise recorded or transmitted by the defendant; + +c) Shall not be disclosed or distributed in any form by the defendant or his counsel except as set forth in paragraph 2(d) below; + +d) May be disclosed only by Defense Counsel and only to the following persons ("Designated Persons"): + +i. investigative, secretarial, clerical, or paralegal personnel employed full-time or part-time by the defendant's counsel ("Defense Staff"); + +ii. any expert, advisor, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); + +iii. such other persons as hereafter may be authorized by Order of the Court ("Other Authorized Persons"); + +e) May be shown to, but not disseminated to or provided copies of to, prospective witnesses and their counsel (collectively, "Potential Witnesses"), to the extent deemed necessary by defense counsel, for trial preparation. + +2. To the extent the Discovery is disclosed to Defense Staff, Defense Experts/Advisors, Other Authorized Persons, or Potential Witnesses, Defense Counsel shall instruct such individual(s) of the terms of this Order and that such individual(s) are bound by this Order. To the extent that Discovery is disseminated to Defense Staff, Defense Experts/Advisors, or Other Authorized Persons, Defense Counsel shall encrypt and/or password protect the Discovery. The provisions of this paragraph do not apply to communications exclusively between and among Defense Counsel. + +3. The Government, the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Witnesses, and Other Authorized Persons are prohibited from posting or causing to be posted any of the Discovery or information contained in the Discovery on the Internet, including any social media website. + +4. The Government (other than in the discharge of their professional obligations in this matter), Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Witnesses, and Other Authorized Persons are precluded from publicly + +disclosing or disseminating the identity of any victims or witnesses referenced in the Discovery. This Order does not prohibit Defense Counsel from publicly referencing individuals who have spoken on the public record in litigation - criminal or otherwise - relating to Jeffrey Epstein. + +5. The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing any of the Discovery or information contained in the Discovery, unless authorized by the Government in writing or by Order of the Court. Any filings that incorporate the Discovery by attachment, contain any excerpts of Discovery, or incorporate Discovery by reference must be filed under seal. Nothing in this Order precludes Defense Counsel from using the Discovery in judicial proceedings in this case. + +6. Copies of Discovery or other materials produced by the Government in this action bearing "confidential" stamps or otherwise designated as "confidential" and/or electronic Discovery materials designated as "confidential" by the Government, including such materials marked as "confidential" either on the documents or materials themselves, or designated as "confidential" in a cover letter, index, folder title, or + +other identifying designation, are deemed "Confidential Information." + +7. Confidential Information may contain personal identification information of specific individuals who are not parties to this action, and other confidential information; as well as information that identifies, or could lead to the identification of, witnesses in this matter. The Government's designation of material as Confidential Information will be controlling absent contrary order of the Court. + +8. Confidential Information disclosed to the defendant, or Defense Counsel, respectively, during the course of proceedings in this action: + +a) Shall be used by the defendant or his counsel only for purposes of the defense of this action; + +b) Shall be maintained in a safe and secure manner solely by Defense Counsel; + +c) Shall be reviewed by the Defendant solely in the presence of Defense Counsel; + +d) shall not be possessed outside the presence of Defense Counsel, or maintained, by the Defendant; + +e) May be disclosed only by Defense Counsel and only to Designated Persons; + +f) May be shown to, but not disseminated to or provided copies of to, Potential Witnesses, to the extent deemed necessary by defense counsel, for trial preparation, and after defense counsel and/or Defense Staff instructs such individual(s) of the terms of this Order and that such individual(s) are bound by this Order. + +9. Copies of Discovery or other materials produced by the Government in this action bearing "highly confidential" stamps or otherwise designated as "highly confidential" and/or electronic Discovery materials designated as "highly confidential" by the Government, including such materials marked as "highly confidential" either on the documents or materials themselves, or designated as "highly confidential" in a cover letter, index, folder title, or other identifying designation, are deemed "Highly Confidential Information." + +10. Highly Confidential Information contains images of nude or partially-nude individuals. The Government's designation of material as Highly Confidential Information will be controlling absent contrary order of the Court. Highly Confidential Information disclosed to Defense Counsel during the course of proceedings in this action: + +a) Shall not be disseminated, transmitted, or otherwise copied and provided to Defense Counsel or the Defendant; + +b) Shall be reviewed by the Defendant solely in the presence of Defense Counsel; + +c) Shall not be possessed outside the presence of Defense Counsel, or maintained, by the Defendant; + +d) Shall be made available for inspection by Defense Counsel and the Defendant, under the protection of law enforcement officers or employees; and + +e) Shall not be copied or otherwise duplicated by Defense Counsel or the Defendant during such inspections. + +11. The Defendant and Defense Counsel shall provide a copy of this Order to Designated Persons to whom they disclose Confidential Information or Highly Confidential Information. Prior to disclosure of such information to Designated Persons, any such Designated Person shall agree to be subject to the terms of this Order by signing a copy hereof and stating that they "Agree to be bound by the terms herein," and providing such copy to the defendant's counsel. However, the defendant and his or her respective counsel need not obtain signatures from any member of the defense team (i.e., attorneys, experts, consultants, paralegals, investigators, support personnel, and secretarial staff involved in the representation of the defendants in this case), all of whom are nonetheless bound by this Protective Order. + +12. Except for Discovery that has been made part of the record of this case, Defense Counsel shall return to the Government or securely destroy or delete all Discovery, + +including but not limited to Confidential Information, within 30 days of the expiration of the period for direct appeal from any verdict in the above-captioned case; the period of direct appeal from any order dismissing any of the charges in the abovecaptioned case; the expiration of the period for a petition pursuant to 28 U.S.C. § 2255; or the granting of any motion made on behalf of the Government dismissing any charges in the abovecaptioned case, whichever date is later. + +13. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree otherwise, or (b) this Order is modified by further order of the Court. + +SO ORDERED: + +Dated: New York, New York it 2019 + +AGREED AND CONSENTED TO: + +Dated: July 24, 2019 New York, New York + +HONORABLE RICHARD M. BERMAN United States District Judge + +rat,44 :Ras aa, + +GEOFFREY S. BERMAN United States Attorney Southern District of New York + +By: /0/ Alison Moe / Alex Rossmiller / Maurene Comey Assistant United States Attorneys + +Dated: as , 2019 New York, New York + +> By: Weinberg, Esq. Reid Weingarten, Esq. Counsel for Jeffrey Epstein + +JEFFREY EPSTEIN \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824473/EFTA02824473.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824473/EFTA02824473.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7b487b27e5d6d87bad8c3ddf6c30c3aab5709f0e --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824473/EFTA02824473.metadata.json @@ -0,0 +1,362 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824473.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 9, + "chars": 9940, + "elapsed_seconds": 1.37, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "PROTECTIVE ORDER", + "heading_level": null, + 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file mode 100644 index 0000000000000000000000000000000000000000..3c949ed201949b4ca4a90598fe64e90839a5bc4e --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824482/EFTA02824482.md @@ -0,0 +1,27 @@ +## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA + +USA / Plaintiff(s) + +case No.: 19CR490 + +JEFFREY EPSTEIN + +Defendant(s) + +## NOTICE OF FILING OF OFFICIAL TRANSCRIPT + +Notice is hereby given that an official transcript of a HEARING held on 7/18/19 has been filed by the court reporter/transcriber in the above-captioned matter. + +Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting the transcript is a judge or a member of the public or media. + +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically available to the public without redaction after ninety (90) calendar days. + +This process may only be used to redact the following personal data identifiers: Social Security numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information may proceed by motion. + +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. + +/s + +Court Reporter/Transcriber Date \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824482/EFTA02824482.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824482/EFTA02824482.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8d1461362617080ae9cd7133b538ffd69edc99c0 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824482/EFTA02824482.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824482.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1437, + "elapsed_seconds": 0.85, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "IN THE UNITED STATES DISTRICT COURT \nFOR THE SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 153.612, + 67.23 + ], + [ + 418.71282958984375, + 67.23 + ], + [ + 418.71282958984375, + 96.363037109375 + ], + [ + 153.612, + 96.363037109375 + ] + ] + }, + { + "title": "NOTICE OF FILING OF OFFICIAL TRANSCRIPT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 167.688, + 308.61 + ], + [ + 448.52362060546875, + 308.61 + ], + [ + 448.52362060546875, + 322.4830627441406 + ], + [ + 167.688, + 322.4830627441406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 26 + ], + [ + "Text", + 15 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824482" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824483/EFTA02824483.md b/marker2/court-us-v-epstein-cr/EFTA02824483/EFTA02824483.md new file mode 100644 index 0000000000000000000000000000000000000000..286d0c0afc1f926285597622c2a2252d676424f0 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824483/EFTA02824483.md @@ -0,0 +1,81 @@ +1 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x + +3 UNITED STATES OF AMERICA + +4 v. 19 CR 490 (RMB) + +5 JEFFREY EPSTEIN, + +6 Defendant. Bail Decision + +7 x + +8 New York, N.Y. July 18, 2019 11:30 a.m. + +9 Before: + +10 HON. RICHARD M. BERMAN + +11 District Judge + +12 + +13 APPEARANCES + +14 + +15 16 17 18 GEOFFREY S. BERMAN United States Attorney for the Southern District of New York ALEXANDER ROSSMILLER MAURENE R. COMEY ALISON G. MOE Assistant United States Attorneys + +19 20 21 WEINBERG MARC FERNICH JOMES BROCHIN MICHAEL Attorneys for Defendant + +22 + +23 Also Present: + +24 25 AMANDA YOUNG - Special Agent FBI PAUL BYRNE - Detective NYPD JOHN MOSCATO - Pretrial Services Officer + +2 3 4 5 6 7 8 9 10 11 THE COURT: I had hoped to have a written decision and order by now, which I don't, one that is regarding the release/remand of Mr. Epstein, which has been the subject of multiple written submissions and, as you all know, an in-court hearing on Monday, July 15, 2019. It is not quite physically produced yet and it needs to be cite checked, but I should have it on the docket in the next hour, two hours at most. What I will do, however, is state the conclusions in the decision and order, which I had said I would do, and summarize very briefly the contents of the ruling for you. + +12 13 14 15 Starting with my conclusions, the government's application for continued remand is hereby granted and the defense application for pretrial release is respectfully hereby denied. Written opinion to follow. + +16 17 18 19 20 21 22 23 In that opinion I will deal with all, I'll try to, all the principal issues which have been briefed. Even though it is not entirely necessary or legally required to consider both dangerousness to others and to the community as well as risk of flight, I have done so. I also deal with the defense's proposed bail package. There is obviously significant public interest in all of these legal issues, so I tried to cover them all as best I could. + +24 25 There are the following headings in the decision and order. First is a background section, followed by counsel's + +1 2 3 4 5 6 7 8 submissions. Those are the written submissions: principally the indictment, the legal principles governing release versus remand, the presumption of remand in 18 U.S.C. section 1591 cases, danger to others and the community. This topic has seven subsections and fills over ten pages of the decision and order. I think it is fair to say that it is the heart of this decision, that is to say, dealing with danger to others and to the community. + +9 10 11 Then I deal with risk of flight. That has four subsections or factors, which are substantially the same factors that are used to analyze dangerousness. + +12 13 14 15 16 17 18 19 Then, finally, the bail package proposed by the defense. Specifically, I find in the decision and order that the government has established dangerousness to others and to the community by clear and convincing evidence and also that the government has established risk of flight by a preponderance of the evidence. I also reject the proposed bail package as irretrievably inadequate and go on in some detail concerning what I consider to be its deficiencies. + +20 21 22 Incidentally, I am not suggesting that a different bail package would be appropriate because I doubt that any bail package can overcome danger to the community. + +23 24 25 I focus then on dangerousness to others, most certainly including the minor victims in this case and prospective victims as well. I cite and quote, for example, + +1 2 3 the compelling testimony of and who testified that they fear for their safety and the safety of others if Mr. Epstein were to be released. + +4 5 6 7 8 I also point out that the presumption of remand, as opposed to the presumption of release, is unusual in our jurisprudence and that it attaches only to very serious crimes, such as sex trafficking involving minor victims, as in this case some allegedly as young as age 14. + +9 10 11 12 I also discuss evidence of intimidation and threats and compensation paid to potential witnesses and the facts surrounding whether or not Mr. Epstein has been compliant with his legal obligations as a registered sex offender. + +13 14 15 16 17 18 19 When discussing risk of flight, which you obviously can tell comes after, in my analysis, dangerousness to the community, when discussing that aspect, risk of flight, the decision speaks to the seriousness of the charged crimes, to Mr. Epstein's great wealth and his vast resources, which include private planes and frequent international travel and also a foreign residence in Paris. + +20 21 22 23 24 25 I mention the items very recently seized from Mr. Epstein's New York City mansion pursuant to lawful search warrants, which include sexually explicit photos and discs, some \$70,000 in cash, diamonds, and an expired Austrian passport with Mr. Epstein's photo but with a name that is different from Jeffrey Epstein, and also contains a reference + +2 3 4 5 I think I have given you a fair account of the decision and order. As I said before, the written version in its complete form, which will be about 30 to 34 pages long I imagine, I hope will be available reasonably soon. + +6 7 8 9 10 11 One piece of business in light of today's ruling. I thought I would schedule a conference with the parties for Wednesday, July 31, at 11:00 a.m. That is not fixed in If you all want to meet and confer and let me know if that is a convenient date, or I'm happy to accommodate you with another date as well. + +12 13 14 For the moment, I'll tentatively schedule a conference for July 31st at 11:00 a.m. and ask if there is an application for exclusion of speedy trial. + +15 16 17 MS. MOE: Yes, your Honor. The government moves to exclude time under the Speedy Trial Act from today's date until July 31st. + +18 19 20 21 22 23 24 25 THE COURT: I am going to find under 18 United States Code section 3161 that adjournment to and including July 31 at 11:00 a.m. is appropriate and warrants exclusion of the adjourned time from speedy trial calculations. I further find that the exclusion is designed to prevent any possible miscarriage of justice, to facilitate these proceedings, and to guarantee effective representation of and preparation by all counsel for both parties, both sides. Thus, the need for + + exclusion and the ends of justice outweigh the interests of the public and the defendant in a speedy trial pursuant to 18 U.S.C. section 3161(h)(7)(A) and (B). + + Finally, a word about the proposed conference. From my point of view, it would be more or less a scheduling/case management type conference, but I'm happy to consider any issues that you might have at that time. + + I think that's it. Everybody, thank you for being here. 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X ORDER + +19 Cr 490 + +Counsel for the Government and the Defense are requested to meet and confer prior to Wednesday's conference and to devise a mutually acceptable schedule for the balance of the case, including discovery, motion practice, and trial. + +Dated: New York, New York July 29, 2019 + +RICHARD M. BERMAN, U.S.D.J. + +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC #: \_\_\_\_\_ +DATE FILED: 7/29/19 \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824489/EFTA02824489.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824489/EFTA02824489.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7779a66ed5fcd115e1b2e376dec13ea8fc88c931 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824489/EFTA02824489.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824489.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 536, + "elapsed_seconds": 0.9, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK \nUNITED STATES OF AMERICA,", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 62.424, + 72.08999999999999 + ], + [ + 312.73199999999997, + 72.08999999999999 + ], + [ + 312.73199999999997, + 128.60302734375 + ], + [ + 62.424, + 128.60302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 44 + ], + [ + "Line", + 22 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Form", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824489" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824490/EFTA02824490.md b/marker2/court-us-v-epstein-cr/EFTA02824490/EFTA02824490.md new file mode 100644 index 0000000000000000000000000000000000000000..bbcd10908eeea65e319d3a5e916df7f65ea77947 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824490/EFTA02824490.md @@ -0,0 +1,383 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x + +4 v. 19 Cr. 490(RMB) + +5 6 JEFFREY EPSTEIN, Defendant. + +7 x Conference + +8 July 31, 2019 11:05 a.m. + +9 + +10 Before: + +11 12 HON. RICHARD M. BERMAN, District Judge + +13 14 APPEARANCES + +15 16 17 18 GEOFFREY S. BERMAN United States Attorney for the Southern District of New York BY: ALISON J. MOE ALEXANDER ROSSMILLER MAURENE R. COMEY Assistant United States Attorneys + +19 + +20 G. WEINBERG Attorney for Defendant + +21 + +22 23 STEPTOE & , LLP Attorneys for Defendant BY: MICHAEL C. + +24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 + +UNITED STATES OF AMERICA, New York, N.Y. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +THE COURT: So, today's conference was scheduled at the end of the July 18 court conference hearing on that date. I thought that we would devote at least the -- well, probably most of today's proceeding to talking about the schedule in this case, and I asked the lawyers to get together and see if they could come up with a mutually agreeable schedule, which would include trial date, motion practice, discovery, etc. + +Does anybody want to let me know how you made out? + +MS. MOE: Yes, your Honor. + +We have conferred with defense counsel and talked about a proposed schedule for this case. So we are prepared to propose to the court today a schedule for discovery, for discovery-related motions, for pretrial motions, and we are also prepared to talk about setting a possible trial date. + +THE COURT: Okay. What have you got in mind? + +MS. MOE: So, with respect to discovery, we would propose a discovery deadline of October 31 to complete discovery, with one exception. There are materials from devices seized from the defendant's residence in New York, and the F.B.I. is beginning the process of reviewing that data. + +In discussing that with defense counsel, we have begun to discuss a process for a privilege-review protocol. It's possible that process may take longer than October 31. But aside from that universe of documents, we would propose setting a schedule of October 31 as a deadline for discovery. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +For discovery-related motions, we would propose that the defense file any motions that they are aware of relating to discovery, to include motions relating to the nonprosecution agreement, by September 13 -- + +THE COURT: By when? + +MS. MOE: September 13, your Honor. + +-- that the government be permitted to respond by October 4; with any reply due on October 11, as necessary. + +Of course we understand that if the defense comes to have additional motions related to discovery based on the ongoing discovery process that we will confer and propose an additional briefing schedule beyond that, as necessary. But with respect to motions that the defense is already aware of, including the NPA, that is the schedule that we would propose at this time. + +Regarding pretrial motions, your Honor, we would propose that the defense file their motions by January 10, that the government be permitted to respond by February 10, and that any replies be due on or before February 24. + +THE COURT: Got it. + +MS. MOE: And finally, your Honor, we are prepared to discuss a trial date in this case. The government is asking the court to set a trial date in this matter. We would propose that the court schedule this matter for trial in June of next year, and we estimate that the trial would take approximately + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +four to six weeks, and so that trial date would carry into July. And I understand that the defense has some comments about that proposal, but that's the government's proposal with respect to a trial date. + +THE COURT: Okay. Let me hear from the defense. + +Do I understand it correctly that, with the exception of the trial date, those dates are agreeable? + +MR. WEINBERG: Those dates are agreeable, your Honor. + +THE COURT: Counsel, whatever you wish to add, that would be fine. + +MR. WEINBERG: We would ask the court to set a preliminary trial date immediately after Labor Day. I say preliminary because we want time to assess Mr. Epstein's -- + +THE COURT: This year? + +MR. WEINBERG: Yes. + +THE COURT: This Labor Day. Okay. + +MR. WEINBERG: We want time to assess Mr. Epstein's ability to . . . + +(Counsel confer) + +MR. WEINBERG: I'm sorry. I am being told that your Honor was inquiring as to the year. Let me -- + +THE COURT: Yes. I thought you wanted a speedy trial, and so -- + +MR. WEINBERG: Not with a four- to six-week trial with discovery coming in October, Judge. I apologize for being + +imprecise. Labor Day 2020 or immediately thereafter. And I 4 5 6 7 8 9 10 make that recommendation -- we haven't received the discovery yet. Understandably, it is coming, and I'm not in any way contesting that there has been a delay, but we haven't had an opportunity to start reviewing what the government has predicted to be over a million pages of discovery with Mr. Epstein and to assess Mr. Epstein's ability to exercise his constitutional right, while at MCC, in assisting counsel prepare for a very difficult case that addresses events that it is alleged occurred 14 to 17 years ago. + +11 THE COURT: Okay. + +12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. WEINBERG: So, we need time to receive a million pages of discovery and to prepare to defend a four- to six-week trial, when a lot of the immediate attention is going to be on the very unique and complex constitutional issues connected to the nonprosecution agreement, our contention that the government's allegations are inextricably intertwined and constitutionally barred by the NPA. There are double jeopardy issues both connected to the conspiracy count, which looks to be an overlap with one of the charges that was expressly within the immunity provisions in the NPA. We are going to be spending a lot of time, and that's why I agreed with the government that we should make early discovery motions on the NPA-related issues, on double-jeopardy-related issues, so that we could not only facially brief the motion to dismiss, but + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +have the discovery, the subfacial discovery, if you will, so that we could make a comprehensive briefing along the lines of the schedule for motions. + +THE COURT: That's what I was going to suggest, if there is a time period when you could put it all together, as it were, and there is a lot of flexibility. So I will leave these dates, you know, for now. + +With respect to the trial date, I could accommodate either June or September of 2020. The issue is not so much as, from my point of view, when you are all ready, but what part of the calendar I block out. So is it realistic to block out time in June? + +MR. WEINBERG: I think it is -- I don't want to have the court block out a six-week time and then come to the court in March and say we need a continuance and risk a September date. + +THE COURT: Got it. Okay. So a September date, you are saying, sounds like it certainly is realistic. + +MR. WEINBERG: Thirteen months sounds like the amount of time that we would ordinarily need to prepare a case of this magnitude and scope. + +THE COURT: All right. That is fine for me. + +Just while we are taking care of details, a speedy trial issue or application? Why don't we extend it to September of 2020? + +4 5 MS. MOE: Your Honor, may I briefly be heard with respect to the trial date? + +6 7 8 9 10 11 12 THE COURT: II, sure. You know, it does sound like it is kind of premature, but I'm happy to hear you. It is often the defense that is ahead of the government, or not often, but equally, but here it is the other way around. So if the defense is not ready, it would be my practice to defer to the defense, but I don't know that it is fixed in either way. But, sure, I am happy to hear you. + +13 14 15 16 17 18 19 20 21 22 23 24 25 MS. MOE: Your Honor, by way of background, we had initially proposed to the defense a May trial date. We think that there is a public interest in bringing this case to trial as swiftly as manageable. We understand, given their concerns in wanting to have more time, we proposed a date in June as a compromise position. We understand if the defense has indicated that they need additional time. We are sensitive to those concerns. But we do have a concern about the notion of setting a September trial date and that that trial would be preliminary or as a placeholder. Thirteen months is a considerable amount of time for a case of this nature to go to trial; and, again, given the time period of the charged conduct and the length of time that's passed, we do think that there is + +MR. WEINBERG: This case certainly meets all of the statutory criteria for complexity and we would agree to that extension, Judge. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +a public interest in scheduling a fixed trial date in this case. Of course we understand if issues arise in the interim, we will address that as it occurs, but we do think it makes sense at this juncture to set a firm trial date. We don't think that any delay in this case is in the public interest. + +THE COURT: Counsel. + +MR. WEINBERG: We think that the delay in bringing this charge, your Honor, the natural corollary of that is to make it more difficult, not easier, for us to defend Mr. Epstein. For instance, there are certain sealed files for potential witnesses that we would have to go to other courts to seek to unseal. There is an NPA to litigate. This case is not your ordinary 1591 case. A case of four to six weeks is not the ordinary amount of time the government takes to prosecute, whether it is old or new cases. We need 13 months. I'm trying to make a principled argument, Judge, that that would be a schedule that we would try our best to meet, conditioned on our ability to work with Mr. Epstein under the current conditions. + +Thank you, sir. + +THE COURT: Okay. + +So, we are going to monitor the case from now until then anyway, so I think everybody will be in a better position to know what is realistic with respect to a trial date. I will exclude time from today through, let's say, June 8, but that, of course, is without prejudice to hearing from the defense and + +4 5 the government as to actually where things stand. Long before then we will know. So we will have a conference, or several, between now and then. Let's see where everybody is as the months go by, and then we will know when we can effectively hold the trial. + +6 7 8 9 10 11 12 13 14 15 16 17 So I am going to find, under 18 United States Code 3161, that the request for adjournment, joined in by both sides, is appropriate and warrants exclusion of the adjourned time from Speedy Trial calculations. I further find that the exclusion is designed to prevent any possible miscarriage of justice, to facilitate these proceedings, including extensive pretrial preparation, and to guarantee effective representation of and preparation by counsel for both sides, and thus the need for exclusion and the ends of justice outweigh the interests of the public and the defendant in a speedy trial pursuant to 18 United States Code § 3161(h)(7)(A) and (B). So that exclusion goes to June 8, 2020 preliminarily. + +18 19 20 Counsel, is it your thought that these motions would be on submission or did you want to have oral argument with respect to any aspect of them? + +21 22 MR. WEINBERG: We would seek oral argument, your Honor. + +23 24 25 THE COURT: So let's set October 28, 2019 for oral argument, and I am tentatively reserving some time on my calendar, as I said before, on June 8, 2020, but I will have a 4 So there you have it. Did you have -- go ahead. + +5 6 MS. MOE: Just to clarify, your Honor, what time would the court like the parties to appear on October 28? + +7 THE COURT: 10 a.m. + +8 MS. MOE: Thank you, your Honor. + +9 THE COURT: And the June 8 date is 9 a.m. Okay? + +10 11 12 MR. WEINBERG: Would your Honor want to schedule an argument on the substantive motions that will be fully briefed before the court on February 24? + +13 THE COURT: Yup. + +14 15 So let's schedule that oral argument for March 12, 2020, at 10 a.m. + +16 Great. So anything anybody else has to talk about? + +17 MR. WEINBERG: Not from the defense, your Honor. + +18 19 MS. MOE: Not from the government, your Honor. Thank you. + +20 THE COURT: Okay. + +21 MR. WEINBERG: Thank you very much, sir. + +22 THE COURT: Nice to see you all. + +23 oOo + +24 25 + +much better feel for where things are long before that and certainly I would say on October 28 we would have a much clearer picture of how things stand. \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824490/EFTA02824490.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824490/EFTA02824490.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..040f60936bedc5ffa7222f3bcfc49a7b3b6d962f --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824490/EFTA02824490.metadata.json @@ -0,0 +1,364 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824490.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": 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transcript is a judge or a member of the public or media. + +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically available to the public without redaction after ninety (90) calendar days. + +This process may only be used to redact the following personal data identifiers: Social Security numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information may proceed by motion. + +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. + +/s KRISTEN CARANNATE + +Court Reporter/Transcriber Date \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824500/EFTA02824500.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824500/EFTA02824500.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..180e07ed1c8c8942d37c45060205a95c5ffdb36f --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824500/EFTA02824500.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824500.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1452, + "elapsed_seconds": 0.85, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "IN THE UNITED STATES DISTRICT COURT \nFOR THE SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 153.612, + 67.23 + ], + [ + 418.71282958984375, + 67.23 + ], + [ + 418.71282958984375, + 96.363037109375 + ], + [ + 153.612, + 96.363037109375 + ] + ] + }, + { + "title": "NOTICE OF FILING OF OFFICIAL TR A \\ SC RIP I", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 167.688, + 307.79888916015625 + ], + [ + 446.76, + 307.79888916015625 + ], + [ + 446.76, + 322.1835632324219 + ], + [ + 167.688, + 322.1835632324219 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Line", + 28 + ], + [ + "Text", + 15 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824500" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824501/EFTA02824501.md b/marker2/court-us-v-epstein-cr/EFTA02824501/EFTA02824501.md new file mode 100644 index 0000000000000000000000000000000000000000..74a57a49f1b586db85b88e4140d990fe231ed48a --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824501/EFTA02824501.md @@ -0,0 +1,36 @@ +August 10, 2019 + +![](_page_0_Picture_4.jpeg) + +Federal Bureau of Prisons + +Office of the Warden + +Meiropolkan Correct loud Caner 150 Park Row New York. New York 10007 (646)8364300. (646) 836-7551 (Fax) + +SENT VIA EMAIL + +The Honorable Colleen McMahon, Chief Judge The Honorable Richard M. Berman, District Judge Daniel Moynihan United States Courthouse 500 Pearl Street New York, New York 10007-1312 + +Re: EPSTEIN, Jeffrey, Federal Register No. 76318-054 United States v. Jeffrey Epstein, 19-cr-00490-RMB + +Dear Chief Judge McMahon and Judge Berman: + +I am writing to notify the Court of the death of Jeffrey Epstein, who passed away Saturday, August 10, 2019, at around 7:37 a.m. + +Mr. Epstein had been found unresponsive in his cell in the Special Housing Unit at around 6:30 am from an apparent suicide at the Metropolitan Correctional Center (MCC) in New York, New York. Responding staff immediately initiated life-saving measures and requested emergency medical services (EMS), by whom Mr. Epstein was transported to a local hospital for treatment of life-threatening injuries. Mr. Epstein was pronounced dead at the New York Presbyterian-Lower Manhattan Hospital in New York, New York. + +At this time, there are no preliminary reports identifying the exact cause of death. An autopsy is pending, and we expect to have more information as to the cause of death from the medical examiner in the near future. The Federal Bureau of Investigation (FBI) is actively investigating the incident. In addition to the FBI's investigation, the Attorney General has requested that the Department of Justice Office of the Inspector General look into the matter as well. + +MCC New York will provide an update to the Court as soon as the autopsy is completed and the official cause of death is determined. If you have any questions or concerns, please feel free to call me at (646)836-7700. Thank you for your time and attention to this matter. + +Sincerely, + +![]()Lamine N'Diaye +Warden +MCC New York + +cc: Michael Greco, U.S. Marshal, and John Csakany, Chief Deputy U.S. Marshal +Michael J. Fitzpatrick, Chief U.S. Probation Officer +Maurene Comey, Alexander Rossmiller, and Alison Moe, Assistant U.S. Attorneys +██████████ Weinberg and Reid Weingarten, Counsel for Mr. Epstein \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824501/EFTA02824501.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824501/EFTA02824501.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..81a4cce47cc67a7b8000338866fc16653e2712a9 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824501/EFTA02824501.metadata.json @@ -0,0 +1,130 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824501.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2260, + "elapsed_seconds": 3.44, + "image_assets": [ + "_page_0_Picture_4.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 375.15599999999995, + 34.062 + ], + [ + 520.2, + 34.062 + ], + [ + 520.2, + 49.363037109375 + ], + [ + 375.15599999999995, + 49.363037109375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 76 + ], + [ + "Line", + 35 + ], + [ + "Text", + 11 + ], + [ + "PageHeader", + 4 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "Text", + 8 + ], + [ + "PageHeader", + 2 + ], + [ + "Caption", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824501" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824501/_page_0_Picture_4.jpeg b/marker2/court-us-v-epstein-cr/EFTA02824501/_page_0_Picture_4.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..750700a11c151ed5dee23ffdb0ba1db3b72e9fab --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824501/_page_0_Picture_4.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:745fc889340d62c89835b2b275ddfebdddcabbfcceff82eb781e86248b8ae976 +size 12077 diff --git a/marker2/court-us-v-epstein-cr/EFTA02824503/EFTA02824503.md b/marker2/court-us-v-epstein-cr/EFTA02824503/EFTA02824503.md new file mode 100644 index 0000000000000000000000000000000000000000..508925f52393be96a9a98b683212295ba449b78e --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824503/EFTA02824503.md @@ -0,0 +1,19 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UM= srrra4 NDURTHOUSE ZOO PEARL Vaal . NEW YORK. NEW YORK 10007 (212) 805-6715 + +ENAMOERS Or RICHARD M. BERMAN UNITED STATUS DISTRICT JUDGE + +August 12, 2019 + +Larninc N'Diaye, Warden. Metropolitan Correctional Center 150 Park Row New York, New York 10007 + +Dear Warden N'Diaye, + +Thank you for your letter of August 10.2019 regarding the death of Jeffrey Epstein. Mr. Epstein's death is a tragedy to everyone involved in his case. + +One open question, among others, is whether the investigations referenced in your letter will include the incident at MCC involving Mr. Epstein on or about July 23, 2019. To my knowledge, it has never been definitively explained what the BOP concluded about that incident. + +irsackmoviko + +Richard M. Berman + +cc; Chief Judge Colleen McMahon Edward Friedland. District Executive Adam Supervisory Staff Attorney MCC Michael Greco, U.S. Marshal Alison Moe. Assistant United States Attorney Weinberg. Counsel for Mr. Epstein \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824503/EFTA02824503.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824503/EFTA02824503.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5e645ccca5eccaaeedc3fcfab747efe9ce992ae6 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824503/EFTA02824503.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824503.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1008, + "elapsed_seconds": 0.61, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK \nUM= srrra4 NDURTHOUSE \nZOO PEARL Vaal .\nNEW YORK. 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New York 10007 16.46) 836-6300. (646) 836-7751 Vaal + +SENT VIA EMAIL The Honorable Richard M. Berman, District Judge Daniel Moynihan United States Courthouse 500 Pearl Street New York, New York 10007-1312 + +Re: EPSTEIN, Jeffrey Federal Register No. 76318-054 United States s ..leffrev Epstein, 19-cr-00490-RMB + +Dear Judge Berman: + +I am writing in regards to your August 12, 2019 inquiry whether the investigations referenced in my August 10. 2019 letter will include the incident at MCC involving Mr. Epstein on or about July 23. 2019. + +I can confirm that, although an internal investigation was completed regarding the July 23, 2019 incident, the current investigations by the FBI and OIG will include this incident as well. Accordingly, I cannot divulge any information about the prior investigation at this time. + +Thank you for your time and attention to this matter. If you have any questions or concerns, please feel free to call me at (646)836-7700. + +Sincerely, + +Lamine N Diaye Warden MCC New York + +cc: Chief Judge Colleen McMahon Edward Friedland, District Executive Michael Greco, U.S. Marshal Alison Moe, Assistant U.S. Attorneys Weinberg, Counsel for Mr. Epstein \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824504/EFTA02824504.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824504/EFTA02824504.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a1e6112991899d0e994546df76d81a622c33abbb --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824504/EFTA02824504.metadata.json @@ -0,0 +1,96 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824504.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1321, + "elapsed_seconds": 1.03, + "image_assets": [ + "_page_0_Picture_4.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 375.768, + 35.001999999999995 + ], + [ + 520.8043823242188, + 35.001999999999995 + ], + [ + 520.8043823242188, + 49.570556640625 + ], + [ + 375.768, + 49.570556640625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 36 + ], + [ + "Text", + 13 + ], + [ + "PageHeader", + 4 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Caption", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824504" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824504/_page_0_Picture_4.jpeg b/marker2/court-us-v-epstein-cr/EFTA02824504/_page_0_Picture_4.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..9bd327f9d59a96abc7c482f863be5ccbcf0296e4 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824504/_page_0_Picture_4.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:4e8439e44aa99d565bf846017e9582dda14bc4e8b5abdf23d50ad5d6ba6e5741 +size 11851 diff --git a/marker2/court-us-v-epstein-cr/EFTA02824505/EFTA02824505.md b/marker2/court-us-v-epstein-cr/EFTA02824505/EFTA02824505.md new file mode 100644 index 0000000000000000000000000000000000000000..5d0da334095540b672b6899f3f6377b3c569d160 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824505/EFTA02824505.md @@ -0,0 +1,33 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +NOLLE PROSEQUI + +UNITED STATES OF AMERICA JEFFREY EPSTEIN, Defendant. + +19 Cr. 490 (RMB) + +1. The filing of this nolle prosequi will dispose of this case with respect to JEFFREY EPSTEIN, the defendant. + +2. On July 2, 2019, Indictment 19 Cr. 490 (the "Indictment") was returned, charging JEFFREY EPSTEIN, the defendant, with one count of conspiracy to commit sex trafficking of minors, in violation of 18 U.S.C. S 371, and one count of sex trafficking of minors, in violation of 18 U.S.C. S 1591. + +3. On or about August 10, 2019, while the abovecaptioned case was pending, but prior to any trial or other disposition, JEFFREY EPSTEIN, the defendant, died. + +4. Because JEFFREY EPSTEIN, the defendant, died while this case was pending, and therefore before a final judgment was issued, the Indictment must be dismissed under the rule of abatement. See United States v. , 160 F.3d 905, 908 (2d Cir. 1998). + +5. Accordingly, I recommend that an order of nolle prosequi be filed as to defendant JEFFREY EPSTEIN. + +Dated: New York, New York August 19, 2019 + +> ALISON MOE / ALEX ROSSMILLER / MAURENE COMEY Assistant United States Attorneys + +Upon the foregoing recommendation, I hereby direct, with leave of the Court, that an order of nolle prosequi be filed as to defendant JEFFREY EPSTEIN. + +Dated: New York, New York August 19, 2019 + +SO ORDERED: + +Dated: New York, New York August , 2019 + +GEOFFREY S. BERMAN United States Attorney Southern District of New York + +Hon. Richard M. Berman United States District Judge Southern District of New York \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824505/EFTA02824505.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824505/EFTA02824505.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..72bcf30a5978acc75033ae95504fdce22967dcd1 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824505/EFTA02824505.metadata.json @@ -0,0 +1,120 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824505.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1594, + "elapsed_seconds": 0.61, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 73.95999908447266, + 70.47 + ], + [ + 290.3566589355469, + 70.47 + ], + [ + 290.3566589355469, + 96.38999999999999 + ], + [ + 73.95999908447266, + 96.38999999999999 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 50 + ], + [ + "Line", + 24 + ], + [ + "Text", + 7 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 23 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824505" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824507/EFTA02824507.md b/marker2/court-us-v-epstein-cr/EFTA02824507/EFTA02824507.md new file mode 100644 index 0000000000000000000000000000000000000000..b679f6cb87ddd90f794ee116955721b9d3b0f5d5 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824507/EFTA02824507.md @@ -0,0 +1,29 @@ +![](_page_0_Picture_1.jpeg) + +United States Attorney Southern District of New York + +The Silvio J. Hallo Building One Saha Aflame 's Pkra New York, New York 10007 + +August 19, 2019 + +## VIA ECF + +The Honorable Richard M. Berman United States District Judge 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: + +As the Court is aware, on the morning of August 10, 2019, Jeffrey Epstein died while in custody at the Metropolitan Correctional Center. On August 16, 2019, and after conducting an autopsy, the Office of the Chief Medical Examiner of the City of New York issued a statement identifying the cause of death as hanging, and the manner of death as suicide. In light of the death of the defendant prior to a conviction becoming final, the Government must request the Court approve the attached proposed order of nolle prosequi. + +Consistent with our practice throughout this case and our obligations under the Crime Victims' Rights Act, the Government has made efforts to contact all identified victims since learning of the death of the defendant and will similarly notify all known victims of the attached order, once entered. As this Office has previously stated publicly, it remains committed to doing its utmost to stand up for the victims who have already come forward, as well as for the many others who have yet to do so. + +Cc: All counsel of record (Via ECF) + +By: + +Alison Moe / Alex Rossmiller / Maurene Comey Assistant United States Attorneys Southern District of New York Tel: (212) 637-2225 / 2415 / 2324 + +Respectfully submitted, + +GEOFFREY S. 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ORDER + +JEFFREY EPSTEIN, Defendant. X + +USDC SDNY I DOCUMENT i ELECTRONICALLY FILED i DOC #: II DATE FILED: + +19 Cr 490 + +The Court will conduct a brief hearing on Tuesday, August 27, 2019 at 10:30 am. in connection with the nolle prusequi order proposed to the Court on August 19, 2019 by the United States Attorney. + +The Court believes that where, as here, a defendant has died before any judgment has been entered against him, the public may still have an informational interest in the process by which the prosecutor seeks dismissal of an indictment. + +At the hearing, Counsel for the Government and for the deceased Defendant, Jeffrey Epstein, will be heard. Counsel for the victims and the victims will also be heard, if they wish to be. + +The hearing will be held in Courtroom 17B. + +Dated: New York, New York August 21, 2019 + +RICHARD M. BERMAN, U.S.D.J. \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824508/EFTA02824508.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824508/EFTA02824508.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..651ac66e0fc4bbe322bb27624e6f0e9e876e9f96 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824508/EFTA02824508.metadata.json @@ -0,0 +1,58 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824508.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 966, + "elapsed_seconds": 0.83, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Line", + 30 + ], + [ + "Text", + 11 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824508" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824509/EFTA02824509.md b/marker2/court-us-v-epstein-cr/EFTA02824509/EFTA02824509.md new file mode 100644 index 0000000000000000000000000000000000000000..6973251325527cec1c689576c6b3753bc462ade1 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824509/EFTA02824509.md @@ -0,0 +1,34 @@ +# MANDATE + +N.Y.S.D. Case # +19-cr-0490(RMB) + +## UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT + +At a Stated Term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 21st day of August, two thousand and nineteen, + +\_\_\_\_\_ + +United States of America, + +Appellee, + +v. + +Jeffrey Epstein, AKA Sealed defendant 1, + +Defendant - Appellant. + +The parties in the above-referenced case have filed a stipulation withdrawing this appeal pursuant to FRAP 42. + +The stipulation is hereby "So Ordered". + +For The Court: +Catherine O'Hagan Wolfe, +Clerk of Court + +![]()A True Copy + +Catherine O'Hagan Wolfe - Clerk + +![]() \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824509/EFTA02824509.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824509/EFTA02824509.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b693da3e92b14747cb01672e2cff23a92ec27274 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824509/EFTA02824509.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824509.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 736, + "elapsed_seconds": 4.43, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "MANDATE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 14.076, + 21.87 + ], + [ + 317.01599999999996, + 21.87 + ], + [ + 317.01599999999996, + 72.08999999999999 + ], + [ + 14.076, + 72.08999999999999 + ] + ] + }, + { + "title": "UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.78000000000003, + 72.08999999999999 + ], + [ + 416.15999999999997, + 72.08999999999999 + ], + [ + 416.15999999999997, + 111.78000000000002 + ], + [ + 192.78000000000003, + 111.78000000000002 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Text", + 39 + ], + [ + "Line", + 33 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824509" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824510/EFTA02824510.md b/marker2/court-us-v-epstein-cr/EFTA02824510/EFTA02824510.md new file mode 100644 index 0000000000000000000000000000000000000000..f9819bec2d835e67bf93a72ce7735d925a6dd015 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824510/EFTA02824510.md @@ -0,0 +1,29 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA, + +- against - + +JEFFREY EPSTEIN, + +Government, + +Defendant. + +—x + +USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC\* I:NfE FILED: + +19 CR. 490 (RMB) + +## ORDER + +The hearing scheduled for Tuesday, August 27, 2019 at 10:30 a.m. will be held in + +Courtroom 110 of the Thurgood Marshall United States Courthouse located at 40 Foley Square. + +Dated: New York, New York August 26, 2019 + +°R41^4,,eteRealloa + +RICHARD M. 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Golden (alias Jeremy Thundercloud/ G.) + +Intervenor + +CRIMINAL ACTION NO. 1:19-cr-O0490 + +Motion to Intervene + +|

Application respectfully denied.

| | +|-----------------------------------------|-------------------| +| SO ORDERED: | | +| Date: 8/27/19 | Richard M. Berman | +| Richard M. Berman, U.S.D.J. | | + +### MOTION TO INTERVENE + +David Golden (herewith referred to as G.) respectfully moves to Intervene in the action, as this case involves common issues of law and fact that are common with his own case, including criminal fraud and conspiracy. G.'s complaint (No. CV186051 RBL) was filed under the False Claims Act in the District Ct. of Western Washington in December of 2018. + +> DAVID GOLDEN 15151 NW MASON RD NORTH PLAINS, OR 97133 + +#### RELIEF REQUESTED + +Relator/ Intervenor requests seizure of the politically corrupt organization USDOJ; associated with abuses of prosecutorial discretion, fraud, and public corruption. Intervenor has witnessed the same pattern of political/ judicial corruption at work in his own case; and has now identified the same conspiracy at work in this case. + +## FACTUAL BACKGROUND + +- Intervenor was a licensed engineer and bridge inspector for State of Washington. In 2012/2013, Intervenor filed a whistleblower complaint with the Washington State Auditor's Office. The complaint was escalated to Michael Horowitz's office of the Inspector General (OIG; See EXHIBIT A Case 1:19-CR-00490-RMB hereby attached by Declaration). 01G refused to investigate the complaint. State of Washington fraudulently concealed that it secured funds for fixing the that Intervenor complained about, and misrepresented the safety issue. Intervenor later discovered that State of Washington concealed this information so that "Democrats" and Republicans could launder \$70 billion to the Association of General Contractors (AGC) and the labor unions through intervenor's attorneyz. +- On 12/27/19, Intervenor filed a False Claims complaint in the District Ct of Western WA under the False Claims Act, seeking \$1 billion in damages and qui tam bounty against "Democrats", Republicans, and his former attorneys for fraud (See EXHIBIT B Case 1:19-CR-00490-RMB hereby attached by Declaration (first 2 pages only)). +- On 5/1/13, USDOJ submitted a fraudulent motion to dismiss intervenor's claim (See EXHIBIT C Case 1:19-CR-00490-RMB hereby attached by Declaration), falsely stating that intervenor's allegations "lack sufficient factual and legal support." +- On 5/13/19, Intervenor filed a petition for quo warrant° against Bill Barr and other USI301 attorneys for conspiracy, fraud, obstruction, and perjury (See EXHIBIT D Case 1:19-CR-00490-RMB hereby attached by Declaration). +- On 5/14/19, Intervenor had his False Claims complaint fraudulently dismissed by the District Ct., after fraud, perjury, and obstruction were proven against USDOJ (See EXHIBIT E Case 1:19-CR-00490-RMB hereby attached by Declaration). + +DAVID GOLDEN 15151 NW MASON MI RD NORTH PLAINS, OR 97133 + +- On 5/15/19, Intervenor had his petition for quo worranto against USDal for fraud/ obstruction/ perjury dismissed as "moot" (See EXHIBIT F Case 1:19-CR-00490-RMB hereby attached by Declaration). +- On 6/6/19, Intervenor identified the conspiracy (the same conspiracy at work in this case) to the District Ct. (Freemasonry/ Rotary; See EXHIBITS G and I-I (EXHIBIT H affidavit ¶ 12.17) Case 1:19-CR-00490-RMB hereby attached by Declaration). The conspiracy is subject to the unequal application of the laws; and the conspiracy monopolizes the judiciary. +- On 6/26/19, the District Court refused to vacate its decision, and threatened Intervenor with sanctions if Relator appealed the decision (See EXHIBIT I Case 1:19-CR-00490-RMB hereby attached by Declaration). Relator appealed. +- On 7/27/19, Intervenor sent USDal attorneyz the 9t" Circuit mediation form (See EXHIBIT.' Case 1:19-CR-00490-RMB hereby attached by Declaration), showing the course of action Intervenor intended to pursue on appeal. Intervenor also indicated that he intended to write about USDOJ's unlimited "prosecutorial discretion" to fraudulently dismiss False Claims complaints, as this "prosecutorial discretion" was the same "prosecutorial discretion" exercised by USDOJ and Alex Acosta in the Jeffrey Epstein case. Intervenor also attached an article by the former Deputy Attorney General of the United States (Donald Ayer), indicating that Barr was a "fierce advocate of unchecked presidential power". Intervenor also identified the judge in the District Ct. (formerly presiding over Intervenor's case), as being associated with the conspiracy. +- According to newspaper reports, on 7/29/19, Jeffrey Epstein was taken off suicide watch. +- According to newspaper reports, on 8/10/19, Epstein was found dead. + +### ARGUMENT + +Intervention in criminal matters "have been granted in limited circumstances where 'a third party's constitutional or other federal rights are implicated by the resolution of a particular motion, request, or other issue during the course of a criminal case." United States v. Collyard, case no. 12cr0058, 2013 W1.1346202 at \*2 (D. Minn. April 3, 2013 quoting United States v. Carmichael, 342 F. Supp. 2d 1070, 1072 (M.D. Ala 2004). + +Here, just 3 months prior, Relator filed a petition of quo warranto against Bill Barr/ USDOJ for fraud, perjury, and treason. The judge in the District Ct. denied Relator (and the People) the right to quo warranto, and dismissed Relator's complaint to "moot" the quo warranto proceedings (Relator is entitled to this right under the 9th/10`^ Arndt.). Further, Relator has been denied constitutional and other legal rights as provided for under the 1" , 4th, St", and 14"' amendments, the Crime Victims Act, + +> DAVID GOLDEN 15151 NW MASON RD NORTH PLAINS, OR 97133 + +and the substantial law. Intervenor has been denied these rights so that the conspiracy can continue laundering tax money. Intervenor has already proven that USDOJ/ 016 are politically corrupt federal agencies, as intervenor filed a whistleblower complaint with WA State Auditor and OIG in 2012/2013 because he was worried about structural bridge collapse. As a result of filing this complaint, intervenor had his career and reputation destroyed by OIG, State of WA, and his attorneyz. Relator has already shown that 016/ USDOJ agencies cannot be trusted as they specialize in fraud and deception (see complaint No CV 18.6051 on Pacer for the entire complaint). + +## CONCLUSION + +For the foregoing reasons, and the fact that USDOJ and OIG have already been proven by relator to be politically corrupt agencies, G. respectfully requests that the Court approve his motion, and surrender USDOJ to relator. + +The obstruction of the quo worranto proceedings and the "apparent acquittal" for USDOJ, has resulted in the "apparent suicide" of Jeffrey Epstein while under USDOJ / Bill Barr watch. Relator has already demonstrated/ proven that USDO1/ CMG are corrupt and assisting Republicans and "Democrats" to launder tax money. Intervenor's motion should be granted. + +Dated: August 21, 2019 + +Respectfully submitted, + +David A. Golden + +DAVID GOLDEN 15151 NW MASON RD NORTH PLAINS, OR 97133 \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824511/EFTA02824511.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824511/EFTA02824511.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2f84ba10ad9614c8637c326b28530ed3afea0cc7 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824511/EFTA02824511.metadata.json @@ -0,0 +1,339 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824511.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 7579, + "elapsed_seconds": 1.65, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "IN THE SOUTHERN DISTRICT CIRCUIT 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SOUTHERN DISTRICT OF NEW YORK + +x UNITED STATES OF AMERICA JEFFREY EPSTEIN, Defendant. x + +NOLLE PROSEQUI + +19 Cr. 4 ittmul + +USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: Si; 1/ 9 + +1. The filing of this nolle prosequi will dispose of this case with respect to JEFFREY EPSTEIN, the defendant. + +2. On July 2, 2019, Indictment 19 Cr. 490 (the "Indictment") was returned, charging JEFFREY EPSTEIN, the defendant, with one count of conspiracy to commit sex trafficking of minors, in violation of 18 U.S.C. § 371, and one count of sex trafficking of minors, in violation of 18 U.S.C. § 1591. + +3. On or about August 10, 2019, while the abovecaptioned case was pending, but prior to any trial or other disposition, JEFFREY EPSTEIN, the defendant, died. + +4. Because JEFFREY EPSTEIN, the defendant, died while this case was pending, and therefore before a final judgment was issued, the Indictment must be dismissed under the rule of abatement. See United States v. , 160 F.3d 905, 908 (2d Cir. 1998). + +Case 1:19-cr-00490-RMB Document 47.1 Fled 08/19119 Pegg 2 of 2 + +5. Accordingly, I recommend thit an order of nolle prosequi be filed se to defendant J1WVASY EPSTEIN. + +Dated: New York, New York August 19, 2019 + +Upon the foregoing recommendation, I hereby direct, with leave of the Court, that an order of nolle vrosequi be tiled as to defendant JeePREY EPSTEIN, + +ALISON NOS / ROSSNILLER / MAURENE CONEY Assistant United States Attorneys + +Dated: NeW York, New York August 19, 2019 + +> • a(410610A ONOP 4 UNMAN United States Attorney Southern District of New York + +SO ORDERED: + +Dated: New York, New York August 2019 + +> TheCourtincorporatesbyreferencethetranscrietofthehearing tubldon8/27/19initsentiretyamimmirmeoomrthesiguificterme oftheCrimeeicrtirestRightsAct,18U.S.C.93771. + +RtkiB + +Hon.RichardM.Berman United States District Judge Southern District of New York \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824515/EFTA02824515.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824515/EFTA02824515.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6cecb2a823011c4fc78326d63b8836adedebbd10 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824515/EFTA02824515.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824515.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1892, + "elapsed_seconds": 0.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Line", + 32 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 30 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824515" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824517/EFTA02824517.md b/marker2/court-us-v-epstein-cr/EFTA02824517/EFTA02824517.md new file mode 100644 index 0000000000000000000000000000000000000000..1efa8fafbfb06940146674a4df9e501cdfd7e78d --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824517/EFTA02824517.md @@ -0,0 +1,1865 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +UNITED STATES OF AMERICA, + +v. + +JEFFREY EPSTEIN, + +Defendant. + +Before: + +x + +19 CR 490 (RMB) + +New York, N.Y. August 27, 2019 10:30 a.m. + +HON. RICHARD M. BERMAN, + +District Judge + +## APPEARANCES + +GEOFFREY S. BERMAN United States Attorney for the Southern District of New York BY: MAURENE R. COMEY ALISON MOE Assistant United States Attorneys + +BY: G. WEINBERG, PC Attorney for Defendant G. WEINBERG + +STEPTOE & , LLP Attorneys for Defendant BY: REID WEINGARTEN MICHAEL + +(Case called) + +THE COURT: Good morning, everybody. Please be seated. + +4 5 6 7 8 So just some housekeeping. We have a podium here for both attorneys and others who may be speaking, and so we would like you, attorneys and others who are speaking, to come up to the podium. This room is a little cavernous. We thought the podium over there would be more comfortable. + +9 10 11 12 For starters, and for this you don't have to go up to the podium, if you could just indicate your names. This table in front to my left, your right, are defense counsel, and that table to my right, your left, are government attorneys. + +13 14 If we could just ask the attorneys to introduce themselves. + +15 16 17 18 MS. COMEY: Good morning, your Honor. Maureen Comey and Alison Moe for the government. Joining us at counsel table are Special Agent Amanda Young of the FBI and Detective Paul Byrne of the NYPD. + +19 MR. WEINGARTEN: Good morning, your Honor. + +20 Reid Weingarten. + +21 MR. WEINBERG: Weinberg. + +22 Good morning, your Honor. + +23 THE COURT: Good morning. + +24 MR. : Good morning, your Honor. + +25 Michael from Steptoe & on behalf of the + +4 5 Again, good morning to all of you. This hearing that we're having today considers the government's motion to dismiss the indictment in this case. + +6 7 8 9 I must add that it also serves as the opportunity for me to thank all of you, the attorneys and the victims who are here today, among others, for your very hard work and dedication in this case. + +10 11 12 We also have here today the U.S. Attorney for the Southern District of New York, Geoffrey Berman, who has also been very helpful and indispensable in this matter. + +13 14 15 16 17 18 19 20 21 22 23 The news on August 10, 2019, that Jeffrey Epstein had been found dead in his cell at the Metropolitan Correctional Center, at the MCC, was certainly shocking. Most of you, and myself for that matter, were anticipating that the next steps in this case would be defense motion practice, including a motion to dismiss, followed by a trial on the merits before a jury, if the motions were not successful, and through which the accusers and the accused would come face to face, allowing everyone to get their day in court. Mr. Epstein's death obviously means that a trial in which he is a defendant cannot take place. It is a rather stunning turn of events. + +24 25 The government's motion to dismiss the indictment because of Jeffrey Epstein's death on August 10, 2019, is + +defendant. + +THE COURT: Great. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +relatively straightforward. In my view, a public hearing clearly is nevertheless the preferred vehicle for its resolution. + +Incidentally, while I'm on this subject, I got some help today from the New York Law Journal from two professors who write that a hearing is -- let me tell you exactly what they said. They say, in part, that this is an odd moment for transparency in a criminal case. I think that is an odd sentence to hear about, transparency in a criminal case. + +They go on to say that normally, if a prosecutor seeks to dismiss an indictment for such an obviously worthy reason, the court would simply grant the request. As to that statement, I respectfully say it is incorrect as a matter of law. + +They go on to say the judge would not schedule a hearing and he definitely would not allow the victims to speak. If he did hold a hearing, whatever informational interests the victims may have would be served by affording them a chance to attend the hearing, not by giving them a speaking role. + +I read it. It was incredulous. I'm still incredulous. I don't quite understand at all. There is a suggestion in the article that the reason they are making these suggestions has to do with minimization of drama in this case. In the Jeffrey Epstein case, there has not been much a minimization of drama, and what little drama might happen + +4 5 6 7 On a somewhat more serious note, don't quote me on this, but it is my understanding that one of the authors of that article is himself counsel in one of the Epstein-related cases. I was surprised to learn that very recently. I'm certain it is true. I was also surprised that that aspect was not disclosed in the Law Journal. + +8 9 10 11 12 13 But in any event, I think you know where I'm heading. I respectfully disagree with the Law Journal piece. I was saying that the government's motion is relatively straightforward, and in my view, a public hearing is clearly, nevertheless, the preferred vehicle for its resolution. I'm still convinced of that. + +14 15 16 17 A few may differ on this, but public hearings are exactly what judges do. Hearings promote transparency and they provide the court with insights and information which the court may not otherwise be aware of. + +18 19 20 The victims have been included in the proceeding today both because of their relevant experiences and because they should always be involved before rather than after the fact. + +21 22 23 24 25 Indictment 19 CR 490 charges Jeffrey Epstein with sex trafficking and with conspiracy to commit sex trafficking. The U.S. Attorney, on August 19, 2019, requested that the court approve the government's proposed order of nolle prosequi. I think that's a rough justice. That means nolle prosequi, + +today, I don't think it would be very significant. + +4 5 6 7 8 9 The government in its motion concludes that Epstein's death abates these proceedings. In accordance with Federal Rule of Criminal Procedure 57(b), I determined to hold a public hearing and I notified the victims that they would be given the opportunity to be heard before any final action on the motion. That is the purpose also of today's proceeding. I would do that every time. + +10 11 12 13 Also, recognized that Epstein, Mr. Epstein died before any judgment of conviction against him had been obtained, and that the government's proposed order appears, in form and substance, to be appropriate. + +14 15 16 17 18 19 20 21 Federal Rule of Criminal Procedure 48(a) codifies the nolle prosequi process. It is entitled dismissal, and it states in relevant part that the government may, with leave of the court, dismiss an indictment, information, or complaint, and that leave of the court proviso, you should know, was added as an amendment to the original draft of Rule 48, which had originally provided for automatic dismissal upon the motion of the government. + +22 23 24 25 This proviso, in my judgment, is clearly directed toward an independent judicial assessment of the public interest in dismissing the indictment. Thus, even whereas, in this case, the standard of court review is deferential, the + +discontinuance by the prosecutor of all or of a part of the case that he or she has commenced. + +4 5 6 7 8 9 It is also, in my view, required that the court consider the views of the victims in the case at the hearing and before deciding whether to grant the motion. This is being done here both as a matter of law and as a measure of respect that we have for the victims' difficult decisions to come forward in this matter. + +10 11 12 13 14 15 In a case called United States v. H-e-a-t-o-n-, the government filed a Rule 48 motion for leave to dismiss a charge against a defendant who allegedly committed a sexual offense against a young victim. Although I should point out, very importantly, that that defendant was still alive, which distinguishes it from our case. + +16 17 18 19 20 21 22 Nevertheless, I think it is irrelevant because in evaluating the Rule 48 motion, then district Judge Paul G. Cassell -- who is now a law professor at the University of Utah and is regarded to be a noted expert in victims' rights concluded that under the Crime Victims' Rights Act, victims have broad rights that extend to a court's decision whether to grant a government motion to dismiss under Rule 48. + +23 24 25 I completely share that viewpoint in these circumstances, even though the facts of our case, as I said, are somewhat different from those in . I believe it is + +court must still make its own independent determination. A conclusory statement from the government that dismissal is appropriate does not satisfy the court's obligations. + +4 5 6 7 8 9 10 The fundamental substantive principle which applies in considering the government's motion is termed the rule of abatement. This principle originated in the English common law. It was adopted by most U.S. federal courts, but more recently, it has faced some appropriate criticism. The rule of abatement is best explained in the Second Circuit case of + +11 12 13 14 15 16 17 18 19 20 In that case, two defendants had pled guilty to embezzlement and tax evasion. Both defendants appealed, but one of the defendants died while his appeal was pending in the Second Circuit. The Court of Appeals rule that under the rule of abatement, the judgment of conviction against the deceased defendant was required to be vacated and the indictment was to be dismissed. The court held that when a convicted defendant dies while his direct appeal as of right is pending, his death abates not only the appeal, but also proceedings had during the course of the prosecution. + +21 22 23 24 25 The Second Circuit incidentally has also held that when a criminal conviction abates upon the death of a defendant, any restitution ordered as a result of that conviction must also abate, and it is also ruled the same with respect to associated forfeiture orders. + +the court's responsibility, and manifestly within its purview, to ensure that the victims in this case are treated fairly and with dignity. + +4 5 6 7 8 This latter application of the rule of abatement regarding forfeiture has not been universally accepted among federal courts, but it certainly is the law in this circuit. Some of you may be interested to know that some United States courts, state courts, have criticized the rule of abatement, particularly in the face of growing recognition of victims' rights in the criminal justice system, including the Crime Victims' Rights Act. + +9 10 11 12 13 14 15 16 17 18 19 20 It has been written and contended in the Brooklyn Law Review -- I can give you the cite later -- that when courts abate criminal convictions, they reimpose a burden on victims that legislatures intended to alleviate through these victim rights statutes. The state Supreme Court has even concluded that the expansion and codification of victims' rights provides the changed conditions needed for overruling the rule of abatement. It has also been stated that Alaska's statute and its constitution now require the criminal justice system to accommodate the rights of crime victims. Further, that the abatement of criminal convictions has important implications for these rights. + +21 22 23 24 25 But coming back to our case, which is what you are concerned about and I am as well, it is appropriate to conclude that if the rule of abatement applies to a convicted defendant as in the case, it should also apply a fortiori in the Epstein case, which was still in the pretrial phase when + +4 5 So that's just some background I wanted to share with you. At this point in time, I would like to turn to the government prosecutors to hear from them in support of their Rule 48 application to dismiss the Epstein indictment. + +6 MS. COMEY: Thank you, your Honor. + +7 8 Would you like me to address the court from the podium? + +9 THE COURT: If you wouldn't mind. + +10 MS. COMEY: Thank you, your Honor. + +11 12 13 14 15 I believe your Honor has accurately summarized the state of the law, as set forth in our papers, in light of the clear Second Circuit law, that upon the death of a defendant before a final entry of a judgment of conviction, all proceedings must be abated. + +16 17 18 19 In light of that clear law, the government is legally obligated to seek dismissal of the pending indictment against Jeffrey Epstein, and we respectfully submit, likewise, that the entry of the proposed order is similarly required by law. + +20 21 22 23 24 25 A few notes to make about that, though, your Honor. To be very clear, dismissal of this indictment as to Jeffrey Epstein in no way prohibits or inhibits the government's ongoing investigation into other potential coconspirators, nor does it prevent the bringing of a new case in the future or the prosecution of new defendants. + +Mr. Epstein died, when there had been no conviction. + +It also does nothing to prevent the government from continuing to explore the possibility of seeking civil forfeiture of any assets that were used to facilitate the crimes charged in this indictment. Indeed, as has been stated publicly, investigations into those matters have been ongoing, remain ongoing, and will continue following dismissal of the indictment here. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +I would also like to note that, as the government has previously mentioned, this dismissal in no way lessens the government's resolve to stand up for the victims in this case, both those who have come forward and those who have yet to do so. We agree with your Honor's sentiment that those victims should be respected, and we appreciate your Honor's recognition of that. + +One housekeeping matter that I did want to reference for your Honor. The protective order in this case requires destruction or return of any and all discovery material upon conclusion of the case. We have been in communication with defense counsel, who have confirmed that they have returned all physical copies that they have of discovery that the government has produced to date, and they are in the process of deleting any copies that they may have made. So the parties are in compliance with the protective order. + +Finally, I just wanted to say a word about the victims in this case, and particularly those who are here in court + +4 5 6 7 today. I'll note that in light of the court's order indicating that the victims and their counsel would be permitted to be heard in court here today, the government has endeavored to provide notice to all known victims of today's proceeding. We did so either directly where a victim was not represented by counsel or through counsel where a victim is represented by an attorney. + +8 9 10 11 12 13 The government does not know exactly how many victims or their attorneys are here today and we do not know how many of them or their counsel would like to speak. To the extent any individuals do wish to speak, we do not know the substance of what they would like to say. We have left that entirely up to the individual decisions of the victims and their attorneys. + +14 15 16 17 18 19 I will note, though, that throughout this case, the government has endeavored and done our utmost to fulfill our obligations under the Crimes Victims' Rights Act. We have done so by trying to keep as many victims as we are aware of up to date about the ongoing case and about any developments in the case. + +20 21 22 23 24 25 We will continue to provide services and offer services to any of the victims in this case, even after the indictment is dismissed. Both the U.S. Attorney's office and the FBI have been in touch with all known victims or have attempted to be in touch with all known victims, either again directly where victims are not represented by counsel or + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +through counsel where they have attorneys. We have expressed to them that services are available for those who wish to take advantage of them. + +Unless the court has any questions for me, the government will otherwise rest on its papers. + +THE COURT: I just have one question. + +The protective order, is that self-executing or do I need to do something? + +MS. COMEY: It is self-executing, your Honor. + +THE COURT: Thanks very much, Ms. Comey. + +MS. COMEY: Thank you, your Honor. + +THE COURT: Yes. + +I'll turn to counsel for the defense at this time. Mr. Weingarten, I'm happy to hear from you. + +MR. WEINGARTEN: Thank you. + +Your Honor, I think it is an understatement of the year to say the world looks and feels differently today than it did the last time I was before you. For us, the elephant in the room is what happened to our client. I would like to tell you how we see the world and where we are on that subject. + +We start with the Attorney General's statements, public statements, that there were very serious improprieties in the jail. We obviously read the press. We see that the warden has been taken out. We see that the guards on duty at the time have been put on leave. We understand guards are + +refusing to cooperate with the investigation. We have heard 4 5 6 allegations that people at the time who had responsibility for protecting our client falsified information. We understand that there were orders out there that Jeffrey Epstein was never to be left alone and that the orders were ignored by many of the employees of the prison. + +7 8 9 10 11 12 In a word, yikes. In addition, obviously we followed the medical examiner's report, or we haven't followed the report, we haven't seen it, but heard conclusions, initially not enough evidence to come to a conclusion, wanted to see more. We assumed she was talking about the videotapes, but then came to the conclusion that it was suicide. + +13 We report to the court that -- + +14 THE COURT: Suicide by hanging + +15 MR. WEINGARTEN: Yes. + +16 THE COURT: -- was her conclusion? + +17 MR. WEINGARTEN: Yes. + +18 19 20 21 22 23 And we report to the court that we had a doctor there at the time, and we also have been in receipt of a tremendous amount of medical and scientific evidence volunteered to us opining that the injuries suffered, as reported, were far more consistent with assault than with suicide, and we are happy to supply the court with all the information that we have. + +24 25 Now, in addition, as the court noted, we were underway with our pretrial motions, and as the court obviously + +4 5 6 7 8 We interviewed all of the relevant lawyers on the defense side who participated in the NPA, and we were satisfied that we had a very strong argument that every one of those lawyers believed with an objective basis that the deal was global. That is, at the time -- + +9 THE COURT: I'm sorry, that? + +10 11 12 13 14 15 16 MR. WEINGARTEN: The deal of the NPA was global. That is, more specifically, at the time, the Florida prosecutors and agents knew of conduct in New York, and that no competent defense counsel negotiating in good faith with the prosecutors would have ever agreed to a deal back then that allowed New York prosecutors to indict for precisely the same conduct in the future, which, of course, is what happened. + +17 18 19 20 21 22 23 24 In addition, we have come up with very powerful evidence, we believe, that Florida prosecutors, who participated in the deal, steered the victims and the alleged victims to New York on more than one occasion because they did not want to suffer the sleights of attacks against them. So we have advanced the ball on this very subject and we are prepared to completely report to the court as to where we are and what we've done. + +25 Another point. We obviously had contact with our + +understands, the NPA and the role of the NPA was going to be critically important. And I would simply like to report that we went pretty far along. + +4 5 6 client at or around the time of his death, and obviously the attorney-client privilege survives death and we are not going to forfeit the privilege, but we will report to the court, with as much specificity as the court may want, that at or around the time of his death, we did not see a despairing, despondent suicidal person. Details to follow, if the court wishes. + +7 8 9 10 11 12 13 The 800-pound gorilla, for us, of course, are the video surveillance tapes. Obviously we assume there is a tape that leads directly to the door where Jeffrey Epstein was housed. If that tape reports for 12 hours before his death that no one went in and out of that room, then the suggestion that there was something other than a suicide seems preposterous. + +14 15 16 17 18 19 20 21 22 23 24 But there is no such evidence that has surfaced to date. Just the opposite. We have heard, and we actually read in the press, that the tapes were either corrupted or not functioning. Talk about a yikes. If, in fact, the system was broken for six months before Jeffrey Epstein was housed, I mean, that would be stunning incompetence. If it was allowed to continue to be inoperative when Jeffrey Epstein was housed, it would be incompetence times ten. But what if the tapes only broke down or were inoperative or were corrupted on the day he was killed or the day he died? Then we're in a completely different situation. + +25 So where does this lead? I think where it leads, + +4 5 Judge, is there are incredibly important questions that remain open. The public interest in this matter is obvious from this courtroom. There are conspiracy theories galore. We are all for finding the truth. We believe this court has an indispensable role to play. + +6 7 8 9 10 11 Whether or not this indictment is dismissed, I think this court has the inherent authority to find out what happened on its watch. Obviously, when the court detained Jeffrey Epstein, the court did not anticipate that weeks later he would be dead in his cell. I think given the inherent authority of the court, the court should make inquiry. + +12 13 14 15 This could come in many forms. Obviously the court made inquiry as to what happened in the first incident. When there was an allegation of an attempted suicide, the court made inquiry. The court obviously was interested. + +16 17 18 19 I recall your language. You talked about that being one of the several open questions indicating an interest on the court for the others as well. Obviously, the ultimate question is what happened to the client. + +20 21 THE COURT: You're talking about the July 23, 2019 incident? + +22 MR. WEINGARTEN: Yes. + +23 24 25 The court obviously could hold hearings. The court could assign a lawyer to help the court. I think this is an area where there is intense public interest. We have complete + +4 5 confidence in the prosecutors in the Southern District and the FBI to do a competent investigation. But these are allegations against serious components of the United States Department of Justice. Sometimes the appearance of justice is just as important as justice itself. + +6 7 8 9 I think the court supervising, or at least keeping an interest in this proceeding, is incredibly important for the public to have confidence in the ultimate findings, and certainly for us to have confidence in the ultimate findings. + +10 11 12 13 14 15 One more issue, Judge. The conditions of the jail, in a word, they were dreadful. Not just for Jeffrey Epstein, but for many of the prisoners over there. This is a prison within the shadows of this courthouse. The situation is rife with vermin. The abuse and the conditions in that prison, in a word, are a disgrace and everybody knows it. + +16 17 18 19 20 21 22 23 A person with authority told us, someone with knowledge, that the prisoners in Guantanamo -- and he spoke with personal knowledge -- are treated better than the prisoners right across the way. The feds certainly know how to run a disciplined, clean prison. I've been in 20 of them. They know how to do it just fine. And the question is, why in the world does it not happen down the road? I think that is a perfectly legitimate subject for the court to make inquiry. + +24 25 In a word, we want the court to help us find out what happened. The court has a role to play. It is the institution that most people have confidence in in these very troubled times. + +So whether or not you dismiss the indictment, to us, 4 5 6 is beside the point. We want you to stay on the case, we want you to conduct an investigation, and we want to know what happened here. + +7 Thank you, your Honor. + +8 9 10 THE COURT: Just so it is clear, so your view on the motion directly on its merits of the nolle prosequi order and application by the U.S. Attorney, do you have a view on that? + +11 12 13 MR. WEINGARTEN: I think if the court felt that the case had to stay alive for the court to continue, we would oppose it. I think -- + +14 THE COURT: I'm sorry, if what? + +15 16 17 18 19 MR. WEINGARTEN: If the issue, if you took the position for you to conduct the investigation or lead the investigation or participate in the investigation, then we want, the role we want you to play, if the indictment has to be alive, we would oppose the motion. + +20 21 I don't think you need to do that. I think you can dismiss the indictment. + +22 23 THE COURT: So you're suggesting that you support the government's motion, just viewed in the context of -- + +24 MR. WEINGARTEN: Yes, of course. + +25 THE COURT: Great. + +MR. WEINBERG: Judge, if I can just supplement? + +THE COURT: Absolutely. + +MR. WEINBERG: Thank you, sir. + +4 5 Thank you, as an out-of-town lawyer for the privilege to appear in front of you, your Honor. + +6 THE COURT: It's my pleasure. + +7 8 9 10 11 12 MR. WEINBERG: First, as to the conditions, we think your Honor trusted the government, the Bureau of Prisons, to keep our client government will detained at the unit. safe and keep him in civilized conditions. The again ask, as to other defendants, that they be MCC, some subset of them will end up in the SHU + +13 14 15 16 17 18 It is a horrific. I've called it medieval. There's vermin on the floor. There is wet from the plumbing. There is no sunlight. There is limited exercise. It is simply conditions that no pretrial detainee -- and I would go farther as a criminal defense lawyer -- no United States defendant should be subjected to. + +19 20 21 22 23 Certain judges have taken views of the conditions. We would urge your Honor, the government talks about and we talk about transparency, to see what kind of conditions there exist within 50 or 100 yards of one of the great United States district courts. + +24 25 Second, in terms, we have a profound problem with the conclusions of the medical examiner. There are for three + +4 5 6 7 8 9 10 11 One is the timing of Mr. Epstein's demise. It was on August 10. On August 12, a bail pending appeal motion was being filed in the Second Circuit. On August 12 or 13, the United States Attorneys were going to respond to our request for the preservation and production of documents that would have facilitated and furthered our efforts to demonstrate communications between the Southern District of Florida, the Northern District of Georgia, which was standing in the shoes of the Southern District of Florida main justice and the Southern District. + +12 13 14 15 16 17 18 In other words, we were beginning the process discharging our responsibilities. There had been no new evidence that Mr. Epstein had committed any offense against a minor after 2005. The subject matter of the New York prosecution was squarely within the heartland of the Florida NPA. We had a significant motion to dismiss. This was not a futile, you know, defeatist attitude. + +19 20 21 22 Third, we had all the discovery motions that your Honor had scheduled. So the timing for a pretrial detainee to commit suicide on August 10, when his bail pending appeal motion is being filed on August 12, strikes us as implausible. + +23 24 25 Second, we had an independent doctor who was present at the autopsy which occurred on August 11. On August 11, the city medical examiner's findings were inconclusive. We are + +reasons, your Honor. + +4 5 6 told by a very experienced forensic pathologist that the broken bones in Mr. Epstein's neck, in his larynx, are more consistent with external pressure, with strangulation, with homicide, if you will, than with suicide. It doesn't exclude suicide, but the pure medical forensic evidence creates profound issues about what happened to him. + +7 8 9 10 11 Also the time opinion is it occurred of death. Our medical examiner's at least 45 minutes and probably hours before 6:30 a.m. on August 10, when he was first found, if you will, according to the reports. Yet he was moved, something that is not ordinary in these circumstances. + +12 I would also -- + +13 THE COURT: Excuse me. He was moved? + +14 15 16 17 18 MR. WEINBERG: Instead of having the cell in the condition it was found, if he had been dead for 45 minutes or two hours or four hours, there were efforts to move him and, therefore, make it more difficult to reconstruct whether or not he died of suicide or some other cause. + +19 20 21 22 23 24 25 I spoke to Stacey Richmond, who is a responsible member of this court who represents the family of Mr. Epstein. She spoke to the medical examiner on the Friday after Mr. Epstein's death and asked why, if the conclusion was made late in the afternoon on Friday that week. She specifically asked about what extrinsic nonmedical evidence caused the medical examiner to go from uncertain to suicide, and she was + +told that the medical examiner had seen nine minutes of one 4 5 video which was on a stairwell between floors at the MCC. She was told that the principal video that would have showed the whole was corrupted. It was in DC with the FBI to see if they can reconstruct it. + +6 7 8 9 10 11 12 And I asked the same questions that my co-counsel did, you know, was the dysfunction of the critical pivotal video, in the most secure prison east of Florence, out in Colorado known to the MCC before August 10, or was this corruption occurring on August 10, which would again cause us to be skeptical of the servitude of the medical examiner's conclusions that this was suicide rather than some other cause. + +13 14 15 16 17 So with my co-counsel, we ask your Honor, it is not a question of trust or not trust. They ask you to detain people and you trust the Bureau of Prisons. And it is within your inherit authority, your Honor, to find out what happened to our client. + +18 19 20 21 22 23 24 We are angry about the conditions he was held in. And we're also angry, quite frankly, your Honor, that the only source of information that we get as to what happened to him is through the media rather than through the United States Attorney's office. We've made requests informal. We have made Touhy requests. We've been told there is a pending investigation. + +25 But we trust your Honor and the judiciary, and with + +4 5 all due respect, we believe there is an inherent and central role, a pivotal role in your Honor to find out what happened to a defendant in a case before the court, whether or not the court grants the nolle pros today or whether it holds it pending an investigation into Mr. Epstein's death. + +6 7 8 9 We're not here without significant doubts regarding the conclusion of suicide. We are not here to say what happened. We don't know what happened. But we deeply want to know what happened to our client. + +10 Thank you, sir. + +11 12 THE COURT: And you, as Mr. Weingarten, have the same view of the nolle prosequi motion? + +13 MR. WEINBERG: Yes, your Honor. + +14 THE COURT: OK. + +15 16 MS. COMEY: Your Honor, may I respond to some of those points? + +17 THE COURT: Sure. + +18 MS. COMEY: Thank you, your Honor. + +19 20 21 22 23 24 Just briefly. With the exception of the noting that the defense does not have an objection to the government's motion, virtually everything else that defense counsel just argued, respectfully is completely irrelevant to the purposes of today's proceeding and to the motion that is pending before your Honor. + +25 As an initial matter, the question -- + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +THE COURT: Well, it may be. Well, I don't know. You say irrelevant. + +It is a public hearing, and I think it is fair game for defense counsel to raise its concerns. + +MS. COMEY: Certainly, your Honor. But it is irrelevant to whether or not the motion should be granted. + +THE COURT: Right. I get that. + +MS. COMEY: I would also note that the question of Mr. Epstein's death is the subject of an ongoing and active investigation, as has been publicly noted, by a separate team of Assistant United States Attorneys from the Southern District of New York, separate from the team who is handling this prosecution, as well as a separate team of FBI agents. + +There is an ongoing and active grand jury investigation into the circumstances surrounding Mr. Epstein's death. It is the function of a grand jury and of the Federal Bureau of Investigation to investigate crimes in the federal court system. It is not the purview, respectfully, of the court to conduct an investigation into uncharged matters. + +So respectfully, we disagree with defense counsel's suggestion that the court has some authority to conduct an independent investigation. To the extent any other defendants who are detained in the MCC have concerns about the conditions or believe that the conditions are relevant to a future or current bail determination, it is for those defendants and + +4 Thank you, your Honor. + +5 6 THE COURT: In those other cases, Ms. Comey, judges do have authority to investigate, but don't here? + +7 8 9 10 MS. COMEY: Not to investigate, your Honor, but to hear arguments about the conditions of confinement in the MCC as they may relate to any bail determination. I believe that was the argument that was made. + +11 12 13 14 15 The bigger picture here, your Honor, is that the focus of today's proceeding, as we understand it, is to allow the victims who have gathered here today to be heard and to comment upon the case and to comment upon the motion that is pending, and to bring this case to a close. + +16 THE COURT: Got it. + +17 MR. WEINGARTEN: May I? + +18 THE COURT: Sure. + +19 20 21 22 MR. WEINGARTEN: We obviously saw this as, perhaps, the last opportunity to be before you, and we wanted to take advantage of the opportunity to say our peace and thank you for allowing us. + +23 24 25 There is precedent here. Ted Stevens, the Senator from Alaska case in Washington, DC, Judge Emmet ordered an independent investigation by a private lawyer when + +their counsel to raise those arguments and for the judges hearing those arguments to evaluate those claims. It is not relevant to today's proceedings. + +4 5 6 7 8 9 10 It is analogous It is a situation where there was tremendous controversy over what happened in the case and whether or not the prosecutors went off the reservation. Judge -- and there were three or four independent -- not independent, DOJ inquiries into the very same matter. But Judge wanted his own opportunity to make a judgment with his own independent investigation. + +11 THE COURT: OK. + +12 13 MR. WEINBERG: If I could just add one precedent, your Honor. + +14 15 16 17 18 19 20 The Chief judge in the District of Massachusetts or the Chief Judge at the time, Judge , in a case called U.S. v. Fleming, when the conditions at Walpole, which is a state prison where federal prisoners were being held -- we don't have a federal MCC in Boston -- went to the prison, stayed in the prison to determine whether or not the complaints about the conditions were authentic. + +21 22 I think your Honor has the inherent authority to go to the ninth floor and see how the MCC houses pretrial detainees. + +23 Thank you. + +24 25 THE COURT: Are you saying that whether or not the motion is granted that is pending before us? + +he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that case, so I'm very, very familiar with it. + +4 5 6 7 8 I think, like when appeals are taken, bail issues remain before the district court. Jurisdiction is not completely divested. Your Honor issued a pretrial detention order and your Honor has the power, the inherent authority, they are not going to refuse to allow you to go look at the ninth floor. They are going to count on you to make decisions in the future. + +9 10 11 12 I just trust that the executive branch is not going to prevent the judicial branch from looking into the death of Jeffrey Epstein or the conditions in the SHU unit at the MCC, sir. + +13 THE COURT: Great. Thank you. + +14 I, your Honor? + +15 16 17 18 19 Just very briefly, your Honor. I would note that upon the dismissal of the indictment, which I believe the parties agree is appropriate in this case, there would be no case. There would be no jurisdiction for the court to conduct any sort of inquiry, even if the court had such authority. + +20 THE COURT: Right. + +21 OK. I think we've heard enough. + +22 23 24 25 It is at this point in the hearing that I would like to call upon victims' counsel, plural, for any remarks they may have and they may wish to make. Also, to introduce their clients, those of them who wish to be heard. + +MR. WEINBERG: Yes, your Honor. + +4 5 6 7 8 It would be helpful if, in doing that, if counsel -- Mr. and I see and I see Mr. Boise as well -- I know they are counsel to several, at least several of the victims. It would be helpful if whoever is speaking, both Mr. and Mr. Boise, would indicate to the court whether or not they have discussed the pending motion with their clients, that is to say and the rule of abatement, etc., etc. with them prior to today's hearing. + +9 10 Are we going to hear from Mr. first, is that right? + +11 MR. : Thank you, your Honor. + +12 THE COURT: You bet. + +13 14 It would be helpful, Mr. , if you would state and spell your name for the court reporter. + +15 16 17 If you are going to introduce someone else, which I trust that you are, if you could state and spell their name as well. + +18 MR. : Yes, your Honor. + +19 20 May it please the court. Brad , B-r-a-d E-d-w-a-r-d-s, with the law firm of Pottinger. + +21 22 23 24 25 I have in the courtroom today 15 victims that I represent and have represented over the years. There are at least 20 more who didn't make this hearing today for a multitude of reasons, some out of fear of public exposure, others because the way in which this case ended will never + +4 5 6 7 8 Some of my clients are going to address the court that are here today. Others are not. Some are going to use their names, and have in the past, and others wish to remain anonymous. And I have instructed each of them to inform the court reporter that they will be proceeding as Jane Doe so that the court reporter can take them down. + +9 THE COURT: For those who wish to remain anonymous? + +10 MR. : Exactly, your Honor. + +11 12 THE COURT: And that is satisfactory, as far as I am concerned. + +13 14 MR. : Before we do that, I would like to address a couple of the things that have occurred this morning. + +15 16 17 First of all, whether relevant or not, I personally, and on behalf of my clients, do appreciate the presentation that Mr. Weingarten made and Mr. Marty Weinberg made. + +18 19 20 21 I have tremendous respect for Mr. Weinberg. I've worked with him through this and related cases for years, and I understand the reason why they made the presentation that they made. + +22 23 24 25 There is two things of interest to our clients in that respect. One is, because of the tragic ending, that none of my clients wanted, nor did I, nor did anyone else, if there is some civil rights violation and there is some civil remedy for + +bring full justice, and they decided it was best for them not to talk today. + +Mr. Epstein that goes to the estate, certainly the victims are interested in that as they might help to repair the damage done. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Second, Mr. Epstein's untimely death, the timing is curious to us. But more so, it makes it absolutely impossible for the victims to ever get the day in court that they wanted in court and to get full justice. That now can never happen. I know that Mr. Epstein's attorneys say he wanted it, and they know, we did too. And there are a lot of people here today that are very sad by the way that this ended for both Mr. Epstein and the fact that full justice was robbed from them, once again. + +The second issue I wanted to address was the Law Review or the Law Journal article that your Honor referenced, which is troubling because the opinion seems to say that transparency is not appropriate in the criminal system and is not appropriate at this point in time. + +That's tough to swallow, especially in this case, given the long history of this case. Personally, it is tough to swallow, and on behalf of my clients, I can say that is very concerning. Transparency is the only way that the justice system works. We know this because there was a similar investigation of Mr. Epstein many years ago, from 2005 to 2008. + +My personal involvement in this case was because a young female came into my office named , and she 4 5 came to me not asking to file a lawsuit against Jeffrey Epstein, but simply asking for the government to talk to her. She was cooperating in an FBI investigation and wanted the government to speak with her, and I thought that was going to be an easy task. + +6 7 8 9 10 11 12 13 It was only a few months later that we learned that this investigation that was represented to my client in written form, that it would be a long investigation, and to be patient. Basically, to hang tight. It was resolved by way of a secret deal that never allowed any of the more than 30 victims who had been identified of Mr. Epstein's abuse in Florida to ever participate in a single hearing. There was a hearing. They were never notified. + +14 15 16 17 18 19 20 21 22 23 24 I then went on to represent many of them in civil cases and also in extensive pro bono work. And I can tell your Honor that while Jeffrey Epstein's abuse of them hurt them and harmed them for many years, the feelings they had was aggravated exponentially by the facts that they had no rights in the criminal justice system, by the fact that they were treated as if they didn't matter. They were not allowed their rights under the Crime Victims' Rights Act to meaningfully confer with prosecutors, to be treated with fairness, to be treated with dignity. That is what this is supposed to be about, and to have notice of hearings. + +25 So I do want to thank your Honor, and especially the + +4 5 6 prosecutors who have worked this investigation and this case, which is very different in experience for all of my clients and the other Epstein victims in this case, because they were allowed to be a part of the process. While some of them elected not to be here today, that opportunity should always be allowed for them. + +7 8 9 10 11 12 13 14 15 16 In 2008, we filed that case under the Crime Victims' Rights Act your Honor favor that because our clients' rights were violated, and as knows, a federal judge has ruled in our clients' their rights were violated. So this hearing today means a lot to them. The fact that they may never get their chance to speak in court, they may never get complete closure, and all of us have to wonder, if their rights had been afforded them the first time, would any of us be here right now. Or wouldn't it more likely be the case that everyone, including Jeffrey Epstein, would have turned out better for it? + +17 18 19 20 21 22 23 24 25 Today, I have not only represented, but met and become very close with many of these victims. Many of these survivors. They are very strong people. They are people who have persevered through a lot of adversity. coaster of emotions that has led us to where while they have all been cast over the years secrecy of the first investigation, in It's been a roller we are today. And because of the the shadow as victims, you can't put them all in one bucket and say one size fits all. They are each individual people who were harmed differently and + +4 5 6 And on behalf of all of them, I would like to thank your Honor for the fairness with which they've been treated, and the United States Attorney's office for the way in which you have handled this investigation, and especially how you have treated the victims in this case. + +7 8 9 Like I said, I have many who want to speak. Some that can't. This is a very difficult day for them. But we appreciate the opportunity and the invitation. + +10 11 12 The first client that I have that is going to address your Honor is the one who walked into my office in 2008 asking just to be heard, + +13 14 THE COURT: Hold on one second. Did you all want to be seated? + +15 16 17 You don't need to be standing. Whatever is more comfortable until you're ready to give some comments. It's up to you. + +18 19 , if you could spell your name for the court reporters, please. + +20 21 W -1 -d. C-o-u-r-t-n-e-y, last name + +22 (Continued on next page) + +23 + +24 + +25 + +distinctly through not only the abuse, but the system. + +4 5 6 : My name is , and I'm a victim of Jeffrey Epstein. Jeffrey Epstein sexually abused me for years, robbing me of my innocence and mental health. Jeffrey Epstein has done nothing but manipulate our justice system, where he has never been held accountable for his actions, even to this day. + +7 8 9 Jeffrey Epstein robbed myself and all the other victims of our day in court to confront him one by one, and for that he is a coward. + +10 11 12 13 14 I want to thank the U.S. Attorney's for seeking justice that has been long over due, and most importantly, given us, the victims, our day in court to speak our peace and find some sort of closure. I feel very angry and sad that justice has never been served in this case. Thank you. + +15 THE COURT: Thanks very much. + +16 17 MR. : I believe my next client who is going to speak is probably going to speak as Jane Doe. + +18 JANE DOE NO. 1: Yes, Jane Doe. + +19 20 THE COURT: We'll say Jane Doe No. 1, just for the record. + +21 22 23 24 25 JANE DOE NO. 1: Okay. Thank you for allowing us to speak today. I've shifted what I want to say in hearing what's already been said, and just about the question of Jeffrey's death. I don't know what the relevance is to this hearing, but I do know that it is profoundly relevant to my + +life, as a victim. I don't like that word, but I still feel 4 5 6 7 8 like I am learning the ways that he's impacted me as a complex situation, but he was also a major part of my life. As destructive as that relationship was and as much of a villain as we have created him to be -- based on facts we've created him to be a villain -- he's a complex villain and actually all of that is irrelevant. Anybody deserves -- an investigation is the right thing to do. Like, we do need to know how he died. + +9 10 11 12 13 14 15 16 17 It felt like a whole new trauma all over again, and I don't know why, you know, because I -- I'm trying to defend myself against him at this point in my life, but it still does not feel good. It didn't feel good to wake up that morning and find out that he had allegedly committed suicide. Okay. But I also wanted to say to the press, I'm reading -- I read my story in the paper. I read so many other girls' stories that are so similar to my own, and everything that's been focused on is not the most important part of it. + +18 19 20 21 22 23 24 25 There was -- the problem with focusing on these, the facts of the situation, that were out of the ordinary and like because he was such a grand person, and it was just a unique situation. I know that that's the more interesting side of the story, but I don't want to be used as entertainment. And the problem, the fundamental problem of the whole situation is the element of exploitation and coercion, and these are things that so many girls can relate to. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +And even though this Jeffrey Epstein brought it to a grand scale, on some level, a lot of girls could relate to the trauma that we are talking about, and even though this whole situation sucks, I would like to think that it may be possibly a catalyst for change because, obviously, as we're seeing with the "Me Too" movement, change needs to happen and it's -- what I'm seeing in the papers is not a common story, but it's so much more common than you realize. That's all. Thank you. + +THE COURT: Thank you very much. + +MR. : I believe that the next client is going to also be a Jane Doe; so I think for the purposes of the record it will be Jane Doe 2. + +THE COURT: Yes. + +JANE DOE NO. 2: Good morning, your Honor. + +THE COURT: Good morning. How are you? + +JANE DOE NO. 2: Doing okay. I hadn't prepared any words to speak today, but there is something that was on my mind this morning when I got here. It's been on my mind in reading through the press and through the people that I've spoken to about it, friends, family. It's something that's bothered me because I think it has a lot of blame in it, as well, a little bit of what my friend, who was up here, was speaking about. + +I think that a lot of people asked why we spent so much time, why we stayed. It's an experience that's really + +4 5 6 hard to explain to people who haven't gone through it. I think there's a writer, Nagel, who wrote an essay called "What is it like to be a bat?" And I think that he touches on it pretty strongly and if you haven't experienced something, it's very hard to fully understand why someone makes the decisions they do and what the circumstances were. + +7 8 9 10 11 12 13 14 15 I don't want to speak for all of the victims. I think each of us has a different story and different circumstances for why we stayed in it, but for me, I think he was really strategic in how he approached each of us. Things happened slowly over time. like that analogy turning the flame We didn't -- it almost was like, putting it of a frog being in a pan of water and slowly up. You didn't realize it was happening, and it just -- I don't think anyone can fully understand the experience, but I just -- the blame feels very strong. + +16 17 18 19 20 21 22 There's a lot of support as well, but I just want people to try and understand that we aren't bad people. We weren't trying to -- it wasn't a situation where we were trying to extort money from someone. A lot of us were in very vulnerable situations and in extreme poverty, circumstances where we didn't have anyone on our side, to speak on our behalf, and that's really scary. + +23 24 25 You start to blame yourself because, at first, you don't tell anyone what's happening, and it becomes your deep, dark secret that you tried to keep from everyone. And I didn't + +4 5 6 even know I was a victim until I spoke with my lawyers. I had no idea. I had so much self-hatred and doubt and just guilt for everything. I still do. I still don't feel like I deserve to say I'm a victim, and I think that's a big problem with our society right now, that people are still blaming victims, and I think that does need to change. + +7 8 9 I hope that today people understand that each of us has a story, has a past, has a family and just give us a chance to you know, that's basically all I just wanted to say. + +10 THE COURT: Thank you so much. + +11 JANE DOE NO. 2: Thank you so much. + +12 THE COURT: Okay. + +13 14 15 MR. : Okay. I think that the next person who is going to speak is also going to be speaking as Jane Doe; so for the purpose of the record, Jane Doe No. 3. + +16 17 18 19 20 21 22 JANE DOE NO. 3: Thank you for allowing us to speak today. I came to New York City 15 years ago to pursue modeling from a small town. I signed on with an agency and was excited to pursue my passion and my dream. Several months later, I met a female who told me about Mr. Epstein. She portrayed him as an amazing man who genuinely cared for people and that he was going to be able to help me in a modeling career. + +23 24 25 I was excited to meet him, after hearing her talk about him. He sounded like an amazing person. An introduction was made at his New York home, and it is there that I was + +4 sexually assaulted. I left his home, after he threw me, basically put money on the table, and I was ashamed. I was embarrassed. This was not the way I was brought up, and I couldn't believe this had happened to me. + +5 6 7 8 9 10 I left and my world kind of spiraled after that. I stopped going on modeling castings. I gained weight. I became depressed. I stopped going out with my friends, and only five months after I had been in New York City to pursue my dream, I left. I left the modeling industry, and I left New York City, and I totally switched my career paths. + +11 12 13 14 15 16 17 I buried this deep within me, and all of the new occurrences that have come up in the media is what brought it back up for me. And I feel sickened and saddened that it took so many years, and God knows how many victims, for this to finally come out, but I'm thankful it did. And I'm just angry that he's not alive anymore to have to pay the price for his actions. So I thank you for your time. + +18 THE COURT: You're very welcome. + +19 20 MR. : Your Honor, Jane Doe No. 4, I believe, is going to speak now. + +21 JANE DOE NO. 4: Good morning, your Honor. + +22 THE COURT: Good morning. + +23 24 25 JANE DOE NO. 4: I just have something very short to say. I met Jeffrey Epstein at a very vulnerable place in my life, and whatever the outcome is with everything, I just + +4 5 6 7 8 9 10 You know, whoever we marry in our life, whatever future we have in our life, it's always going to be something that's always there for us. And I'm very nervous right now. And Jeffrey Epstein, he took away the chance I had at having the future I had envisioned for myself as a young girl, and I think many of us here today will never fully heal from that pain and the heartache that we'll continue carrying with us. + +11 12 13 So I just wanted to say that. It's something that it's irreparable. I can't even really use a better word to describe that. So thank you for hearing us today. + +14 THE COURT: You're very welcome. + +15 16 MR. : Your Honor, Jane Doe No. 5 would like to speak. + +17 18 19 20 21 22 23 24 JANE DOE NO. 5: This is a letter that I wrote; so it's going to be: Dear Jeffrey, I think you are a mentally disturbed human being. You used your power to make me believe at a young age that I could have my dreams of being a model. You paid for your freedom. You violated my rights. You should have to pay for them, just as anyone else. You got a plea deal that no one else would have been able to get. You used your money to get out of paying the price for your actions. + +25 Also, as a victim, I never got to see what the + +wanted to express that we, the victims, we will always carry irreparable damage and pain throughout our lives after this. It's something that's never going to go away. + +4 5 6 agreement was or why the special treatment got approved. I think you should have been in jail for several years in population and live like everyone else that is mentally disturbed like you. You paid for yourself to get special treatment while you were in jail. I don't even think you spent a day in a jail as a normal human being. + +7 8 9 10 11 12 You had investigators come to my house and also went to my friend's house to question them. I will never be able to over -- I will never be able to get over the overwhelming emotions and embarrassment I experienced from that trauma. I needed therapy several times a week and had high stress and anxiety levels. + +13 14 15 16 17 18 19 20 21 You paid your way to make the public think that the girls had nothing in life going on for them. You wanted to try and blame that we were lower class and that was the problem with the girls. I was from a middle class family and did well in school. I lived the American girl dream -- or the American girl life. I went on family vacations around the world, grew up in a good city, and my parents are still married to this day. Basically, everything you said that we didn't have in our life, I did. + +22 23 24 25 It all came down to I was told I was making \$200 in an hour. Being young, that was a lot of money, and I didn't know any better. Sadly, you were the one with an illness that you should have to go and see a doctor and also have a mentor group + +4 5 6 for the sickness you have. I will continue with writing my book about that secret life, with all the newspaper articles of the case, my high school agenda book of official dates. I'm basing that proof that I deposited cash after leaving Jeffrey's. I still have all of the information, articles that I collected over the years. + +7 8 9 10 11 You mentally and physically traumatized me. I went to therapy, and it was the best thing I did for myself. If anyone only learns one thing from this case, I hope is that money should not let you buy your way free. A crime is a crime and a victim is a victim. Thank you. + +12 THE COURT: Thank you. Thank you very much + +13 14 MR. : Your Honor, my next client is C-h-a-u-n-t-a-e, , D-a-v-i-e-s. + +15 16 17 18 19 20 : I met Jeffrey Epstein through my first massage teacher, a man who took me in as his apprentice to teach me a practice I wanted to learn while in desperate search to find a cure for a debilitating neurological disorder that I have, which manifests into violent vomiting attacks, largely triggered by stress. It's called Cyclic Vomiting Syndrome. + +21 22 23 24 25 I was recruited by Ghislaine Maxwell. Upon my first meeting of her, I wouldn't know I had been recruited until many years later, when I would read it in a headline. Ghislaine and Jeffrey took me in. They sent me to school. They gave me a job. They flew me around the world, introduced me to a world I + +had only dreamt of and made me feel as though I had become a part of their family, another thing I was desperately searching for. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +But on my third or fourth time meeting them, they brought me to Jeffrey's island for the first time, and on the first night there, came tapping on my door late at night to inform me Jeffrey was ready for another massage. My instincts told me this didn't feel right, but I got up and followed her to a villa I hadn't yet seen. Jeffrey and Ghislaine's villa. + +I began my massage, trying not to let him smell my fear and obvious discomfort, but before I knew what was happening, he grabbed onto my wrist and tugged me towards the bed. I tried to pull away, but he was unbuttoning my shorts and pulling my body onto his already naked body faster than I could think. I was searching for words but all I could say was meek, "No, please stop," but that just seemed to excite him more. + +He continued to rape me, and when he was finished, he hopped off and went to the shower. I pulled my shorts up, and I ran as fast as I could back to my own villa, my feet bloodied from the rocks. I cried myself to sleep that night. + +I spent two weeks vomiting, almost to death, in a Los Angeles hospital after that first encounter. Jeffrey's abuse would continue for the next three years, and I allowed it + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +to continue because I had been taken advantage of my entire life and had been conditioned to just accept it. + +It took me a long time to come forward, too long maybe, and all it took to bring -- and all that it took to bring this man to justice has been robbed by his death. Every day, every week I've spent in the hospital since, I've suffered and he has won. Every job offer that's been offered to me and then retracted because of my connection to this case, I have suffered and he has won. Every public humiliation I have endured, I have suffered and he has won. Every relationship that I've had to end because of the abuse that I have endured by the hands of this man, I have suffered and he has won. + +Every woman sitting in this room today, and all of the women who have yet come forward and who have not yet to come forward and whose lives have been affected by Jeffrey Epstein's sick abuse of young girls, we have all suffered, and he is still winning in death. + +I refuse to let this man win in death. I couldn't fight back when Jeffrey Epstein sexually abused me because I hadn't yet found my voice. Well, I have found my voice now, and while Jeffrey may no longer be here to hear it, I will not stop fighting, and I will not be silenced anymore. I needed him to hear the pain he's caused, what I've gone through because of him. I wrote a 350-page book of all the pain that I have endured at the hands of this man that I really needed him + +4 5 MR. : Your Honor, I think I have one more client that is going to speak today, + +6 THE COURT: Would you spell that? + +7 Good morning, your Honor. + +8 THE COURT: Good morning. + +9 10 My name is spelled A-n-o-u-s-k-a, D-e, space, G-e-o-r-g-i-o-u. + +11 12 Thank you, your Honor, for giving us the opportunity to be heard this morning. + +13 THE COURT: Sure. + +14 15 16 17 18 When I was introduced to Jeffrey Epstein, I was young and full of hope and the foolishness of a teenager. I was idealistic, and I saw the good in people. Jeffrey Epstein manipulated me, coerced me and sexually abused me. + +19 20 21 22 23 24 25 Something I think is very important to communicate is that loss of innocence, trust and joy is not recoverable. The abuse, spanning several years, was devaluing beyond measure and affected my ability both in my work and fathom what he took to form and maintain healthy relationships, my personal life. He could not begin to from us, and i say "us" because I am every girl he did this to, and they're all me. And today we stand + +to hear. His death has robbed me of that justice. + +Please don't rob us of justice again. Thank you. + +THE COURT: Thank you. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +together, those that are present and those that aren't. + +I was a victim, and it has taken me many, many years Lo stand here and say, yes, it was me. I was a victim, but I will not remain a victim and be silent for one more day. Although I think it's tragic when anybody dies before their time, I'm extremely relieved that Jeffrey Epstein will not be in a position to hurt anymore children or anymore women, and I'm glad to be part of a group of women who are now bonded forever in the trauma that we endured at the hands of this man. Thank you. + +THE COURT: Thank you. + +MR. : Your Honor, we had one client who was not able to be here but sent a message through a letter. Her name is M-i-c-h-e-1-1-e; last name, L-i-c-a-t-a. And Brittany of my office, is going to read her letter as instructed. + +THE COURT: Sure. + +: Thank you, your Honor. + +THE COURT: Yup. + +: What happened to me occurred many years ago when I was in high school, but it still effects my life. I was told then that Jeffrey Epstein was going to be held accountable, but he was not. In fact, the government worked out a secret deal and didn't tell me about it. The case ended without me knowing what was going on, without him being + +4 5 6 7 8 Many years later, he was arrested again. These investigators and attorneys representing the United States have been completely different. I am still mad, concerned and confused about how he committed suicide and escaped responsibility again, but I know it is not the fault of the judge or the government attorneys. + +9 10 11 12 13 14 15 16 17 I was allowed to be a part of the process this time. My attorney was able to tell me what was going on at every stage because they kept him informed. Thank you for inviting me. It means more to me than you can ever know. I was not able to be here this time, but I know that I was allowed to be and I had the chance to attend this hearing, which is helping me in my healing process. The fact that I mattered this time and the other victims mattered is what counts. For that, I am grateful. + +18 THE COURT: Thank you. + +19 20 21 MR. : Your Honor, finally, in 2008 when I filed the case under the Crime Victims Rights Act, it wasn't me alone. I did it with Paul Cassell and Jay Howell. + +22 23 24 Paul Cassell is here today, and I think your Honor even cited to a piece of -- an opinion of his from when he was on the bench, and he has some remarks to make. + +25 Once again, your Honor, I really do believe that this + +held responsible, without any explanation and without a chance for my voice to be heard. I was treated like I did not matter. + +is a model for how victims should be treated in a criminal process, and we really do appreciate it. Thank you. + +4 5 6 7 8 MR. CASSELL: I'll be very brief because I know there are others that want to speak here. I'm Paul Cassell, C-a-s-s-e-1-1, previously served as a federal judge at the District of Utah, currently a law professor, where I teach crime victims rights at the University of Utah, College of Law. + +9 10 11 12 13 14 15 16 17 18 19 I just wanted to take one minute to address some suggestion that there would be no need for a hearing this morning. I think, having heard already from these powerful victims and recognizing how important giving those statements will be in the trajectory of their lives, makes clear that your Honor has followed exactly the right path. Legally, there is one precedent, which is U.S. v. that I wrote about a decade ago, opinion, victims have important justice system that can only be their day in court. a case that you cited and as explained in that interests in the criminal recognized if they're given + +20 21 22 23 24 25 With all due respect to other law professors that have recently written an article, I think transparency is one of the overriding objectives in our criminal justice system, and the one substantive action that I would urge your Honor to take today is to publish your remarks as a published opinion. The case is, to my knowledge, the only reported decision on + +THE COURT: Thank you. + +this particular issue, even though it's more than a decade old 4 5 and, yet, we can see today that these problems recur in many other cases. Your remarks today, I think, should be published so that they can serve as a guide for other judges around the country. + +6 7 8 9 10 11 I would encourage you to add into your remarks a reference to the Crime Victims Rights Act. The Crime Victims Right Act promises victims the right to be treated with fairness, dignity and respect, and the process that we see unfolding this morning is a clear example of how victims can be treated with fairness, dignity and respect. + +12 13 14 15 16 17 18 19 20 21 22 So I know that your Honor is wondering what is the appropriate action here. Unfortunately, it seems like there are no other legal options, but there was a legal option for you to decide to exercise, which was to allow these victims to come forward. And if there's been one positive thing that has come out of the tragedies, the abuse, the other events of this case, it's been your decision to allow these victims to be heard this morning, and I encourage you to publish your decision and to encourage other judges to follow what is clearly a model for crime victims rights and is clearly an example that should be followed in other cases down the road. + +23 24 25 THE COURT: Thank you very much. I appreciate your being here. I had no idea that you would be here when I wrote the remarks, but it was clear from the literature that you are + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +the leading expert formerly of the District Court of Utah, I believe, and it's a pleasure to have you here today. + +MR. CASSELL: Thank you, your Honor. + +THE COURT: Thanks. + +Mr. Boies? + +MR. BOIES: Thank you, your Honor. David Boies of Boies Schiller Flexner. We have with us today five of the victims that we represent. There are a number of additional victims who either were unable to attend or are still unwilling to come forward publicly. This has been an enormously traumatic aspect of their lives, something that, as you've already heard and will hear more today, is something that they can never entirely escape from. + +I want to, as prior counsel have, commend both the Court and counsel for the Department of Justice for the consideration and respect and attention that they have paid to the victims. We believe that that is not only right, as a matter of human dignity, but we think that is exactly what the law requires and intends. + +I will be more blunt than the Court has been, or Professor Cassell has been about Professor article. That is an article that cites no authority, and I believe there is no authority for his proposition. I entirely respect his right to advocate on behalf of his client Alan Dershowitz, who has retained him in connection with litigation that we've + +brought against Mr. Dershowitz, but I would have expected that the Law Journal or Professor himself would have disclosed that connection, which I think is a conflict. + +4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 But regardless of the appropriateness of his disclosure, or lack of disclosure, I think that his article opposing allowing the victims to have a voice in this proceeding is inconsistent not only with the policy that underlies the Crime Victim Rights Act and the very statute that Mr. Epstein is being prosecuted under, but it ignores the actual language of those statutes, and many other statutes, in which Congress has made clear that the purpose of the criminal law is no longer simply to punish the individual defendant, but it is to find some way of trying to mitigate the damage that has been done to the victims through restitution and economic mitigation, but also through the ability to confront and to have the court system and the justice system and the prosecutors treat these victims as they are victims, as they are human beings, and they are entitled to the respect that our society needs to give every human being. So I think that this is not only commendable, but I think it is what the law requires. + +22 23 24 25 In response to the question the Court asked, I have discussed this hearing with my clients. I have told them that, under the applicable law, the government has no alternative but to move to dismiss this case, and I believe under the + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +applicable law in this circuit, the Court has no alternative but to grant that motion. + +I think the current law is outdated, as the Court suggested in some of its remarks. I think there will come a time when either an Appellate court or the Congress will make clear that, just as it's possible to continue civil cases against someone after they have deceased, it is possible, at least for purposes of things like restitution, to continue criminal cases, but we are not there now. And, fortunately, in this case, there are other ways and perhaps even more efficient ways to vindicate the interests of the victims here. + +We greatly appreciate the remarks of the representative of the Department of Justice today, and we, too, on behalf of the victims, are not going to stop when we walk out of this courtroom. We are going to continue to seek vindication against Mr. Epstein's estate and, in some senses, perhaps even more important, against the people who worked with him and enabled him. + +As you have already heard, and will hear more, Mr. Epstein did not act alone. He could not have done what he did, on the scope and the scale of what he did, for as many years as he did it without the activities and support and the co-conspirator activity of a number of other key individuals, and those individuals also need to bear their share of responsibility, and those people need to have a reckoning as + +well. + +My partner Sig McCawley, who's been working with me 4 5 for more than five years on this case, is going to, with the Court's permission, introduce five of our clients who will speak briefly to your Court. Thank you very much. + +6 7 THE COURT: Thank you very much, Mr. Boies. Pleasure to have you here. + +8 + +9 10 MS. McCAWLEY: Thank you, your Honor, the first victim that would like to speak today is + +11 THE COURT: Can we have the spelling of your name? + +12 13 14 MS. McCAWLEY: Sure. Sigrid, S-i-g-r-i-d, and the last name is M-c-C-a-w-1-e-y, and I'm a partner at Boies Schiller Flexner. + +15 THE COURT: Thank you. + +16 : Good morning. + +17 THE COURT: Good morning. + +18 19 20 21 22 23 Court. My name is respected and listened say that I commend the Thank you, prosecutors and Judge, and the I note today I do feel to; so I appreciate that, and I have to boldness of the New York prosecutors for pursuing a man that has, you know -- and others, that have clearly taken a lot from a lot of people. + +24 25 17 years ago i knew him only as "Jeffrey." I was recruited and brought from California to New York, and that + +4 5 6 experience for the last 17 years has been a dark corner in my story, in my life, in my life story and that has been definitely made worse by my own self-shame and that -- and anger for normalizing all of the red flags. I feel like we are conditioned to do that, and that's something that needs to change. + +7 8 9 10 11 12 13 14 So I'm here today, you know, I'm coming forward because it is time to bring light to that darkness, and it's time to replace that darkness with light. And I am a survivor of this, and I do aim to progress further from being a survivor, you know. I feel I've worked hard, quite hard, to get to where I'm at now, and I'm definitely at a place in my life where I will no longer cover up. I'll no longer cover up what needs to be brought to light. + +15 16 17 18 19 20 21 22 Jeffrey is no longer here, and the women that helped him are, Ghislaine Maxwell. My experience is with Ghislaine Maxwell and , and they definitely need to be held accountable for helping him, helping themselves, helping one another carry on this huge, almost like a system. So they need to be held accountable, all of them, and I would like to see that, certainly on behalf of myself and for everyone here. Thank you. + +23 THE COURT: Thanks so much. + +24 25 MS. McCAWLEY: Our next client, who is going to speak this morning, is + +4 , that's V-i-r-g-i-n-i-a, + +5 R-o-b-e-r-t-s, , G-i-u, double F, for Fred, -r-e. + +6 7 8 9 I am a victim of Jeffrey Epstein and Ghislaine Maxwell in the dark and cruel and criminal acts they committed against me and hundreds of other girls and young women for years and years and years, unstopped. + +10 11 12 13 14 Thank you for allowing me to address the Court and speak the truth. I commend the prosecutors from the Southern District of New York for the ongoing investigation and its pursuit of justice for us victims. It has given me hope, and I will not let go of that hope. + +15 16 17 18 19 20 When I was recruited by Ghislaine Maxwell at Mar-a-Lago, just before I was 17, I thought I was given a big break, and I'd be able to reset my life and become an actual real massage therapist. My hopes were quickly dashed, and my dreams were stolen. Jeffrey Epstein is no longer alive, but this is not about how he died. This is about how he lived. + +21 22 23 24 25 He will not have his day in court, but the reckoning of accountability has begun, supported by the voices of these brave and beautiful women in this courtroom today. The reckoning must not end. It must continue. He did not act alone and we, the victims, know that. We trust the government + +: Good morning, your Honor. + +THE COURT: Good morning. How are you? + +: Okay. Thank you. My name is + +4 5 MS. McCAWLEY: The next client of ours that will be speaking this morning is + +6 7 8 : Thank you, your Honor. My name is , R-a-n-s-o-m-e. I'm a victim of Jeffrey Epstein and Ghislaine Maxwell's international sex trafficking ring. + +9 10 11 12 13 14 15 16 I would like to thank the Court for the dignity and the respect you are showing me here today, as well as the other victims. I would also like to acknowledge and extend my gratitude to the prosecutors from the Southern District of New York for pursuing justice on behalf of the victims. Please, please finish what you have started. I struggled to find the words to adequately say how important your work is to us. + +17 18 19 20 21 22 23 For a very long time Jeffrey Epstein gamed the system at every level, and when he realized he couldn't do that any longer, he showed the world what a depraved and cowardly human being he is by taking his own life. But we, the victims, are still here, prepared to tell the truth, and we all know he did not act alone. We are survivors, and the pursuit of justice should not abate. Thank you, your Honor. + +24 THE COURT: You're very welcome. + +25 MS. McCAWLEY: Our next client who is going to be + +is listening and that the others will be brought to justice. Thank you, your Honor. + +THE COURT: Thank you very much. + +4 , A-n-n-i-e, , F-a-r-m-e-r. + +5 6 7 8 9 10 I had the opportunity to speak at Jeffrey Epstein's bail hearing, and I really appreciate that you heard me and listened to me that day. I am so sorry that others will not have the opportunity to stand before him the way that I did. But I'm here today to speak on behalf of my sister, , who could not be here. + +11 12 13 14 15 16 Jeffrey Epstein, Ghislaine Maxwell not only assaulted her, but as we're hearing from so many of these brave women here today, they stole her dreams and her livelihood. She risked her safety in 1996, so many years ago, to report them, to no avail, and it is heartbreaking to her and to me that all this destruction has been wrought since that time. + +17 18 19 20 21 We were deeply disappointed and disturbed by Epstein's death and the fact that that was allowed to happen while he was in the government's custody, and I'm encouraged to hear that there will be a full investigation as to how that was allowed to happen. + +22 23 24 25 But it is extremely important, as others are saying, that he did not act alone and that the other people that were a part of what he did are held accountable and that that investigation continues. + +speaking this morning is + +: Good morning, your Honor. + +THE COURT: Good morning. + +I believe that we have a real problem in this country 4 5 6 7 8 9 10 with perpetrators of sexual abuse and sexual assault being held accountable. There are so many roadblocks to victims being heard, to cases being investigated thoroughly, and then to those cases being prosecuted. And so I think this is a really important signal to send a message to victims out there that people will take you seriously, people will follow through, and that even those in has not been often power will be held power, as we have unfortunately seen, that are able to escape that, that even those in accountable. Thank you. + +11 THE COURT: Thanks so much. + +12 13 14 MS. McCAWLEY: Our next client, who's going to address the Court is . She says it much more beautifully than I do; so I'll let her say it. + +15 16 : My first name is spelled, M-a-r-i-j-k-e; last name is C-h-a-r-t-o-u-n-i. + +17 18 19 My name is , and I am a victim of Jeffrey Epstein and the sophisticated sex trafficking operation he ran, where he allegedly was to be a financier. + +20 21 22 23 24 25 I was 20 and previously modeled and was living in the West Village. I met a young woman named Rena through a mutual friend. We were friends for a few months. She was an amazing artist and liked to party. One day she called me and asked if I was interested in meeting a friend of hers. She told me he wanted to meet me and really liked blonds, and I thought he was + +our age and liked to do the same things we did at that age; so I agreed. + +4 5 6 7 On a sunny, crisp day, we took the train together to the Upper East Side. She then began to talk a little bit about him on our way to his house. I was at his house. I was sexually assaulted by both Rena and Jeffrey Epstein in his mansion. It left me feeling both disgusted and betrayed. + +8 9 10 11 12 13 14 15 16 As we walked home to the subway afterwards, she continued to tell me about the man who had just abused me with her participation. She seemed exhilarated from the horrific experience. I was shocked and in a daze. This is a few things that she had told me. She told me he went to Union. He was a mathematical genius. That he had favorite girls that he would take to Chanel for 15-minute, all-you-can-buy shopping trips. She told me his right-hand person had connection to the arts and the fashion world, and she could help me. + +17 18 19 20 21 This is not my complete story. I'll stop here. I'm in a good, stable place in my life, and I had decided to come forward to be a voice to the victims who may not be able to tell their story, or at least not yet. I feel like I am a survivor. + +22 23 24 Thank you, Judge Berman, for inviting victims to speak today before you. We hope the government is listening very closely to the words we are saying. + +25 THE COURT: Thank you very much. + +4 5 6 MR. BOIES: I would like to express to the Court how proud I am of all of these women who have come forward. It's taken an enormous amount of strength and courage for them to do so. Thank you. + +7 THE COURT: Thanks, Mr. Boies. Hold on one second. + +8 (Pause) + +9 10 11 12 MS. LERNER: Thank you, your Honor. My name is Kimberly Lerner, of Lerner and Lerner, and your Honor, with your permission, I would like my client, Jennifer Aroz, to stand next to me. + +13 THE COURT: Sure. + +14 MS. LERNER: Would that be okay? + +15 THE COURT: Absolutely. + +16 17 18 19 20 21 MS. LERNER: Your Honor, I would like to begin by saying that I am in awe of all of these beautiful women. I just want to let you know, on behalf of Jennifer and myself, we admire you, we respect you, and we applaud you, and you are brave survivors. And Jennifer's heart is with all of you, and we thank you so much for coming forward. + +22 23 24 Jennifer, when she went public, she thought she was one of the only ones, and to see all of these faces is, I know, amazing for her. + +25 Jeffrey Epstein was a predator, a pedophile and a sick + +MR. BOIES: Your Honor, just very briefly. + +THE COURT: Sure. + +4 5 6 individual. However, he was also a thief. He stole Jennifer's childhood dreams, her innocence and her self-confidence. She was 14 years old. What he could not buy, he forcibly took. Why? Because he surrounded himself with a network of powerful people who not only looked the other way, but also actively facilitated and participated in his sexual abuse of children. + +7 8 9 10 11 Jeffrey Epstein thought he was above the law, and essentially he was until now. The system let Jennifer and the other victims down, but it does not have to end here. We ask the U.S. Attorney's Office and the FBI to bring all of Epstein's enablers and co-conspirators to justice. + +12 13 14 15 16 It has taken Jennifer 18 years to find her voice, and again, Jeffrey Epstein has tried to silence her. While she will never have her chance to face him in court, he no longer has any power over her. Today, this brave survivor will be heard. + +17 18 19 20 21 22 23 24 25 MS. AROZ: Thank you for allowing me to be able to have my chance in court today, to be able to tell you what this horrific man did to my life. You can't even imagine how much it affected my childhood, all the way through my adult life. He robbed me of my dreams. He robbed me of my chance to pursue a career I always adored. He stole my chance at really feeling love because I was so scared to trust anyone for so many years that I had such severe anxiety. I didn't want to leave my house let alone my bed. + +The fact that he felt entitled to take away my innocence, the fact that he felt that he could do whatever he wanted, regardless of the laws, hurts me so very much. It took 4 5 6 7 8 me years to tell anyone ashamed and embarrassed until I found out there what Epstein did to me because I was so at what people would say or think of me were other victims, girls just like me. I knew I could no longer keep my silence no matter how ruthless and powerful Epstein was, and still is even after his death. + +9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 The fact I will never have a chance to face my predator in court eats away at my soul. Even in death, Epstein is trying to hurt me. I had hoped to at last get an apology, but this evil man had no remorse or caring for what he did to anyone. I felt let down by the people who were supposed to watch him in prison. They let this man kill himself and kill the chance of justice for so many others in the process, taking away our ability to speak. anymore. + +Out of all the damages and side effects that Epstein caused by his heartless and selfish acts, it's very hard to put my feelings and emotions into words, trying to let his horrendous actions go and attempting to forgive him, has been so difficult for me. Yet, as hard as it's been to come so publicly forward, I refuse to let Epstein take me as a victim + +I am a survivor. The many that stand before me here today that have shared the horrific experiences with this + +4 5 deplorable human being, because even though this weak, evil coward tried to steal all of our childhoods, tried to steal all of our innocence and tried to steal all of our means of justice, he will never steal our inner strength, and he will never, ever, ever steal our voice. Thank you so much. + +6 + +7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. GIBBS: Good morning, your Honor. Teri Gibbs, T-e-r-i, G-i-b-b-s. For the record, I am a California attorney. I'm not admitted to the New York State bar. I am here to make a statement on behalf of New York attorney, Lisa Bloom. I work for her firm, The Bloom Firm. clients. + +THE COURT: You're welcome. + +Lisa Bloom represents four of Jeffrey Epstein's victims, Jane Doe 6, for the record, Jane Doe 7 and Jane Doe 8. I am so proud of all of you victims who are here today and are able to voice yourselves today. I will not and cannot comment on the criminal case, or Ms. Bloom's communications with her + +Ms. Bloom would like to share three of her client's statements for the record. Here are the statements. Statement of Jane Doe 6. + +To the Honorable Richard M. Berman. Jeffrey Epstein stole my innocence. He gave me a life sentence of guilt and shame. I do not consider myself a victim. I see myself a survivor. The abuse that I endured cannot continue. Let's stop this before it happens to other young women. Jane Doe. + +4 5 6 7 Statement of Jane Doe 7. To the Honorable Richard M. Berman. I used to be relatively carefree, inquisitive, hopeful and excited about life, but my life changed because of Jeffrey Epstein. My perspective on life became very dark when I was unknowingly recruited by one of his agents. Jeffrey Epstein ruined me. His recruiter ruined me. The far-reaching consequences of that day ruined my family's lives. + +8 9 I've chosen to remain anonymous in order to protect my family from unwanted media attention. + +10 11 12 13 14 15 16 I was just trying to figure out my path in life when I encountered Jeffrey Epstein in his New York City mansion. I cannot even begin to summarize the many detriments this experience of sexual assault has had on my life. Immediately following the incident, I was unable to function and be around other people. My parents had to rescue me and bring me home, where I became a recluse for years. + +17 18 19 20 21 22 23 24 25 I was changed forever and buried my assault deep down, where the darkness couldn't hurt me anymore, but of course, it has always been here, lingering and affecting me unconsciously. At the time, I was mired in shame, guilt and humiliation. I had somehow tricked myself into thinking that I had allowed the assault to happen, that I did it to myself, that I don't deserve to be alive or to be loved. I believed that I was a disgusting, shameful person who does not deserve to ever be happy. These are the thoughts I've lived with on a daily + +basis. + +4 5 6 Furthermore, because I couldn't tell anyone, out of fear of judgment, blame or retaliation, keeping this secret completely hindered my ability to uncover why these issues existed for me, which could have led to a path of healing over the years. + +7 8 9 10 11 12 13 14 It is time for those of power to do the right thing. It is time for compassion toward our fellow human beings to reign over money, power and greed. We need to protect our most vulnerable to allow them a chance at a normal life, and nothing should come in the way of that. I believe that for future generations, including my own children, this case will set a precedent that victims must no longer suffer in silence on our own or be shamed for coming forward to seek protection. + +15 16 17 18 19 This case should demonstrate to those who want to harm others that there will be a reckoning, and they will pay dearly for the harm they inflict on innocent people. Judge Berman, I thank you for from the bottom of my heart for this forum and opportunity. + +20 21 22 To all of those survivors who came before me, I commend your bravery. There is no way I could have done this without you. + +23 24 25 Thank you to the public following this story, for your outrage and desire for answers, which will hopefully move this case forward so that victims can stop having to relive their + +experiences every day and move on to begin to heal. + +God bless the victims, their families, the investigators and public servants working so diligently to find those answers and to right all these wrongs. Jane Doe 7. + +(Continued on next page) + +4 5 6 7 In the past few weeks, I have had to reflect on my interaction with Jeffrey Epstein and realized that, though I have yet to put it all behind me, I am still a victim. I say this because I have to come to terms with it in an effort to truly get past the abuse I suffered at the hands of Epstein. + +8 9 10 11 12 Pursuing criminal penalties against him and having an opportunity to address the egregious crimes he committed against me and other young woman would have helped my recovery process. This all came to an abrupt halt when he took his own life. This point of disclosure is lost. + +13 14 15 16 17 18 19 20 I cannot say that I am pleased he committed suicide, but I am at peace knowing he will not be able to hurt anyone else. However, a sad truth remains. I, along with other people, will never have an answer as to why. I will never have an apology for the wrongdoing. And most importantly, Epstein will not be justly sentenced for his crimes. Now I sit in my home questioning the well-being of those girls like myself. In choosing death, Epstein denied everyone justice. + +21 22 23 24 25 Any efforts made to protect Epstein's name and legacy send a message to the victims that he wins and that he is untouchable. I understand his case may be dismissed or closed, but this makes me feel as though I, and anyone else who fell pry to his hands, simply do not matter. + +THE COURT: Thanks very much. + +MS. GIBBS: One more. Statement of Jane Doe 8. + +I ask that you very seriously consider the final 4 5 6 7 8 9 decision, because it will undoubtedly affect all other facets of this case, including any future charges brought against the recruiters or third parties to his crimes. I do not want the narrative to be, Those poor girls. I want to send a message to anyone who would consider engaging in similar acts to think twice beforehand. I want some sort of closure for those of us who relive those horrible moments where we were assaulted, abused, and taken advantage of by Epstein. + +10 11 12 13 You have the opportunity to help us seek that closure. I appreciate your time and consideration and ask for your continued support in dealing with this case to illustrate that we, Epstein's victims, do matter. + +14 Sincerely, Jane Doe 8. + +15 16 On behalf of Lisa Bloom and The Bloom Firm, thank you, your Honor. + +17 THE COURT: Thank you, Ms. Gibbs. + +18 Did we have any other victim's counsel or victims? + +19 Ms. Allred. + +20 MS. ALLRED: Good morning, your Honor. + +21 THE COURT: Good morning. How are you? + +22 MS. ALLRED: Fine. Thank you. + +23 Allred, Maroko & Goldberg by Gloria Allred, + +24 G-1-o-r-i-a A-1-1-r-e-d. + +25 Your Honor, thank you so much for this opportunity to 4 5 afford the victims their voice, because many of them have never spoken before. They never spoke in Florida. They never spoke anywhere. They never told their mother. They never told their father. They never told their family members. This is an opportunity for them to be heard. We thank you for that. + +6 7 8 9 10 11 12 13 14 15 Your Honor, for 43 years my firm has been the leading women's rights private law firm in the United States. We have helped thousands of victims. And I, as an officer of the court, and as a believer in the system, have tried to encourage the victims to have confidence in the system that should provide them access to justice that should help them to assert and vindicate their rights in a court of law. It has been increasingly difficult in this case for me to say to my clients that they should have confidence in the system of justice given what has occurred in this case, People v. Jeffrey Epstein. + +16 17 18 19 20 Having said that, I am encouraged by the fact that this court, essentially, in an unprecedented situation where the defendant is deceased, is still affording these victims an opportunity to be heard. So we thank you for that. It is some encouragement. + +21 22 23 24 25 Your Honor, you also asked do our clients wish to be heard in reference to some of the issues that have been raised this morning, including what should happen into this case. Your Honor, there has been a suggestion that the court should investigate the circumstances of the death of Mr. Epstein. I'm + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +not going to repeat the arguments made by counsel, but I would say that if there is jurisdiction, and I know that is a legal issue which has been previously argued, that certainly it would increase the confidence of my clients. Not just my clients, but victims all over, and some are, by the way, located in other parts of the world, to have the court oversee the investigation. + +We are encouraged by the sensitivity of the attorneys for the United States Attorney's office for the Southern District of New York and the investigation that is going on with the separate team. However, and, of course, the defense is also conducting its own investigation. But I do think the greatest confidence would be if the court in some way would be able to oversee an investigation because the court is a neutral party. And although the court certainly has a stake in finding out what happened to defendants who are in the custody of the federal system and who should be there to face the prosecutors and the charges against them, but now are not because clearly the system has failed. + +And the United States Attorney has admitted that, and even before he admitted that, everybody knows the system failed. Failed the victims, failed the court, failed everyone. + +In any event, your Honor, having seen so many thousands of victims of gender violence, sex harassment, sexual assault, I've dealt with child sex trafficking, child + +4 molesters, I mean, this is a unique case because there are so many victims and so many failures of the system. At this point, what we would really ask for is not just words, but words have been helpful, but deeds, and that is very important. + +5 6 7 8 9 10 In addition, I would like to say, throughout this case is the running theme of the betrayal of trust. Betrayal of trust by Jeffrey Epstein. Betrayal of trust by the system. And betrayal of trust to the victims who had a right to justice. And the Crime Victims' Act should not just be words, it should have meaning and it should be enforced. + +11 12 13 14 15 16 17 18 19 20 21 22 23 24 In essence, we are asking, although you may need to, of course, grant this motion to dismiss, I think because the court has shown sensitivity to victims and victims' needs, if there is a way to at least keep the record open so that victims who have not been able to be physically present in the courtroom today and who have not been able to submit to the court any letters, victim impact, and who have not been able to secure attorneys or speak to attorneys yet -- so, for example, I'll still hearing from victims who I have not been able to meet with yet because they just recently are now contacting me -- so if they could submit, at least for the record, their victim impact statements, that, I think, would be a very important assistance to them. So that would be, at least they would know that what they are sharing is on the record. + +25 So, in summary, I would say that they are looking + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +forward to the very serious investigation by the United States Attorney of who may have conspired in this case, and that is very hopeful, and we're hoping that everyone who may have a role to this criminal prosecution will submit that evidence. + +This is about power. This is about many victims having lived in fear -- fear of the rich, the powerful, the famous, fear that the system will not afford them justice. So fear of not coming forward. And fear, of course, is a weapon that the rich, powerful, famous, and sexual predators used to silence the victims. But that is gone for a lot of victims because they refuse to suffer in silence. + +Finally, it does take courage to speak truth to power. We thank this honorable court for giving these victims a voice. We thank them, even after the death of the defendant, for showing respect for the victims, allowing them dignity, allowing them a voice. We do want truth, we do want justice, we do want accountability, and we do want those conspirators to face the justice system. + +Your Honor, right now we have two of our clients who would like to address the court. + +THE COURT: Sure. + +MS. ALLRED: Then I have a couple of statements on victims who do not wish to address the court. + +As they come up, we'll give them the opportunity to say either their name or Jane Doe. + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +By the way, thank you, your Honor, for allowing some of these victims to be called Jane Doe. What number the court affords to them, we'll accept whatever that is. + +Thank you. + +THE COURT: We're up to nine. + +MS. ALLRED: Thank you. + +: Hello. My name is . That is T-e-a-1-a D-a-v-i-e-s. + +I was going to start this statement by saying that I was a victim of Jeffrey Epstein. But that's not the case. I'm still a victim of Jeffrey Epstein. I'm still a victim because the fear of not being heard stopped me from telling my story for so many years. This lingering fear almost stopped me from attending this monumental movement of strength and power. + +I'm still a victim because I am fearful for my daughters and everyone's daughters. I'm fearful for their future in this world, where there are predators in power, a world where people can avoid justice if their pockets run deep enough. + +I'm still a victim because the 17-year-old Teala was manipulated into thinking she had found someone who cared, someone who wanted to help. Jeffrey knew I had nowhere to go. He knew I was vulnerable, and he took advantage of that poor girl, who will never be the same. + +I cannot eat at the thought that Jeffrey Epstein -- I + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +cannot eat at the thought of Jeffrey Epstein not serving the time he needed to realize the pain and suffering he caused so many vulnerable young girls. He thought he was untouchable, and honestly, so did I. I thought he was the most powerful person I would ever meet. + +But the end is here and here I stand becoming more powerful than he will ever be. Thank you. + +THE COURT: Thank you. + +JANE DOE: Jane Doe. + +Um, in 2004, when I was 15 years old, I flew on Jeffrey Epstein's plane to Zorro Ranch, where I was sexual molested by him for many hours. What I remember most vividly was him explaining to me how beneficial the experience was for me and how much he was helping me to grow. Yikes. + +I remember feeling so small and powerless, especially after he positioned me by laying me on his floor so that I was confronted by all the framed photographs on his dresser of him smiling with wealthy celebrities and politicians. + +After he finished with me, he told me to describe in detail how good my first sexual experience felt. That was the first of many lies I was forced to carry for him, the weight of which proliferated my trauma. I felt powerless not merely because one man wanted to strip me of my innocence, but because I was the victim of a system that just enfranchises human beings, making them vulnerable to pedophilic exploitation. + +4 5 As unjust as what happened to me was, I believe that experience to be a symptom of insidious and pathological violence that extreme wealth yields, a violence which ultimately stays hidden through channels of extreme power that serve it. + +6 7 8 9 10 11 I first identified with this feeling the night after I was molested by Epstein, when another girl and I took out two of his ATVs and raised them across the mesa. I crashed mine and expressed my concern to the other girl of getting in trouble, which she replied to me, Don't worry, no one gets in trouble for anything here. + +12 13 14 15 16 Even as a child, I understood, in a sad and precocious way, what I hoped we have the ability of changing now. Even though Epstein is dead, there is still justice to be brought for the crimes we felt powerless against concealing for him and the system that supported him for all these years. + +17 Thank you. + +18 THE COURT: You're very welcome. + +19 MS. ALLRED: Thank you. + +20 21 22 Your Honor, may it please the court. I would like to read a statement for Jane Doe, my client, who is present in court, but requested that I read it. + +23 24 25 We only have one opportunity at childhood. One opportunity to develop. One opportunity to find direction for our lives. Jeffrey Epstein robbed and denied me at each + +4 5 6 I came from a small Texas town, not far from the New Mexico border. My mother died when I was 11, after suffering from cancer for many years. My father was devastated, as were my siblings and I. My father was saddled with debt. My only hope for college was to get a scholarship. + +7 8 9 10 11 12 13 When I was 15, I was a blossoming freshman in high school and was trying to carry on my mother's dream. She wanted me to the violin. After school, I would often go to a mall in a nearby city. A lady approached me and saw I had a violin case with me and asked if I was any good. We talked about the violin, my family, and why I had clothes that looked like hand-me-downs. + +14 15 16 17 18 19 The lady told me she works for a very rich man who had a home close by and that he would pay to hear me play. I was told that if I could get away, she could arrange for transportation to and from his place and have me back before anyone knew I was gone. After some hesitation, I agreed. This decision was the beginning of the end of my childhood. + +20 21 22 23 24 The man who only identified himself as J or Jeff had asked if I would give him a massage, and over four visits, eventually progressed to forced oral copulation. The money he gave me further placed my young soul into a perverse sense of hell. + +25 I was so utterly disgusted with myself and what he did + +opportunity he had. + +4 5 6 7 8 9 Epstein targeted and took advantage of me, a young girl, whose mother had recently died a horrific death and whose family structure had deteriorated. His actions placed me, a young girl, into a downward spiral to the point where I purchased a gun and drove myself to an isolated place to end my suffering. + +10 11 12 A voice that could only have been from my mother told me, quote, I am not the victim, I am the victor, and I dare not pull the trigger." I returned the gun days later. + +13 14 15 16 17 Epstein is a coward. He lived his life leaching off the souls of inspiring, young girls due to the fact that he could never know how it feels inspired to live. Like a leach, once Epstein had his fill, he would unlatch and seek out another victim. + +18 19 20 The only sense of justice I had hoped to see was Epstein being sentenced. However, Epstein died as he lived, taking the easy way out without any responsibility. + +21 22 Your Honor, the next statement is also a statement of a Jane Doe. May it please the court. + +23 24 25 I was a 16-year-old virgin when Jeffrey Epstein first raped me. I was naive and gullable. He was a pillar of finance and a giant in the world that I was an insignificant + +to me that I stopped going to see him. I had documented the events with a Texas rape crisis center about the man I know now as Jeffrey Epstein. + +4 part of. I was so impressed that this great man would even talk to me and impart any of his wisdom on me. I gladly jumped at the chance to meet him again, when he told me how impressed he was with my personal story and maturity for my age. + +5 6 7 8 When I was in his presence, he made an effort to call celebrities and influential people on speakerphone, like Academy Award-winning actresses and super models, who always answered his calls. Sadly, I was impressed. + +9 10 11 12 13 14 15 16 He was friends with former and future heads of states and every other fixture in the New York social scene and beyond. He knew important people in my own world that I looked up to and revered, but he spoke about them like they were sweet distractions far beneath his stature. He could easily reach down from his position and influence the people directly involved with my daily life and future prosperity. I was the perfect victim. + +17 18 19 20 21 22 23 24 My whole life was extremely turbulent. But one of my mother's greatest wishes was that all her children would graduate from respectable universities. He promised me that he would write me a letter of recommendation for Harvard if I got the grades and scores needed for admission. His word was worth a lot, he assured me, as he was in the midst of funding and leading Harvard's studies on the human brain, and the president was his friend. + +25 The fact that all of you already know these next + +details, which I'll share, should ignite fire instead of induce 4 the complacency they did in the past, when heard repeatedly over the years, but yes, an innocent massage turned sexual almost immediately. + +5 6 7 8 9 10 11 12 "Here, come. Come help me with a kink in my shoulder while we finish our discussion." A large vibrator and a couple of hundred dollars, disgust and dirty secret, more praise and imparted wisdom from a godlike figure, a deliberate diabolical depression of grooming and submission for his pleasure and release. Even if I resisted, I was no match for him. I felt powerless, ashamed, and embarrassed. I wanted to vomit remembering these moments. + +13 14 15 16 17 18 19 What I learned in those depraved sessions, staring up at the dome ceiling in his private massage room, tore a violent hole through any normal sexual awakening. I'm haunted forever, having learned everything there is to know about sex through a vile criminal. Every time a new molestation would bring a new lesson, the progressive and constant unwinding. I was nothing more than a teenage prostitute. I was his slave. + +20 21 22 23 24 25 I had never even kissed a boy before I met him, and never throughout the horrific abuse did Jeffrey Epstein kiss me even once. When he stole my virginity, he washed my entire body compulsively in the shower and then told me, "If you're not a virgin, I will kill you." And then I wasn't a virgin anymore. + +4 5 He forcefully penetrated me. I was numb. There was pain, but his use of the vibrator and his fingers in previous sessions with me had left a black hole-like void between my legs. I protested, but he forced my face into the bed to stifle my cries. That was my first time. + +6 7 8 9 10 11 12 I got a few hundred dollars, as usual, as he led me out of his mansion with assurances that I was on the right path guided by him. I lied to myself and tried to believe him. I became a hollow shell. If I missed an appointment, he threatened me and let me know who was in charge. "Do you know how important my time is? I'll bury you. I owe this -- I won't say the word -- F'ing town." He would hang up. + +13 14 15 16 17 18 I would stand there frozen in the street, terrified that his assistant would call to reschedule. I made sure to stay in line and not disobey him. I was in complete denial. Being paid after every scheduled meeting felt routine and disgusting. He was the of the universe and the world bent to his will. + +19 20 21 22 23 24 25 He would eventually brag to his assistants about my ability to please him sexually right in front of me, leaving me feeling grotesque and worthless. Everything in my outside life was falling apart. I distanced myself from friends and grew further away from my family. I felt less human after each ordeal. My psyche broke down completely and wouldn't let me continue. + +4 5 One day I walked out of his residence and passed a girl similar to myself. When I turned around, she was entering Jeffrey's residence. He no longer even tried to schedule his appointments with other girls in secrecy from me. Maybe he never did. I was too stupid to see. + +6 7 8 9 10 11 12 13 My world shattered. I had been so naive. I had an epiphany in a calvary of desperation. I realized I was just one of many young girls he had in rotation come to perform for him for money. I went into a deep depression and never lifted completely. I wanted to inflict pain on myself. I was humiliated, angry, and suicidal. I locked myself away from everything. I cut myself off forever from the world I had known. + +14 15 16 17 I endured the daily agony of knowing my life would never be the same. I could never go back to New York City and the wonderful life I had taken for granted before I met this demon named Jeffrey Epstein. + +18 19 20 21 22 23 This creature had manipulated and outwitted the whole system, including some of the most intelligent scientists, political people, prosecutors, and power players. How easy was it to manipulate a 16-year-old virgin who never had a boyfriend and came from a background of hardship with no parental guidance or support. + +24 25 I went to therapy and was given antidepressants for severe anxiety and depression. My only solace, years later, + +was my desire to succeed on my own terms. I emersed myself into my studies and was accepted to every college I applied to, 4 5 graduating from a top university. To this day, there is still an ache in my being that I did not apply to Harvard in fear of his influence there. + +6 7 8 9 They say you never forget your first. I'm in a never-ending nightmare trying to do just that. I'm forever suffering because everything reminds me of that horror. This new wave of worldwide publicity only worsens my despair. + +10 11 12 13 14 It was only many years later that I was finally intimate with a man again, and those moments were marred by my actions as a child with Jeffrey Epstein. Even now is impossible to separate his treachery from any care of a good man. + +15 16 17 18 19 20 21 For one brief moment there was elation when he was recently arrested. I would finally get my chance to see him again face to face and show him what I had become, that I had succeeded on my own, that I was worth something in spite of his abuse, and that I had surmounted the monumental obstacles he laid before me throughout my entire life since falling prey to him. + +22 23 24 25 I had hoped humanity would prevail, but it seems to me that he outsmarted everyone so far, and his ghost is still laughing at us. I appeal to all of those just and true that his evil legacy and his death not stand in the way of + +resolution and justice for all of his underaged victims. + +4 Statement of Jane Doe, also my client. + +5 6 7 8 9 I was a model in another country when I came to the United States. I was told by a booker that I needed to meet with a man named Jeffrey Epstein, who was the owner of Victoria's Secret. The booker told me that Mr. Epstein could help me get into Victoria Secret's world. + +10 11 12 13 14 15 It was my childhood dream to be a Victoria's Secret model. So I went one day in the afternoon and I met Mr. Epstein in his office in his mansion in New York. A woman introduced herself and suggested to me that I should be extremely nice to Mr. Epstein, because if he liked me, he would probably have photographers shooting photos of me right away. + +16 17 18 19 20 The told me to go upstairs and directed me to Jeffrey Epstein's office. Mr. Epstein had a robe on and we chatted very briefly. I had my portfolio of photos, but he didn't even look at it. Suddenly, he took his robe off and got close to me. I got up to leave, but the door was locked. + +21 22 23 24 25 I didn't know what was going on. It was my first official meeting to be cast in the United States. I was a young girl and confused. He got very close to me, and I had a skirt on. He started to touch my genitals. I refused him. Then he went to the massage table and showed me the vibrator. + +Thank you, your Honor. + +And then just one last one, and this is much shorter. + +4 5 6 7 At that point, I ran to the door again and figured out now to get out of there. A girl outside asked me where I was going and she said to be careful. She said that Mr. Epstein knew a lot of powerful people, including Bill Clinton, and that if I didn't do what Mr. Epstein wanted, I would not be able to have any job in the industry. + +8 9 10 11 12 I was so scared. I couldn't wait to get out of there, and I left. I took the train home. I had spent all of my savings getting Victoria's Secret lingerie to prepare for what I thought would be my audition. But instead, it seemed like a casting call for prostitution. I felt like I was in hell. + +13 Thank you, your Honor. + +14 Thank you. + +15 THE COURT: Thank you, Ms. Allred. + +16 17 Was there anybody else, any victim's counsel or any of the other victims who have not been heard and wish to be heard? + +18 19 20 21 22 Well, OK then. All I have to say, really, is thank you, all of you, for your participation in today's remarkable hearing. I think everybody has benefited greatly from your input, and especially from the testimony of victims here today and who have had the courage to come forward. + +23 24 25 We have also benefited throughout these proceedings, however brief altogether, from the attorneys' legal advocacy and their written and oral submissions. 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+Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting the transcript is a judge or a member of the public or media. + +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically available to the public without redaction after ninety (90) calendar days. + +This process may only be used to redact the following personal data identifiers: Social Security numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information may proceed by motion. + +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. + +/s PRATER + +Court Reporter/Transcriber Date \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824603/EFTA02824603.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824603/EFTA02824603.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1b8ef0a66ead4f3613df3927bf653109c97b166f --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824603/EFTA02824603.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824603.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1433, + "elapsed_seconds": 0.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "IN THE UNITED STATES DISTRICT COURT \nFOR THE SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 153.612, + 67.23 + ], + [ + 418.71282958984375, + 67.23 + ], + [ + 418.71282958984375, + 96.363037109375 + ], + [ + 153.612, + 96.363037109375 + ] + ] + }, + { + "title": "NOTICE OF FILING OF OFFICIAL TRANSCRIPT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 167.688, + 308.61 + ], + [ + 448.52362060546875, + 308.61 + ], + [ + 448.52362060546875, + 322.4830627441406 + ], + [ + 167.688, + 322.4830627441406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 26 + ], + [ + "Text", + 15 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824603" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824604/EFTA02824604.md b/marker2/court-us-v-epstein-cr/EFTA02824604/EFTA02824604.md new file mode 100644 index 0000000000000000000000000000000000000000..00cc282cbf0371a0acf27201c944ea4a25c8d6ea --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824604/EFTA02824604.md @@ -0,0 +1,41 @@ +## FORDHAM + +University + +Lincoln Center, 150 West 62nd + +Bruceir Louis Chair 0. 2(I') + +Hon. Richard M. Berman + +U.S. District Court + +for the Southern District of New York Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +School of Law + +Phone: 212-636-6851 Fax: 212-636-6899 bgreen@law.fordham.edu + +-DTVVIV1 + +SEP 04 2019 + +nic.. OF + +.K4AN + +••••• + +re: \_United States v. Epstein. 1:19-cr-00490-RMB + +Dear Judge Berman: + +Yesterday, I was provided a partial transcript of the August 27, 2019 hearing in the abovecaptioned case, and I am writing to clarify the record. + +As you know, I co-authored a New York Law Journal article before the hearing. The transcript quotes the court, in pertinent part, as follows with reference to me and the article: "On a somewhat more serious note, don't quote me on this, but it is my understanding that one of the authors of that article is himself counsel in one of the Epstein-related cases. I was surprised to learn that very recently. I'm certain it is true. I was also surprised that that aspect was not disclosed in the Law Journal." Later in the hearing, attorney David Boies made comments consistent with those of the court. + +Just to clear up the evident misunderstanding: I have never been counsel to Epstein or his estate or to anyone in an Epstein-related case. I did serve as an expert witness, by way of ex .r leclaration, in support of Professor Dershowitz's motion to disqualify Mr. Boies and his law firm in v. Dershowitz,1:19-cv-03377 (SDNY), a pending defamation case that might be described as "Epsteinrelated." My work as an expert witness, which concluded in June, did not involve my representation of, or advocacy on behalf of, Professor Dershowitz. I did not serve as counsel or as an advocate on anyone's behalf in co-authoring the law journal article. + +Very truly yours, + +Bruce A. \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824604/EFTA02824604.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824604/EFTA02824604.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..24e4adb113d37fe6e8501eb81755b0178e1daf42 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824604/EFTA02824604.metadata.json @@ -0,0 +1,82 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824604.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1864, + "elapsed_seconds": 0.94, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FORDHAM", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 52.63199999999999, + 52.650000000000006 + ], + [ + 161.8096160888672, + 52.650000000000006 + ], + [ + 161.8096160888672, + 74.918212890625 + ], + [ + 52.63199999999999, + 74.918212890625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 92 + ], + [ + "Line", + 43 + ], + [ + "Text", + 24 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824604" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824605/EFTA02824605.md b/marker2/court-us-v-epstein-cr/EFTA02824605/EFTA02824605.md new file mode 100644 index 0000000000000000000000000000000000000000..b1232ce965a34aa80ef02db2b7da3f39376df1be --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824605/EFTA02824605.md @@ -0,0 +1,25 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES COURTHOUSE 500 PEARL STREET NEW YORK. NEW YORK 10007 (212) 805.6715 + +OF RICHARD M. BERMAN UNITED STATES DISTRICT JUDGE + +> Bruce A. Louis Chair Fordham University School of Law 150 West 62nd Street Room 7-168 New York City, NY 10023 + +Dear Professor M, + +![](_page_0_Picture_3.jpeg) + +September 4, 2019 + +Thank you for your letter of August 30, 2019.1 appreciate your taking the time to clarify the record. + +I learned that you had been "retained to provide opinions as an expert on legal ethics" in v. Dershowitz lowing the August 27, 2019 public hearing in US v. Epstein. I learned o your role in the case by reading your affidavit, dated June 7, 2019, which includes your legal ethics opinion that David Boies should be di ualified from representing in that matter. As you are aware, both Mr. Boles and were invited to testify at the August 27, 2019 hearing. + +I remain surprised that your advocacy of Mr. Boies' disqualification from representing Ms. Guiffit (in a case obviously related to US v. Epstein) was not disclosed simultaneously with your August 26, 2019 Law Journal opinion piece entitled "The Judge in Epstein's Case Should Not Turn the Dismissal Into a Drama for the Victims." I am also surprised that you would find the August 27, 2019 public hearing to be an inappropriate occasion for transparency in light of Federal Rule of Criminal Procedure 57 and the Crime Victims' Rights Act, 18 U.S.C. § 3771. You wrote: "This is an odd moment for transparency in a criminal case." + +Final) it is unfortunate that your opinion piece may have been construed as an effort to chill and Mr. Boies' right to be heard under 18 U.S.C. § 3771 at the August 27, 2019 public hearing. You wrote: "[W]hatever informational interests the victims may have would be served by affording them a chance to attend the hearing, not by giving them a speaking role." + +Sincerely, + +Richard M. Berman U.S.DJ. + +cc: AUSA Maurene Comey; G. Weinberg, Esq.; Reid Weingarten, Esq.; David Boies, Esq. \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824605/EFTA02824605.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824605/EFTA02824605.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e9a2a1151dd1d7c5cdf1007a9accb0b9d42d6b82 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824605/EFTA02824605.metadata.json @@ -0,0 +1,130 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824605.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2047, + "elapsed_seconds": 0.72, + "image_assets": [ + "_page_0_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK \nUNITED STATES COURTHOUSE \n500 PEARL STREET \nNEW YORK. 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Richard M. Berman + +NOTICE OF WITHDRAWAL OF GLORIA ALLRED AND ALLRED, MAROKO & GOLDBERG OF REPRESENTATION OF THE SECOND OF THREE JANE DOES WHOSE VICTIM STATEMENTS WERE READ BY GLORIA ALLRED ON AUGUST 27, 2019 + +[Jane Doe appearing on Page 76 Line 20 through Page 78 Line 20 in the official transcript of the August 27, 2019 Victim Impact Statement hearing] + + Gloria Allred and Allred. Maroko & Goldberg hereby inform the Court that they no longer represent the third of four Jane Does who were represented by Gloria Allred and Allred, Maroko & Goldberg, and whose Victim Impact Statement was read into the record during the August 27, 2019 hearing before the Honorable Richard M. Berman. The Notice of Withdrawal is only as to the Jane Doe whose statement appears on Page 76, Line 20 through Page 78, Line 20 of the August 27, 2019 Transcript of Proceedings. Gloria Allred and Allred, Maroko & Goldberg continue to represent the other three Jane Does whose Victim Impact Statements appear on Page 75, Line 9 through Page 76. Line 17, Page 78, Line 21 through Page 84, Line 2, and on Page 84, Line 4 through Page 85, Line 12. + + ALLRED, MAROKO & GOLDBERG GLORIA ALLRED + +B : \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824607/EFTA02824607.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824607/EFTA02824607.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..dd0f797df1c761bc5259e1617b722f094d8ebe05 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824607/EFTA02824607.metadata.json @@ -0,0 +1,120 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824607.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1367, + "elapsed_seconds": 0.73, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 100.3800048828125, + 94.656 + ], + [ + 314.9440000000001, + 94.656 + ], + [ + 314.9440000000001, + 121.843017578125 + ], + [ + 100.3800048828125, + 121.843017578125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 105 + ], + [ + "Line", + 53 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 87 + ], + [ + "Line", + 44 + ], + [ + "Text", + 19 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824607" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824609/EFTA02824609.md b/marker2/court-us-v-epstein-cr/EFTA02824609/EFTA02824609.md new file mode 100644 index 0000000000000000000000000000000000000000..45e4acae12d368b3529cfff594baf0df854ff03c --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824609/EFTA02824609.md @@ -0,0 +1,19 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America + +v. + +Jeffrey Epstein, + +Defendant. + +1:19-cr-490 (RMB) + +## NOTICE OF APPEARANCE + +The undersigned attorney respectfully requests the Clerk to note his appearance in this case and to add him as a Filing User to whom Notices of Electronic Filing will be transmitted in this case. 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As the Memorandum concluded, no such evidence was uncovered during the review. + +Since July 6, 2025, there has been extensive public interest in the basis for the Memorandum's conclusions. While the Department of Justice and Federal Bureau of Investigation continue to adhere to the conclusions reached in the Memorandum, transparency to the American public is of the utmost importance to this Administration. Given the public interest in the investigative work conducted by the Department of Justice and Federal Bureau of Investigation into Epstein, the Department of Justice moves the Court to unseal the underlying grand jury + +t https://www.justice.gov/opa/media/1407001/dl?inline. + +transcripts in United States v. Epstein, subject to appropriate redactions of victim-related and other personal identifying information.2 The Department will work with the United States Attorney's Office for Southern District of New York to make appropriate redactions of victim-related information and other personal identifying information prior to releasing the transcripts. Transparency in this process will not be at the expense of our obligation under the law to protect victims. + +1. On July 2, 2019, a grand jury sitting in the Southern District of New York returned an indictment charging Epstein with sex trafficking offenses. See Dkt. No. 2. On August 10, 2019, while awaiting trial, Epstein committed suicide in his cell in the Metropolitan Correctional Center in New York City. Soon after, the Court dismissed the indictment. Dkt. No. 52. + +2. On June 29, 2020, a grand jury sitting in the Southern District of New York charged Epstein's longtime confidant, Ghislaine Maxwell, with numerous offenses related to the trafficking and coercion of minors. See United States v. Maxwell, 1:20-cr-330, Dkt. No. I (S.D.N.Y. June 29, 2020). In December 2021, a jury found Maxwell guilty on several counts. Maxwell was sentenced to 240 months' imprisonment, and the Second Circuit later affirmed her convictions and sentence. See United States v. Maxwell, 118 F.4th 256 (2d Cir. 2024). + +3. On July 6, 2025, the Department of Justice and Federal Bureau of Investigation announced the conclusion of their review of the particulars of Epstein's crimes and death. Since then, the public's interest in the Epstein matter has remained. Given this longstanding and legitimate interest, the government now moves to unseal grand jury transcripts associated with Epstein. + +The Department of Justice is filing similar motions in United States v. Maxwell, 1:20-cr-330 (S.D.N.Y.), and in the Southern District of Florida. + +4. "It is a tradition of law that proceedings before a grand jury shall generally remain secret." In re Biaggi, 478 F.2d 489 (2d Cir. 1973). "[T]he tradition of secrecy," however, "is not absolute." In re Petition of Nat. Sec. Archive, 104 F. Supp. 3d 625, 628 (S.D.N.Y. 2015). Although Rule 6(bX3) of the Federal Rules of Criminal Procedure generally lists the exceptions to grand jury secrecy, the Second Circuit has recognized that "there are certain `special circumstances' in which release of grand jury records is appropriate even outside the boundaries of the rule." In re Craig, 131 F.3d 99, 102 (2d Cir. 1997); see also Carlson v. United States, 837 F.3d 753, 767 (7th Cir. 2016) ("Rule 6(eX3XE) does not displace that inherent power. It merely identifies a permissive list of situations where that power can be used."). One such "special circumstance" is historical interest by the public. In re Craig, 131 F.3d at 105. Under In re Craig, this Court retains discretion to determine "whether such an interest outweighs the countervailing interests in privacy and secrecy[.]" Id. + +5. Public officials, lawmakers, pundits, and ordinary citizens remain deeply interested and concerned about the Epstein matter. Indeed, other jurists have released grand jury transcripts after concluding that Epstein's case qualifies as a matter of public concern. See Order Granting Plaintiff's Motion for Reconsideration of the Trial Court's February 29, 2024 Order, CA Florida Holdings, LLC v. Dave Aronberg and Abruzzo, 50-2019 CA-014681 (15th Cir. July 1, 2024).3 After all, Jeffrey Epstein is "the most infamous pedophile in American history." Id. The facts surrounding Epstein's case "tell a tale of national disgrace." In re M, 994 F.3d 1244, 1247 (11th Cir. 2021) (discussing the plea agreement secured by Epstein in Florida). The grand jury records are thus "critical pieces of an important moment in our nation's history." In re Petition of Nat. Sec. Archive, 104 E Supp. 3d at 629. "The time for the public to guess what they contain + +3 http\$://HAVW.MypahnbCaChClerk.comThomeshowpublisheddocument/4194/638554423710170000. + +should end." Id. Notably, the privacy interests at stake on the other side of the balance are substantially diminished due to Epstein's death. Of course, as noted above, the Department of Justice will work with the United States Attorney's Office for the Southern District of New York to redact all victim-identifying information prior to any release. + +6. For these reasons, this Court should conclude that the Epstein and Maxwell cases qualify as a matter of public interest, release the associated grand jury transcripts, and lift any preexisting protective orders. See In re Craig, 131 F.3d at 105 ("It is ... entirely conceivable that in some situations historical or public interest alone could justify the release of grand jury information."). + +Respectfully submitted, + +PAMELA J. 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counsel for the United States of America and add him as a Filing User to whom Notices of Electronic Filing will be transmitted in this case. + +Date: New York, New York July 21, 2025 + +Respectfully submitted, + +JAY CLAYTON United States Attorney for the Southern District of New York + +By: /s/ Jeffrey Oestericher JEFFREY OESTERICHER Assistant United States Attorney 86 Street, 3nd Floor New York, New York 10007 Telephone: (212) 637-2695 Facsimile: (212) 637-0033 Email: Jeffrey.Oesterichetausdoi.gov \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824614/EFTA02824614.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824614/EFTA02824614.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e3b40268e4f461973265445218123ed4fdfeb537 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824614/EFTA02824614.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": 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X 19 CR. 490 (RMB) + +## ORDER + +The Court has received a four page "United States' Motion to Unseal Grand Jury Transcripts" filed with the S.D.N.Y. Clerk's Office on Friday evening, July 18, 2025. See ECF No. 61 (Gov't Motion). The Gov't Motion requests that the Court "unseal the underlying grand jury transcripts in United States v. Epstein, subject to appropriate redactions of victim-related and other personal identifying information." Id. at 1-2. + +The Court intends to resolve this motion expeditiously. However, the Court cannot rule on the motion without additional submissions from the Government. Specifically: + +Memorandum of law: Federal Rule of Criminal Procedure 6(e) codified the practice, "'older than our Nation itself,' that proceedings before a grand jury shall generally remain secret." In re Petition of Craig, 131 F.3d 99, 102 (2d Cir. 1997) (quoting In re Biaggi, 478 F.2d 489, 491 (2d Cir. 1973) (Friendly, C.J.)); see also Douglas Oil Co. of Cal. v. Petrol Stops Nw., 441 U.S. 211, 218 (1979). Rule 6(eX3) lists exceptions to the rule of secrecy but these are not invoked by the Government's Motion. The Second Circuit - but not many other circuits - has recognized that there are certain "special circumstances" in which release of grand jury records may be appropriate, based upon a court's supervisory authority over grand juries it empanels..' See + +The Seventh Circuit agrees that a district court may order the release of grand jury materials upon a showing of special circumstances. See Carlson v. United States, 837 F.3d 753, 766-67 (7th Cir. + +In re Craig, 131 F.3d at 102; see also Id. at 104 ("The discretion of a trial court in deciding whether to make public the ordinarily secret proceedings of a grand jury investigation is one of the broadest and most sensitive exercises of careful judgment that a trial judge can make."). The Second Circuit has identified the following factors for district courts to weigh where considering applications for disclosure: + +- the identity of the party seeking disclosure; +- whether the defendant to the grand jury proceeding or the Government opposes the disclosure; +- why disclosure is being sought in the particular case; +- what specific information is being sought for disclosure; +- how long ago the grand jury proceedings took place; +- the current status of the principals of the grand jury proceedings and that of their families; +- the extent to which the desired material has been previously made public; +- whether witnesses to the grand jury proceedings who might be affected by disclosure are still alive; and +- [whether there is an] additional need for maintaining secrecy in the particular case in question. + +Id. at 106 (capitalization altered); see also Laws.' Comm. for 9/11 Inquiry, Inc. v. Garland, 43 + +F.4th 276, 285 (2d Cir. 2022) (affirming district court's application of those factors). + +2016). Other circuits have taken a much narrower view of a district court's authority. See, e.g., McKeever v. Barr, 920 F.3d 842, 843, 850 (D.C. Cir. 2019), cert. denied, 140 S. Ct. 597 (2020); Pitch v. United States, 953 F.3d 1226, 1241 (11th Cir. 2020) (en bane); United States v. McDougal, 559F.3d 837, 841 (8th Cir. 2009); In re Grand Jury 89-4-72, 932 F.2d 481, 488 (6th Cir. 1991). + +The Government's motion does not adequately address these factors. The Court accordingly directs the Government to file a memorandum of law, no later than Tuesday, July 29, 2025, addressing with specificity these factors. The memorandum of law is to be no more than 25 pages, double spaced. In light of grand jury secrecy and victim-related issues and other personal identifying information concerns, the Government is directed to file, on the public record, a redacted version, and to file under seal the memorandum in unredacted form. + +The Court also directs the Government to state in the memorandum whether, before filing the instant motion, counsel for the Government reviewed the Epstein grand jury transcripts and whether the Government provided notice to the victims of the motion to unseal. Following the Court's ruling on the Government's motion, the Court will invite the Government's input as to whether, and to what extent, these redactions are warranted. + +Grand Jury transcripts: The Court has not received the grand jury transcripts that the Government seeks to unseal. The Court directs the Government to submit to the Court under seal the following materials no later than Tuesday, July 29, 2025: (I) an index of Epstein grand jury transcript materials, including a brief summary, the number of pages, and dates; (2) a complete set of Epstein grand jury transcripts; (3) a complete proposed redacted set of Epstein grand jury transcripts (i.e., the transcripts in the form that the Government proposes to release them); and (4) a description of any other Epstein grand jury materials, including, but not limited to, exhibits. + +Submission from Epstein's Representative: The Court has not received any letter on behalf of deceased defendant Epstein setting out any position vis-I-vis the proposed disclosure. Any such letter is due on or before Tuesday, August 5, 2025. + +Submission(s) from Victims: The Government may not have notified the victims. And, the Court has not received any letters on behalf of the victims setting out their positions on grand jury disclosure. Any such letters are due on or before Tuesday, August 5, 2025. See Gov't Motion at I n.1 (This is a 2 page, undated, unsigned, U.S. Department of Justice and Federal Bureau of Investigation memo. According to the Government, "Epstein harmed over one thousand victims. Each suffered unique trauma. Sensitive information relating to these victims is intertwined throughout the materials. This includes specific details such as victim names and likenesses, physical descriptions, places of birth, associates, and employment history."). + +SO ORDERED. + +Dated: New York, New York July 22, 2025 + +"R' LORI) oias RICHARD M. 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The Court denies the motion to intervene but Hill take into consideration the views expressed in MSW Media's letter. See United States v. Ant, 533 F.3d 72, 81 (2d Cir. 2008) ("The Federal Rules of Criminal Procedure make no reference to a motion to intervene in a criminal case."); United States u Saipov, No. 17 C:r. 722, 2023 WI. 4186055, at \*1 (S.D.N.Y. June 26, 2023). + +Date: July 25, 2025 + +New Yor lc, New York RICHARD M. BERMAN, U.S.D.J. et3 + +## ATTACHMENT 1 + +## NATIONAL SECURITY COUNSELORS + +1451 ROCKVILLE PIKE, SUITE 250 + +ROCKVILLE, MD EOM + +TELEPHONE: (501) 80I.4NSC (4672) + +PACSDAILE: (240) 681-2159 + +KEL MCCLANAHAN, ESQ., EXECUTIVE DIRECTOR(ndmitted in DC, NY, WA) + +EMAIL: KELQINATIONALSECtURITYLAWORG + +OM' P=, ESQ., DEPUTY EXECUTIVE DIRECTOR (admitted in DC, IL) + +25 July 2025 + +Hon. Richard M. Berman + +United States District Court for the Southern District of New York + +Thurgood Marshall Courthouse + +40 Foley Square + +New York, NY 10007 + +Re: United States v. Epstein, Case No. 19-Cr-490 + +Dear Judge Berman: + +On behalf of MSW Media, Inc. ("MSW Media"), I respectfully submit this letter motion to intervene in the above-captioned case for the purposes of partially supporting and partially opposing the Government's motion to unseal the transcripts of grand jury testimony in this case, filed as Docket No. 61. + +MSW Media (https://mswmedia.comf) operates numerous podcasts and blogs about federal government operations, including Mueller She Wrote, SpyTalk, Daily Beans, and Jack. It clearly qualifies as a representative of the news media. + +MSW Media has standing to intervene in this case for the following reason. On 17 July 2025, after President Donald Trump publicly instructed Attorney General Pam Bondi to seek the Court's permission to release "any and all pertinent Grand Jury testimony, we filed a Freedom of Information Act ("FOIA") request with the Department of Justice ("DOT) for transcripts of all grand jury testimony from this case and United States v. Maxwell, No. 20-330 (S.D.N.Y.). We are concerned with the modifier "pertinent" in President Trump's instruction, and that concern seemed vindicated when the Government advised this Court that it intended to "make appropriate redactions of victim-related information and other personal identifying information prior to releasing the transcripts." (DM. #61 at 2 (emphasis added).) + +To be clear, we have no interest in victim-related information, and this Motion does not pertain to that information. However, we do have concerns that the Government seems to be implicitly seeking this Court's permission to withhold other personally identifiable information, such as information about the former defendant's partners in crime or clients. Accordingly, while we join the Government in requesting that these transcripts be released, we accordingly make this narrow independent request to the Court: Please do not weigh in on the appropriateness of withholding personally identifiable information unrelated to victims. We intend to litigate this FOIA request if necessary, and the question of whether such information may be properly + +withheld is a question best left to the court adjudicating that future case. We are concerned that, if this Court explicitly or implicitly blesses the Government's proposed redactions of non-victimrelated personally identifiable information (even in passing), that opinion will be treated as a proverbial thumb on the scale in our FOIA case without materially affecting the Court's decision in this case. + +In other words, if this Court mentions in its decision that it was swayed at all by the Government's promise to redact personally identifiable information, we are concerned that the Government will then argue in its FOIA case that "Judge Berman agreed that this information should not be publicly disclosed." Therefore, we respectfully request that this Court not take the Government's statements regarding non-victim-related personally identifiable information into account when reaching its decision regarding the Government's motion, and we further request that the Court specify that it is not opining on that question, should it grant the Government's motion. + +The Government takes no position on the intervention of MSW Media. 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The Court also requests that all electronic submissions be made directly to Grady Mac.Pheeqmsd.uscourts.gov + +Date: July 25, 2025 + +New York, New York RICHARD M. BERMAN, U.S.D.J. \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824623/EFTA02824623.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824623/EFTA02824623.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8bb4ebe51b9253f882cadbd0c7cafff2481800f3 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824623/EFTA02824623.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824623.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 584, + "elapsed_seconds": 0.55, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 69.156, + 84.24 + ], + [ + 291.3874816894531, + 84.24 + ], + [ + 291.3874816894531, + 113.60302734375 + ], + [ + 69.156, + 113.60302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 30 + ], + [ + "Line", + 16 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824623" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824624/EFTA02824624.md b/marker2/court-us-v-epstein-cr/EFTA02824624/EFTA02824624.md new file mode 100644 index 0000000000000000000000000000000000000000..f725dbadea62f4d91201661cc78082b6321d137a --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824624/EFTA02824624.md @@ -0,0 +1,131 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA + +19 Cr. 490 (RMB) + +JEFFREY EPSTEIN, + +Defendant. + +UNITED STATES OF AMERICA + +20 Cr. 330 (PAE) + +GHISLAINE MAXWELL, + +Defendant. + +# GOVERNMENT'S MEMORANDUM IN RESPONSE TO THE COURT'S ORDERS OF JULY 22, 2025 + +PAMELA J. BONDI United States Attorney General TODD BLANCHE Deputy United States Attorney General United States Department of Justice + +JAY CLAYTON United States Attorney for the Southern District of New York 26 Federal Plaza 37th Floor New York, New York 10278 + +#### I. Preliminary Statement + +The Government respectfully submits this memorandum in response to the Court's Orders concerning the two pending motions to unseal grand jury transcripts (Epstein Dkt. 61; Maxwell Dkt. 785) in cases prosecuted in this District. (Epstein Dkt. 63 at 1-3; Maxwell Dkt. 789 at 1-3). This memorandum, as directed by the Court, addresses the specific facts and factors highlighted in the Court's Orders relevant to the particular grand jury materials at issue here. (Epstein Dkt. 63 at 1-3; Maxwell Dkt. 789 at 1-3). In order to ensure that "[t]ransparency in this process ... not be at the expense of [the Government's] obligation under the law to protect victims" (Epstein Dkt. 61 at 2; Maxwell Dkt. 785 at 2), the Government also respectfully requests leave to file a supplemental submission once the Government and the Court have received any filings from the victims or others referenced in the transcripts. + +# II. The Court's Orders + +As the Court recognized (Epstein Dkt. 63 at 1-2; Maxwell Dkt. 789 at 1-2), the Second Circuit has held that "there are certain 'special circumstances' in which release of grand jury records is appropriate even outside the boundaries of the rule." In re Craig, 131 F.3d 99, 102 (2d Cir. 1997); see also In in Biaggi, 478 F.2d 489, 494 (2d Cir. 1973) (supplemental opinion) (Friendly, C.J.) (recognizing that there are certain "special circumstances" in which release of grand jury records is appropriate even outside of the boundaries of Rule 6(e)). The Second Circuit enumerated a list of non-exhaustive factors for trial courts to consider when deciding such motions: + +I There is currently a Circuit split. See Pitch v. United States, 953 F.3d 1226, 1233 & n.6 (11th Cir. 2020) (en banc) (describing the Circuit split); In re Petition for Order Directing Release of Records, 27 F.4th 84, 90-91 ( I st Cir. 2022) (same). In light of this split, when the Government sought similar relief seeking to unseal grand jury transcripts in the Southern District of Florida from 2005 and 2007 relating to Epstein, the Honorable who is bound by the Eleventh Circuit's rule barring extra-Rule disclosures set forth in Pitch—denied that motion. In re + +(i) the identity of the party seeking disclosure; (ii) whether the defendant to the grand jury proceeding or the government opposes the disclosure; (iii) why disclosure is being sought in the particular case; (iv) what specific information is being sought for disclosure; (v) how long ago the grand jury proceedings took place; (vi) the current status of the principals of the grand July proceedings and that of their families; (vii) the extent to which the desired material either permissibly or impermissibly—has been previously made public; (viii) whether witnesses to the grand jury proceedings who might be affected by disclosure are still alive; and (ix) the additional need for maintaining secrecy in the particular case in question. + +In re Craig, 133 F.3d at 106. + +On July 22, 2025, the Court directed the Government to file a memorandum of law "addressing with specificity these and any other factors that the Government views as germane to its application." (Epstein Dkt. 63 at 3; Maxwell Dkt. 789 at 3). The Court also directed the Government to state whether, "before filing the instant motion, counsel for the Government reviewed the Maxwell grand jury transcripts and whether the Government provided notice to the victims of the motion to unseal," and to submit: (1) indices of Epstein and Maxwell grand jury materials, including a brief summary, the number of pages, and dates; (2) a complete set of the Epstein and Maxwell grand jury transcripts; (3) a complete proposed redacted set of the Epstein and Maxwell grand jury transcripts; and (4) a description of any other Epstein and Maxwell grand jury materials, including, but not limited to, exhibits. (Epstein Dkt. 63 at 3; Maxwell Dkt. 789 at 3). + +Grand Jury 05-02 (WPB) & 07-103 (WPB), No. 25 Misc. 80920 (RLR), 2025 WL 2076030, at '1 (S.D. Fla. July 23, 2025). + +### III. Discussion + +## A. The In re Craig Factors + +The Court directed the Government to "address[] with specificity the0 [In re Craig] factors and any other factors that the Government views as germane to its application." (Epstein Dkt. 63 at 3; Maxwell Dkt. 789 at 3). What follows is a discussion of each of the In re Craig factors, which are designed to assist the Court in exercising its "careful judgment" in balancing the interests in public disclosure in unique circumstances of strongly expressed and wide-ranging public interest and the traditional considerations concerning the secrecy of grand jury proceedings. In re Craig, 131 F.3d at 104. + +### 1. The Identity of the Party Seeking Disclosure + +The first factor considers which party is seeking disclosure of grand jury materials; the identity of the party seeking disclosure "carr[ies) great weight." In re Craig, 131 F.3d at 106. Here, the Government is seeking disclosure of grand jury transcripts, a request that is consistent with increasing calls for additional disclosures in this matter.2 The Government's position "serve[s] as a preliminary indication that the need for secrecy is not especially strong," even if it is "not dispositive." Id.; see also id. ("Government support cannot 'confer' disclosure, nor can government opposition preclude it."). While the Government acknowledges the extraordinary + +2 See, e.g., Press Release, Chairman Coiner Subpoenas Ghislaine Maxwell for Deposition at Federal Prison - United States House Committee on Oversight and Accountability ("The facts and circumstances surrounding both [Ms. Maxwell] and Mr. Epstein's cases have received immense public interest and scrutiny. At the outset of the 119th Congress, on February 11, 2025, the Committee and the Task Force on the Declassification of Federal Secrets sent a letter to the U.S. Department of Justice requesting a briefing regarding documents in the Department's possession regarding 'the investigation into and prosecution of Jeffrey Epstein.' On May 8, the Task Force sent another letter to the Department requesting the public release of 'the entirety of the Epstein files' and a briefing regarding the release of these files."). + +nature of the instant request, it is also (like the Court) faced with a broad public interest in the underlying proceedings. + +### 2. Whether the Defendant to the Grand Jury Proceeding or the Government Opposes the Disclosure + +The second factor asks whether the defendant or the Government opposes public disclosure of grand jury materials. See In re Craig, 131 F.3d at 106; see also Lawyers' Committee for 9/11 Inquiry Inc. v. Garland, 43 F.4th 276, 285-86 (2d Cir. 2022) (affirming denial of motion to disclose grand jury materials where the Government opposed release). A defendant's opposition to public disclosure is not dispositive. See In re Grand Jury Proceedings GJ-76-4 & GJ-75-3, 800 F.2d 1293, 1305 (4th Cir. 1986) (affirming district court's decision to disclose grand jury transcript and exhibits over defendant corporation's objection). + +Defendant Epstein has passed and therefore cannot assert a position.3 Defendant Maxwell has indicated that she expects "to craft a response and set out [her] position to the Court." (Maxwell Dkt. 793). + +# 3. Why Disclosure Is Being Sought in the Particular Case + +The third factor considers "why disclosure is being sought in the particular case." In re Craig, 131 F.3d at 106. The Second Circuit in In re Craig held: "It is ... entirely conceivable that in some situations historical or public interest alone could justify the release of grand jury information." Id. As described above and in the underlying motions, there is undoubtedly a clearly expressed interest from the public in Jeffrey Epstein's and Ghislaine Maxwell's crimes. Beyond that, there is abundant public interest in the investigative work conducted by the Department of Justice and the Federal Bureau of investigation into those crimes. See In it Am. Hist. Assn, 49 F. + +3 As noted below, the Government has not received any outreach from Epstein's surviving family concerning the instant motion. + +Supp. 2d 274, 294 (S.D.N.Y. 1999) (applying In re Craig) ("Many historians ... have spent countless hours documenting the Rosenbergs' story. Many questions remain unanswered, and the public's interest remains."); (Epstein Dkt. 61 at 1; Maxwell Dkt. 785 at I). Attention given to the Epstein and Maxwell cases has recently intensified in the wake of the July 6, 2025 Memorandum announcing the conclusions of the Government's review into the investigation. See id. + +The instant motions for unsealing are consistent with the fundamental purposes set forth in that memorandum given the magnitude and abhorrence of Epstein's crimes: to provide information to the public while remaining sensitive to protecting the rights of victims. + +# 4. What Specific Information Is Being Sought for Disclosure + +The fourth factor asks what specific information the movant seeks to disclose. See In re Craig, 131 F.3d at 106. Here, the Government seeks the public disclosure of the grand jury transcripts in the Epstein and Maxwell cases (Epstein Dkt. 61 at I; Maxwell Dkt. 785 at I ). As stated in the pending motions, any public disclosure granted by the Court would be "subject to appropriate redactions of victim-related and other personal identifying information" (Epstein Dkt. 61 at 2; Maxwell Dkt. 785 at 2). + +# 5. How Long Ago the Grand Jury Proceedings Took Place + +The fifth factor asks how long ago the grand jury proceedings took place. In re Craig, 131 F.3d at 106. The grand jury met in June and July of 2019 in the Epstein case. The grand jury met in June and July of 2020 and March of 2021 in the Maxwell case. Here, the passage of time has not dulled the public's interest in these cases. See In re Craig, 131 F.3d at 107 ("if historical interest in a specific case has persisted over a number of years, that serves as an important indication that the public's interest in release of the information is substantial"). + +#### 6. The Current Status of the Principals of the Grand Jury Proceedings and that of their Families + +The sixth factor considers "the current status of the principals of the grand jury proceedings and that of their families." In re Craig, 131 F.3d 99. The passage of time "brings about the death of the principal parties involved in the investigations, as well as that of their immediate families." Id. at 106. The Court should consider the "continued existence and vulnerabilities of such parties." Id. + +In this case, the grand jury testimony was offered specifically in connection with charges proposed against Epstein and Maxwell. Epstein is deceased, and no family member has approached the Government indicating an interest in the instant motions. One of Epstein's family members previously filed a request for materials pursuant to the Freedom of Information Act, the Government responded to that request, and no litigation ensued. Maxwell currently is incarcerated, and no family member has approached the Government indicating an interest in the motions. + +### 7. The Extent to Which the Desired Material—Either Permissibly or Impermissibly—Has Been Previously Made Public + +The Government is not aware of the relevant grand jury transcripts being impermissibly leaked to the public. + +Certain aspects and subject matters of the transcripts became public during Maxwell's trial. To the extent that any of the desired material was disclosed to Maxwell as a result of the Government's disclosure obligations, it was disclosed pursuant to a protective order. + +Many of the victims whose accounts relating to Epstein and Maxwell that were the subject of grand jury testimony testified at trial consistent with the accounts described by an FBI agent and the detective from the New York City Police Department ("NYPD") in the grand jury and some have also made public those factual accounts in the course of civil litigation. The + +Government is providing under seal a list of witnesses whose accounts were conveyed in the grand jury proceedings and a corresponding list noting which witnesses testified at trial. + +#### 8. Whether Witnesses to the Grand Jury Proceedings Who Might Be Affected by Disclosure Are Still Alive + +The eighth factor considers "whether witnesses to the grand jury proceedings who might be affected by disclosure are still alive." In re Craig, 131 F.3d at 106. + +Here, there was one witness—an FBI agent—during the Epstein grand jury proceedings. There were two witnesses—the same FBI agent from the Epstein grand jury proceedings and a detective with the NYPD who was a Task Force Officer with the FBI's Child Exploitation and Human Trafficking Task Force—during the Maxwell grand jury proceedings. + +Both witnesses are still alive; the FBI agent continues to be an agent with the FBI, and the Detective continues to be a Detective with the NYPD as well as a Task Force Officer. + +Consistent with applicable rules concerning the admissibility of hearsay testimony, the grand jury witnesses described statements of others, including statements of and concerning victims, many of whom are still alive. In the sealed submission accompanying this filing, the Government will note which victims are still alive. + +## 9. Whether There Is an Additional Need for Maintaining Secrecy in the Particular Case in Question + +Finally, the ninth factor considers "the additional need for maintaining secrecy in the particular case in question." In re Craig, 131 F.3d at 106. In addition to the typical reasons for grand jury secrecy, the grand July transcripts contain victim•related and other personal identifying information related to third parties who neither have been charged or alleged to be involved in the crimes with which Epstein and Maxwell were charged, to which the Government is sensitive, and which is why the Government proposes redacting the transcripts before releasing them. (See Epstein Dkt. 61 at 2; Maxwell Dkt. 785 at 2). + +### B. Additional I nturmatiun + +The Court directed the Government to state whether, "before filing the instant motion, counsel for the Government reviewed the Maxwell grand jury transcripts and whether the Government provided notice to the victims of the motion to unseal." (Epstein Dkt. 63 at 3; Maxwell Dkt. 789 at 3). + +Before filing the motions to unseal, relevant counsel for the Government reviewed the Epstein and Maxwell grand jury transcripts. In addition, the Government has now provided notice to all but one of the victims who are referenced in the grand jury transcripts at issue in this motion. The Government has attempted to contact the remaining victim, but such efforts have been unsuccessful. In addition, the Government is in the process of providing notice to any other individuals identified in the transcripts. + +## C. Provision of Materials to the Court + +The Court directed the Government to submit: (I) indices of Epstein and Maxwell grand jury materials, including a brief summary, the number of pages, and dates; (2) a complete set of the Epstein and Maxwell grand jury transcripts; (3) a complete proposed redacted set of the Epstein and Maxwell grand jury transcripts; and (4) a description of any other Epstein and Maxwell grand jury materials, including, but not limited to, exhibits. (Epstein Dkt. 63 at 3; Maxwell Dkt. 789 at 3). As to the final category, the Government provides a description of all of the underlying materials presented to the grand jury as well as copies of, and proposed redactions to, certain materials presented to the grand jury. + +The Government is submitting these materials ex pane and under seal, as they relate to grand jury proceedings and include information related to victims, including but not limited to victim-identifying information of individuals who neither testified at trial or who were the subject of testimony at trial. The Government underscores that it takes very seriously its obligation to protect victim-related information and therefore believes the proposed redactions not only are appropriate but are necessary to protect those rights. + +Dated: New York, New York July 29, 2025 + +Respectfully submitted, + +PAMELA J. BONDI United States Attorney General TODD BLANCHE Deputy United States Attorney General United States Department of Justice + +/s/ Jay Clayton + +JAY CLAYTON United States Attorney for the Southern District of New York 26 Federal Plaza 37th Floor New York, New York 10278 \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824624/EFTA02824624.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824624/EFTA02824624.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c9e66a6ff3039f5487f195b8a8b1643b331878ce --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824624/EFTA02824624.metadata.json @@ -0,0 +1,804 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824624.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 10, + "chars": 17056, + "elapsed_seconds": 1.36, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 281.0828552246094, + 71.28 + ], + [ + 281.0828552246094, + 100.10302734375 + ], + [ + 68.544, + 100.10302734375 + ] + ] + }, + { + "title": "GOVERNMENT'S MEMORANDUM IN RESPONSE TO THE \nCOURT'S ORDERS OF JULY 22, 2025", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 159.12, + 391.23 + ], + [ + 453.67431640625, + 391.23 + ], + [ + 453.67431640625, + 424.2509765625 + ], + [ + 159.12, + 424.2509765625 + ] + ] + }, + { + "title": "I. 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DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA, Government, + +19 CR. 490 (RMB) + +-against- + +ORDER + +JEFFREY EPSTEIN, Defendant. + +X + +In order to assist the Court in its review of the Government's motion, dated July 18, 2025 (ECF No. 61), the Court respectfully requests the Government, by Monday, August 4, 2025, to provide the Court with a letter: + +- I. Verifying the date(s) of all grand jury presentation(s) in this case; +- 2. Providing all exhibits shown to the grand jurors; +- 3. Stating whether the Government moves to unseal the grand jury exhibits as well as the transcripts; +- 4. Identifying with specificity the grand jury exhibits that are not already part of the public record (They may be redacted for any public release); +- 5. Analyzing how the Nolle Prosequi (ECF No. 52) filed in this case impacts proposed disclosure, with legal authorities. + +Dated: New York, New York July 31, 2025 + +43244414A, RICHARD M. 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Richard M. Berman, U.S.DJ. United States District Court Southern District of New York 500 Pearl Street New York, New York 10007-1312 + +Re: USA vs. EpM, 1:19-cr-00490-RMB + +Dear Hon. Judge Berman: + +![Signature of Richard M. Berman]()Docket and file. + +SO ORDERED: +Date: 08/04/25      Richard M. Berman +Richard M. Berman, U.S.D.J. + +As a suffering victim of Epstein and his co-conspirators, I would like to highlight some things that stand out to me and for many reasons on the latest `memo' written by an anonymous member of the DOJ. + +One, I am not sure the highest priority here is the victims, justice for the victims or combatting child exploitation, or at least I do not feel this way. If there was justice for the victims we would see some kind of accountability for the years they allowed this horrible human being, if you can call him that, to prey on underage and young girls while jet-setting around the world with high-profile individuals and/or entrapping his victims in his various mansions and/or his notorious private island. And to make matters more severe continued to traffic, rape and assault victims while on prison work-release and/or even after being a registered sex offender for about a decade. Rather, I feel like the DOJ's and FBI's priority is protecting the "third-party", the wealthy men by focusing on scrubbing their names off the files of which the victims, "know who they are". To learn that our own president has utilized thousands of agents to protect his identity and these high-profile individuals is monumentally mind-blowing. That is their focus? Wow! + +Two, the fact that he "Killed himself" in prison leaves us all empty, without answers, without resolution, with the ongoing conspiracy that will never die. I ask myself every day, what happened? Did he really "Kill himself"? Is he still alive? Where is he buried? Why didn't we get to see his dead body? This all leaves me fearful, angry and rightfully devastated and damaged. + +Three, the latest attention on the "Epstein Files", the "Client List" is OUT OF CONTROL and the ones that are left to suffer are not the high-profile individuals, IT IS THE VICTIMS. Why the lack of concern in handling such sensitive information for the victims sake? + +I appreciate your time reading my short thoughts and feeling and my anxiety and frustration is NOT aimed at you, obviously. It is aimed at the very government here, the ones asking to release these transcripts, exhibits, etc., of which the victims are not privy to while they have concluded that there is nothing more to see on the files they hold. Yet no one has seen them, but them. I am beside myself. + +I think what I would request from you, your honor, is to consider having an approved third-party review these documents to ensure that NO victims names or likenesses are revealed through this release. It is imperative with the scrutiny over this media frenzy that the victims are completely and entirely protected. + +Thank you so much for your time. + +I have attached the portion of the Dal's memo and link to their statement. + +[Consistent with prior disclosures, this review confirmed that Epstein harmed over one thousand victims. Each suffered unique trauma. Sensitive information relating to these victims is intertwined throughout the materials. This includes specific details such as victim names and likenesses, physical descriptions, places of birth, associates, and employment history. + +One of our highest priorities is combatting child exploitation and bringing justice to victims. Perpetuating unfounded theories about Epstein serves neither of those ends. + +To that end, while we have labored to provide the public with maximum information regarding Epstein and ensured examination of any evidence in the government's possession, it is the determination of the Department of Justice and the Federal Bureau of Investigation that no further disclosure would be appropriate or warranted.] + +hapsifiwww,justicelovlopahnediall407001/dPinline \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824635/EFTA02824635.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824635/EFTA02824635.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..32252f99554b775c523a2f608264793a9fb71ca4 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824635/EFTA02824635.metadata.json @@ -0,0 +1,124 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824635.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 4022, + "elapsed_seconds": 1.32, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA EMAIL TO JUDGE BERMAN:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 263.45648193359375, + 71.28 + ], + [ + 263.45648193359375, + 85.93353271484375 + ], + [ + 68.544, + 85.93353271484375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 92 + ], + [ + "Line", + 45 + ], + [ + "Text", + 12 + ], + [ + "PageHeader", + 3 + ], + [ + "SectionHeader", + 1 + ], + [ + "Form", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 17 + ], + [ + "PageHeader", + 6 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824635" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824637/EFTA02824637.md b/marker2/court-us-v-epstein-cr/EFTA02824637/EFTA02824637.md new file mode 100644 index 0000000000000000000000000000000000000000..a4757a561f10efef32721f75509432266281846b --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824637/EFTA02824637.md @@ -0,0 +1,38 @@ +## VIA EMAIL TO JUDGE BERNIAIsk + +Hon. Richard M. Berman, U.S.D.J. + +United States District Court + +Southern District of New York + +500 Pearl Street + +New York, New York 10007-1312 + +![Docket and file.]()Docket and file. + +SO ORDERED: +Date: 08/04/25 Richard M. Berman, U.S.D.J. + +Re: United States of America vs. Jeffrey Epstein. 1:19-cr-00490-RMB + +Dear Hon. Judge Berman: + +I come forward to you today in disdain, disgust and fear of how the United States of America's DOJ has handled the promise to release the "Epstein Files". Out of respect for the court, I will keep this short, to the point and as direct as possible. It has been a very difficult time for me personally, mentally and emotionally dealing with the circus around the "Epstein Files". I use quotations because what are these "Files" exactly, anyway?" + +I regrettably feel the need to come forward and shed some light on the Government's motion to unseal transcripts, documents and exhibits from the "case" that was never tried. Sad to say, for the victims we never got our day in court. Apparently, Epstein killed himself under whose watch? ■, **was it Trump's DOJ? Hmmm, interesting. Although, I am for complete and utter transparency in this case, we deserve transparency from our own government, the agencies that were supposed to be there to protect us victims and guess what, they utterly and completely failed us. Unfortunately, with their disregard for the victims I feel it is imperative to write this letter to the court.** + +**Because, I personally desire to remain anonymous I feel like I do not have a voice. Therefore, with it being my right to have an opinion as a victim in this matter I have a voice to speak to the court and to the United States.** + +**Dear United States, I wish you would have handled and would handle the whole "Epstein Files" with more respect towards and for the victims. I am not some pawn in your political warfare. What you have done and continue to do is eating at me day after day as you help to perpetuate this story indefinitely. Why not be completely transparent? Show us all the files with only the necessary redactions! Be done with it and allow me/us to heal. You protect yourself and your powerful and wealthy "friends" (not enemies) over the victims, why? The victims know the truth, we know who are in the files and now so do you. Do you really think the public is that ignorant of the truth? Further redacting the names, like yours, will only cause the distraction you say you don't want, and the conspiracies that you in fact are stirring. So I will continue to stay silent and continue to hide from all the pain and suffering, out of fear of you and your wealthy powerful "friends". In the end we are the biggest voices of the truth and the truth always comes out in time.** + +Dear Judge Berman, in making your decision to allow the Unites States of America's current sitting attorneys for the DOJ's request to release these files, I ask you to have our attorneys review the "suggested" redactions as they are the ones who also know the victims, their names, their truths and their stories unlike the Unites States Government who did not and does not even care to know our truth. They would rather ask a convicted imprisoned sex trafficker/ abuser for information. + +In conclusion, I beg the court to make sure it is the upmost priority that in any sort of release ALL and EVERY detail that could possibly reveal our identities be redacted. I also request that you take your time in making your decision and consider allowing for the victims attorney's to review these files before a release is permitted. + +Side Note: brother victims do not mind having their personal information redacted, my voice is not for them. + +Sincerely and thank you for your time, + +Xxx-victim/survivor \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824637/EFTA02824637.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824637/EFTA02824637.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7df0d25f977d6ccf78c43266f061d02c90ef5e96 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824637/EFTA02824637.metadata.json @@ -0,0 +1,124 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824637.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3791, + "elapsed_seconds": 1.28, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA EMAIL TO JUDGE BERNIAIsk", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 69.156, + 72.67889404296875 + ], + [ + 263.5599365234375, + 72.67889404296875 + ], + [ + 263.5599365234375, + 86.68353271484375 + ], + [ + 69.156, + 86.68353271484375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 93 + ], + [ + "Line", + 43 + ], + [ + "Text", + 11 + ], + [ + "PageHeader", + 7 + ], + [ + "SectionHeader", + 1 + ], + [ + "Form", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 16 + ], + [ + "Text", + 7 + ], + [ + "PageHeader", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02824637" + } +} \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824639/EFTA02824639.md b/marker2/court-us-v-epstein-cr/EFTA02824639/EFTA02824639.md new file mode 100644 index 0000000000000000000000000000000000000000..4ca63a195e3626b8a027bc4a021e27dc1d9954f4 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824639/EFTA02824639.md @@ -0,0 +1,104 @@ +![](_page_0_Picture_1.jpeg) + +United States Attorney Southern District of New York + +The Honorable Richard M. Berman United States District Judge Southern District of New York 500 Pearl Street New York, New York 10007 + +> Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) United States v. Ghislaine Maxwell, 20 Cr. 330 (PAE) + +The Jacob K. Javits Federal Building 26 Federal Plaza. 37th Floor New York. New• York 10278 + +August 4, 2025 + +The Honorable Paul A. Engelmayer United States District Judge Southern District of New York 40 Foley Square New York, New York 1007 + +Dear Judges Berman and Engelmayer: + +The Government writes respectfully to respond to the Court's orders, dated July 31, 2025, directing the Government to provide additional information regarding grand jury materials the Government has asked the Court to unseal in these cases. (Epstein Dkt. 67; Maxwell Dkt. 797). + +In particular, on July 18, 2025, the Government moved the Court to unseal grand jury transcripts from these cases, subject to appropriate redactions. (Epstein Dkt. 61; Maxwell Dkt. 785). The Court directed the Government to provide supplemental briefing (Epstein Dkt. 63; Maxwell Dkt. 789), which the Government submitted on July 29, 2025 (Epstein Dkt. 66; Maxwell Dkt. 796). In addition, the Court set a schedule whereby the defendants and victims could set out their positions on or before August 5, 2025. (Epstein Dkt. 63 at 3-4; Maxwell Dkt. 789 at 4). + +On July 31, 2025, the Court directed the Government to provide additional information by August 4, 2025, in particular, in the Epstein case, a letter: + +- I. Verifying the date(s) of all grand jury presentation(s) in this case; +- 2. Providing all exhibits shown to grand jurors; +- 3. Stating whether the Government moves to unseal the grand jury exhibits as well as the transcripts; +- 4. Identifying with specificity the grand jury exhibits that are not already part of the public record (They may be redacted for any public release); + +Hon. Richard M. Berman, U.S.D.J. Hon. Paul A. Engelmayer, U.S.D.J. August 4, 2025 Page 2 of 4 + +- 5. Analyzing how the Nolle Prosequi ([Epstein] ECF No. 52) filed in this case impacts proposed disclosure, with legal authorities. + +(Epstein Dkt. 67). In the Maxwell case, the Court directed the Government to provide additional information by August 4, 2025, in particular, a letter + +- 1. Stating whether the Government moves to unseal the grand jury exhibits as well as the transcripts, or just the transcripts. +- 2. Identifying with specificity the grand jury exhibits, as redacted for public release, that are not already part of the public record. In making this assessment, the Government should take into account whether the unredacted portions of these exhibits were received in evidence during trial in this case, otherwise disclosed on the docket of this case or disclosed in the course of civil litigation, see, e.g., Maxwell, 15 Civ. 7433 (LAP). +- 3. Identifying with specificity the information testified to in the grand jury transcripts, as redacted for proposed release, that is not already part of the public record, taking into account the sources above. + +(Maxwell Dkt. 797). + +Because the Court's Orders, and the information sought, are consistent in several respects, the Government respectfully submits this consolidated letter response. + +First, at this time, the Government has moved only to unseal the grand jury transcripts in these cases. Of course, the grand jury exhibits are not the only exhibits in these cases; a large number of exhibits were admitted at the Maxwell trial, which trial exhibits are—subject to judicially approved redactions and/or sealing—presumptively public documents. See, e.g., United States v. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995) ("the public has an especially strong right of access to evidence introduced in trials" (internal quotation marks and citation omitted)); United States v. Akhavan, 532 F. Supp. 3d 181, 186 (S.D.N.Y. 2021) ("trial exhibits are judicial documents to which an 'especially strong' common law presumption of access applies" (quoting Amodeo, 71 F.3d at 1049)). The Government previously made those trial exhibits—subject to any judicially approved redactions and/or sealing—available to the public through a website during the Maxwell trial. + +The Government respectfully requests leave of the Court to advise the Court by August 8, 2025, of its position with respect to unsealing of the grand jury exhibits. Such timing will permit the Government to consider (with respect to its underlying position as well as with respect to any + +Hon. Paul A. Engelmayer, U.S.D.J. + +August 4, 2025 + +Page 3 of 4 + +necessary redactions) any submissions to the Court by the victims identified in the grand jury transcripts, which are due to the Court on August 5, 2025. + +Second, the Epstein grand jury met on June 18, 2019, and July 2, 2019. The Maxwell grand jury met on June 29, 2020, July 8, 2020, and March 29, 2021. + +Third, the Government has provided the Court with all substantive exhibits from the grand jury presentations in each of the Epstein and Maxwell cases that it currently has in its possession. The Government respectfully submits under seal to Judge Berman one additional grand jury exhibit from the Epstein case that it referenced in its letter to the Court but did not have readily available at that time. + +Fourth, in connection with this letter, the Government respectfully submits to Judge Engelmayer under seal and ex parte a version of the Maxwell grand jury transcripts that specifically identifies which information in the transcripts is not, as far as the Government is aware, publicly available. As previewed in the Government's submission of July 29, 2025, many of the victims and witnesses testified at trial consistent with the accounts offered in the grand jury by investigating law enforcement witnesses. The enclosed, annotated transcripts show that much of the information provided during the course of the grand jury testimony—with the exception of the identities of certain victims and witnesses—was made publicly available at trial or has otherwise been publicly reported through the public statements of victims and witnesses.' + +Fifth, the substantive grand jury exhibits are not currently part of the public record. The Government, however, is undertaking to identify for the Court any specific portions of the grand jury exhibits that are reflected in the public record. In doing so, the Government endeavors to compare the exhibits against the voluminous public and sealed exhibits offered at the Maxwell trial and to review certain relevant civil litigation dockets of which the Government is aware to the extent such dockets are publicly available. The Government respectfully requests leave of the Court to supplement this letter no later than August 8, 2025, in order to respond to item 4 of Judge Berman's Order and item 2 of Judge Engelmayer's Order. + +Sixth, the nolle prosequi filed in the Epstein case does not impact the proposed disclosure. While the Supreme Court has noted—in a different context—that a Court's "jurisdiction end[s]" when "a nolle prosequi [is] entered," Ex parte Wilson, 140 U.S. 575, 583 (1891), it did so in the context of a court having the ability to enter a judgment. To the contrary, at least one court has explicitly held that a nolle prosequi does not deprive a court of the authority to determine whether to disclose sealed grand jury minutes. United States v. Byoir, 58 F. Supp. 273, 274 (N.D. Tex.), + +Although there was no public trial of Epstein, the Government is prepared to do a similar analysis regarding the Epstein grand jury transcripts if Judge Berman believes it would assist in the Court's analysis of the In re Craig factors related to the Government's motion in Epstein. + +Hon. Paul A. Engelmayer, U.S.D.J. + +August 4,2025 + +Page 4 of 4 + +affirmed 147 F.2d 336 (5th Cir. 1945) ("The same jurisdiction that was sought in the beginning continues to exist insofar as the integrity and preservation of the minutia and minutes and proceedings of those steps are concerned. What was done here is evidence and may be advantaged by either party, having in mind, of course, the question of the secrecy of the grand jury proceedings. And the only jurisdiction over such matters is in this court"); see also, e.g., Dale v. Bartels, 532 F. Supp. 973,978-79 (S.D.N.Y. 1982) (ordering limited disclosure of sealed grand jury testimony after entry of a nolle prosequi). However, the fact that Epstein passed away—which was the basis for the entry of the nolle prosequi—is a factor to be considered. See In re Craig, 131 F.3d 99,106 (2d Cir. 1997) (noting that "the current status of the principals of the grand jury proceedings and that of their families" is a factor "that a trial court might want to consider when confronted with these highly discretionary and fact-sensitive 'special circumstances' motions"). + +Seventh, regarding the Government's approach to victim notification of the instant proceedings, as noted in its July 29 submission, the Government has provided notice of the unsealing motions to all but one of the victims who are referenced in the grand jury transcripts at issue in the motions. The Government still has been unable to contact that remaining victim. With respect to victims who are not identified in the grand jury transcripts but who have previously received victim notifications in the Maxwell and Epstein matters, the Government will over the coming days alert those victims to the fact of the unsealing motions. + +Finally, in light of the Government's ongoing efforts to ensure that that the interests of victims and other third parties are appropriately considered, as well as the multifaceted nature of these and other relevant proceedings, it may be necessary or appropriate for the Government to modify or supplement the information provided today, and the Government commits to doing so as promptly as practicable. + +As always, the Government is available to answer any questions the Court may have. + +Respectfully submitted, + +PAMELA J. 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Berman United States District Court Southern District of New York Daniel Moynihan United States Courthouse 500 Pearl Street, Courtroom 17B New York, NY 10007 + +Hughes Hubbard & 1.19 One Bantry Park Plaza New York, Ncw York 10004-1482 Office:4A (212) 837.6000 Pax: +I (212) 422-4726 hugheshubbard.com + +Daniel H. Weiner Partner Direct Dial: +1 (212) 837.6874 Direct It: +1 (212) 299-6874 daniel.weiner®hugheshubbard.com + +Re: United States of America v. Jeffrey Epstein. Case No. 19-cr-490 (RMB) + +Dear Judge Berman: + +On behalf of the Co-Executors of the Estate of Jeffrey Epstein, we write at the Court's invitation by Order in this action dated July 22, 2025 (ECF No. 63) to set out the Epstein Estate's position regarding the Government's recent motion to unseal all grand jury transcripts in this action, "subject to appropriate redactions of victim-related and other personal identifying information" (ECF No. 61 at 1-2). + +In view of the Government's commitment to protect the identities of those claiming to have been victimized by Mr. Epstein, the Epstein Estate takes no position regarding the Government's motion to unseal. + +Respectfully submitted, + +Daniel H. 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Richard M. Berman U.S. District Court for the Southern District of New York Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 + +Hon. Paul A. Engelmayer U.S. District Court of the Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 + +Sigrid McCawley Telephone: (954) 377-4223 Email: smccawley®bsfilp.com + +![Signature of Richard M. Berman]()Re: Unsealing of Grand Jury Transcripts in CS. v. Epstein, 19-cr-490 (RMB) and U.S. v. Maxwell, 20-cr-330 (PAE) + +Dear Judges Berman and Engelmayer, + +We write on behalf of in response to the belated notice that we received from the Department of Justice on July 25, 2025, advising that the Court is seeking letters on behalf of victims setting out their positions on the proposed disclosures of Jeffrey Epstein's and Ghislainc Maxwell's grand jury transcripts.' + +By the Government's admission, "over one thousand victims" suffered from Epstein's and Maxwell's actions. To date, however, the combined forces of our country's law enforcement agencies have only ever arrested these two individuals in connection with crimes committed against countless young women and girls, and the Government's recent suggestion that no further criminal investigations are forthcoming is a cowardly abdication of its duties to protect and serve.2 + +is a survivor of Epstein's and Maxwell's crimes and testified at Maxwell's trial. While the undersigned counsel has at various times, represented hundreds of victims of Epstein and Maxwell aside from MM, the Department of Justice's notice did not identify the specific victims whose names, likenesses, or information may be subject to disclosure. + +2 Of those two, Epstein escaped justice through his apparent suicide, and Maxwell is now, to the victims' horror, herself attempting to escape justice by negotiating for herself a potential pardon + +It is obviously impossible for two people to conduct a decades-long sex-trafficking enterprise involving thousands of victims without other individuals who participated in and facilitated these unspeakable atrocities. + +The recent controversy surrounding the Government's decision to withhold information concerning Epstein's and Maxwell's crimes has largely ignored the victims' perspective. • is thankful for the Court's invitations to state the victims' positions, and supports the unsealing of the grand jury transcripts, as well as the accompanying grand jury exhibits, with redactions only as necessary to protect victims' names, likenesses, and identifying information. Transparency is critical to justice, and the public has a legitimate interest in understanding the full scope of Epstein's and Maxwell's crimes, particularly where those actions caused lasting harm to others. While it was not the victims' decision to seek disclosure of the grand jury transcripts alone (as opposed to the much larger volume of information available in the "more than 300 gigabytes of data and physical evidence" in the Government's possession that should be disclosed as well), the instant motion for unsealing will help expose the magnitude and abhorrence of Epstein's and Maxwell's crimes. + +In this case that involved a decades-long, systematic criminal scheme that shocked the conscience of the public, caused lasting harm to survivors, and raised credible concerns about the failures of institutional accountability, there is an especially compelling interest in transparency. Unsealing the grand jury transcripts will illuminate the scope of Epstein's and Maxwell's abuse, provide additional insight into those who enabled his abuse, and bring light to how these crimes were investigated and prosecuted. While grand jury secrecy serves important purposes, it is not absolute and under these circumstances the balance tilts in favor of disclosure. + +## 1. Given the Magnitude and Abhorrence of Epstein's and Maxwell's Crimes, the Unsealing of the Grand Transcripts Is Appropriate. + +The Second Circuit has recognized that there are special circumstances when the release of grand jury records is appropriate based on the courts' supervisory authority over the grand juries they empanel and that the trial court has "wide discretion ... in evaluating whether disclosure is appropriate." In re Petition of Craig, 131 F.3d 99, 102, 104 (2d Cir. 1997). In Craig, the Second Circuit outlined a non-exclusive list of factors that a trial court may consider when deciding whether "special circumstances warrant the release of grand jury transcripts. Id. at 106. We join the Government's arguments for unsealing under the Craig factors, Epstein Dkt No. 66, at 3-7. Two factors warrant additional discussion in light of the victims' position in favor of unsealing. + +or commutation of her sentence. The victims of her crimes unequivocally object to any potential leniency that the Government may be considering offering Maxwell, a convicted sex trafficker. + +## A. Why Disclosure Is Being Sought in Particular Case + +Grand jury secrecy may serve legitimate purposes in ordinary cases, but this is no ordinary case. In addition to the public interest that the Government identifies, Epstein Dkt. No. 66 at 4-5, disclosure of the grand jury transcripts in this case serves the interest of Epstein's and Maxwell's victims in bringing light to Epstein's and Maxwell's horrific crimes. This transparency and accountability is a form of justice. Epstein is the world's most notorious sex offender, and his crimes span decades, with thousands of victims. Epstein was a calculated predator who preyed on minors and young women using wealth, deceit, and manipulation. Maxwell, his righthand woman, played a central role in recruiting, grooming, and trafficking Epstein's victims, oftentimes participating in the abuse. Her participation, and the complicity and participation of others, enabled Epstein to conduct a decades-long sex-trafficking scheme. + +Given the magnitude and abhorrence of Epstein and Maxwell's crimes, unsealing the grand jury transcripts is not just appropriate, it is necessary to understand the full scope of the abuse and those who enabled it. For years, victims of Epstein's and Maxwell's crimes have been silenced, fearful of the repercussions of exposing the many powerful individuals in Epstein's network, many of whom have not yet been named or investigated. Unsealing the grand jury transcripts would allow additional important information to emerge without requiring the victims to expose themselves to the same ridicule, retaliation, and humiliation they would face if they were the ones to expose such information. The Government itself acknowledged that there are "over one thousand victims," 3 yet only a small fraction—approximately one-fifth—have received compensation, underscoring the continuing lack of full accountability for Epstein, Maxwell, and their co-conspirators. The interests of the victims should therefore weigh in favor of disclosure. See Matter of Aiani v. Donovan, 98 A.D.3d 972, 974 (2d Dep't 2012) (ordering disclosure of banking records requested in connection with grand jury proceedings based on the interests of the victims). + +### B. Whether Witnesses to the Grand Jury Transcripts Who Might Be Affected by Disclosure Are Still Alive + +This factor considers whether individuals who may be affected by the disclosure of grand jury materials may be adversely impacted by unsealing. This case presents a rare and compelling circumstance where the victims seek transparency, not secrecy. In In re National Security Archive, for example, where the proceedings held substantial historical importance and the living witnesses did not express any objection to the release, the Court found that the release of grand jury testimony was appropriate. 2008 WL 8985358, at \*1-2 (S.D.N.Y. Aug. 26, 2008). The victims represented by the undersigned counsel who are still alive do not just passively support unsealing, but + +See U.S. Dep't of Justice, Federal Bureau of Investigation, Memorandum (July 6, 2025), https://www.justice.gov/opa/media/1407001/d1?inline. + +affirmatively support unsealing, subject to appropriate redactions to protect their personal privacy. Their consent to disclosure should weigh in favor of unsealing under this factor. Further, because the Government intends to redact the names and identifying information of the victims, there is no risk that the privacy of the victims will be jeopardized. In re Kutler, 800 F. Supp. 2d 42, 50 (D.D.C. 2011) (procedures for reviewing transcripts to protect named individuals as needed "allay any remaining privacy concerns"). + +#### 2. The Court Should Assess the Appropriateness of the Redactions. + +The grand jury transcripts should be released subject to narrowly tailored redactions of the names, likenesses, and identifying information of the victims. The Court should not, however, rubber stamp redactions to withhold from the public "information related to third parties who neither have been charged or alleged to be involved in the crimes with which Epstein and Maxwell were charged," Epstein Dkt. No. 66 at 7. Any effort to redact third party names smacks of a cover up. The Government does not elaborate on what protocol it is using to redact other "third party" names or which types of individuals it seeks to protect in this way. To the extent the Government for some reason seeks to redact the names of other Epstein and Maxwell affiliates on the basis that these individuals "neither have been charged or alleged to be involved" in their crimes, the Court should exercise its independent authority to ensure that any redactions are tailored to serve compelling interests. See generally v. Maxwell, 929 F.3d 41, 50 (2d Cir. 2019) (even if materials are not considered judicial documents to which a presumption of public access applies, "a court must still articulate specific and substantial reasons for sealing such material"). + +#### A. Redactions of the Names and Identifying Information of the Victims Is Appropriate. + +The privacy interests of and other victims (as victims of sex abuse and human trafficking) are strong. In v. Maxwell, Judge Preska repeatedly recognized the "gravity of the privacy interests" of "victims of Jeffrey Epstein's sexual abuse." v. Maxwell, 2020 U.S. Dist. LEXIS 221599, at \*16 (S.D.N.Y. Nov. 25, 2020). The Court explained that "[t]hose interests are particularly acute given that the psychological and emotional wellbeing of survivors of alleged sexual assaults may be implicated by such a broad disclosure." v. Dershowitz, 2020 WL 5439623, at \*2 (S.D.N.Y. Sept. 9, 2020). And "[t]hose interests weigh no less heavily" where "it is law enforcement seeking modification of the protective order instead of a private litigant." v. Maxwell, 2020 U.S. Dist. LEXIS 221599, at \*16. In Doe I v. JP Chase Bank, N.A., Judge Rakoff recently found that the privacy interest of a victim of Epstein justified sealing because "[p]rotecting the identity of sexual assault survivors and the details of their assaults is traditionally considered private and has been widely recognized as a compelling reason to limit public access to [even] judicial documents." 742 F. Supp. 3d 387, 397 (S.D.N.Y. + +![](_page_4_Picture_1.jpeg) + +2024). Thus, and other victims' privacy interests as victims of Epstein and Maxwell weigh heavily in favor of the redactions of the victims' names and identifying information. + +#### B. Redactions of Names and Information Relating to Epstein and Maxwell's Co-Conspirators Are Improper. + +The Government's original motion refers to a July 6, 2025 Memorandum that concluded that no evidence could predicate an investigation into uncharged third parties associated with Epstein's and Maxwell's criminal scheme. Epstein Dkt. No. 61 at 1-2. The Government purports to seek the unsealing of the grand jury transcripts to provide transparency for the public into the conclusions reached by the Memorandum. Id. To be clear, we do not agree that there is insufficient evidence to support investigations into third parties who enabled Epstein's and Maxwell's crimes and participated in them. Numerous individuals have yet to be investigated and several civil cases have been filed addressing other individuals' central involvement with Epstein's and Maxwell's sex trafficking. + +As the Court acknowledged, there are "over one thousand victims" of Epstein's and Maxwell's crimes. Epstein Dkt. 63 at 4. Less than one-fifth of these victims have been compensated for the crimes committed against them, either through the now-closed Epstein Victims Compensation Fund or otherwise. To rectify this, there have been numerous civil cases filed that address third parties' central involvement with Epstein and Maxwell's sex-trafficking crimes. See Doe 1 v. JP Chase Bank, N.A., Case No. 22-cv-10019 (S.D.N.Y.), Doe 1 v. Deutsche Bank Aktiengesellschaft, Case No. 22-cv-10018 (S.D.N.Y.); Doe 3 v. Indyke, Case No. 24-cv-01204 (S.D.N.Y.). To the extent any of Epstein's and Maxwell's enablers and coconspirators who have thus far evaded accountability are implicated by the grand jury transcripts, their identities should not be shielded from the public. Though "[t]he privacy interests of innocent third parties" like the victims should be redacted, see Gardner v. Newsday, Inc., 895 F.2d 74, 79 (2d Cir. 1990), there should be no similar protection for those third parties accused of wrongdoing. + +\*\*\* + +strongly supports the release of Epstein's and Maxwell's grand July transcripts, subject to appropriate redactions of the victims' names and identifying information. Unsealing the grand jury transcripts serves the interests of transparency, accountability, and restorative justice. + +Respectfully submitted, + +/s/ Sigrid S. McCawley Sigrid S. 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Berman Southern District of New York Daniel Moynihan United States Courthouse 500 Pearl Street Courtroom 17B New York, NY 10007-1312 + +Telephone (954)524-2820 Fax (954)524-2822 info@cvlf.com Brad@cvicom Brittany@cvlticom + +August 5, 2025 + +Via Email: BennanNYSDChambers@nysd.uscourts.gov Grady\_MacPhee@nysd.uscourts.gov USANYS.EpsteinMaxwellVictims@usdoj.gov New York Office + +By Appointment Only + +Docket and file. + +SO ORDERED: +Date: 8/5/25 + +*Richard A. Berman* +Richard M. Berman, U.S.D.J. + +RE: Crime Victims' Rights Act Implications Regarding Unsealing of Grand Jury Materials in Epstein Proceedings + +Case: United States of America v.Jeffrey Epstein Case No.: 19 CR 490 (RMB) + +DearJudge Berman: + +We represent numerous survivors ofleffrey Epstein, including several individuals whose names and identifying information appear in the subject materials. In that vein, we write to address the Department of Justice's request to unseal grand jury materials and to respectfully urge the Court to administer any disclosure in a manner that fully honors the victims' rights under the Crime Victims' Rights Act ("CVRA"), 18 U.S.C. § 3771, the enduring interests protected by Federal Rule of Criminal Procedure 6(e), and Eleventh Circuit precedent. + +- I. Victims' CVRA Rights Are Directly Implicated and Must Be Considered in Context— Not in a Vacuum + +The CVRA guarantees victims: + +Honorable Richard M. Berman + Case No: 19 CR 490 (RMB) + Page 2 + +--- + +- • The right to be reasonably protected from the accused (§ 3771(a)(1)); +- • The right to be heard at any public proceeding involving release, parole, or sentencing (§ 3771(a)(3)); +- • The right to confer with the attorney for the Government (§ 3771(a)(5)); and, +- • The right to be treated with fairness and respect for dignity and privacy (§ 3771(a)(8)). + +*See also Kenna v. U.S. Dist. Court*, 435 F.3d 1011, 1016–17 (9th Cir. 2006) (fairness and dignity are substantive, enforceable rights); *In re* [redacted], 527 F.3d 391, 394–95 (5th Cir. 2008) (government must confer with victims before making consequential case decisions); *In re* [redacted], 994 F.3d 1244 (11th Cir. 2021) (en banc) (confirming that CVRA protections are fully attached post-conviction). + +Given our history fighting for the enforcement of the CVRA on behalf of Jeffrey Epstein’s many victims, we were quite surprised to learn that the government sought the unsealing of grand jury materials before this Court without first conferring with the victims or their counsel, a step required by the CVRA and reinforced by *Doe v. United States*, 08-80736 (S.D. Fla.). That case, litigated pro bono by undersigned counsel for more than a decade, arose precisely because the government previously violated the rights of many of these very same victims. It is especially troubling that, despite the outcome of that litigation, the government has once again proceeded in a manner that disregards the victims’ rights—suggesting that the hard-learned lessons of the past have not taken hold. This omission reinforces the perception that the victims are, at best, an afterthought to the current administration. + +Of significant concern, the same government that failed to provide notice to the victims before moving this Court to unseal the grand jury materials is now the government representing to this Court that it has provided appropriate notice to the victims or their counsel and has conducted a proper review and redaction of the materials it seeks to release. Several clients have contacted us expressing deep anxiety over whether the redactions were in fact adequate. Consequently, we requested yesterday that the government identify which of our clients were referenced to the grand jury. The government responded promptly and provided clarification. However, we have strong reason to believe that additional individuals—whom we also represent—were likely referenced in those materials but were not identified to us by the government. + +It remains unclear whether notice was instead provided to prior counsel, whether their omission was a government oversight, whether the government does not consider them to be victims, or whether these individuals were, in fact, not mentioned to the grand jury. Regardless of the explanation, this ambiguity raises a serious issue that must be resolved before any materials are publicly released. + +Against this backdrop, any disclosure of grand jury material—especially material that could expose or help identify victims in any way—directly affects the CVRA’s fairness, privacy, conferral, and protection guarantees. To ensure those rights are protected, it is essential that the protocol outlined in the relief requested below is adopted by this Court. + +## 11. Rule 6(e) and Eleventh Circuit Authority Require Heightened Caution and Narrow Tailoring. + +Grand jury secrecy is a "long-established policy" safeguarded by Rule 6(e). Douglas Oda. v. Petrol Stops Nw., 441 U.S. 211, 219-23 (1979). Even where disclosure may be considered, the mount must establish a particularized need that outweighs the countervailing interests in secrecy, and any disclosure should he no broader than necessary. Id. at 222-23. The Eleventh Circuit has further held that district courts lack inherent authority to order grand jury disclosure outside the exceptions in Rule 6(e). Pitch United States, 953 F.3d 1226, 1237-38 (11th Cir. 2020) (en bane); see also McKeever v. Ban; 920 F.:3d 842, 845-46 (D.C. Cir. 2019). + +Here, even if the Court were to find a Rule 6(e) path to limited disclosure, victims' CVRA rights and the traditional interests protected by grand jury secrecy converge in favor of extraordinary care: rigorous judicial screening, robust redactions, minimization of any risk of re-identification, and meaningful victim participation before anything is made public. Related privacy provisions reinforce this approach. See, e.g., 18 U.S.C. § 3.509(d)(2) (authorizing protective orders to shield child-victims' identities and "other information concerning a child"); Fed. R. Crim. P. 49.1 (privacy redactions). Many Epstein victims were minors at the time of the abuse; even for those now adults, § 3771(a)(8) and the Court's protective authority warrant safeguards that functionally align midi § 3.509(d) principles. + +## III. Requested Relief + +In light of the foregoing, the victims respectfully request that the Court: + +- I) Require Conferral and Notice (CVRA SS 3771(a)(3), (c)(1)): Direct the Government to confer with victims' counsel and provide reasonable notice and an opportunity to be heard before any ruling on unsealing or public release of grand jury materials. +- 2) Judicial In Camera Review: Conduct a comprehensive in camera review of the grand jury materials to determine whether the proponent has shown a Rule 6(e)-compliant basis for any disclosure and, if so, the narrowest scope of disclosure consistent with Douglas Oil. +- 3) Victims' Counsel Pre-Release Review (Under Protective Order): Permit designated victims' counsel to review the government's proposed redactions and any index of materials under a strict protective order, to allow victims' counsel to identify and prevent: (a) direct identifiers, + - (b) combinations of data points that could reasonably lead to re-identification or harassment of victims, and (c) to propose all additional redactions necessary. +- 4) Dispute Resolution before Unsealing or Release: If the government does not agree with additional proposed redactions from victims' counsel, provide victims' counsel die opportunity to be heard on any dispute before ruling on unsealing or public release. + +Honorable Richard M. Berman +Case No: 19 CR 490 (RMB) +Page 4 + +--- + +- 5) Defer or Deny Without Prejudice if Safeguards Cannot Be Assured: If adequate safeguards cannot be implemented consistent with Rule 6(e), *Pitch*, and the CVRA, deny disclosure without prejudice. + +IV. Conclusion + +The survivors support transparency when it can be achieved without sacrificing their safety, privacy, or dignity. But transparency cannot come at the expense of the very people whom the justice system is sworn to protect—particularly amid contemporaneous events that magnify risk and trauma. Several victims have already died by suicide, drug overdose, or under tragic circumstances tied directly to the trauma caused by Jeffrey Epstein and Ghislaine Maxwell. These survivors have already endured profound violations of their rights and dignity, both during the years of Epstein's abuse and in the years following. To now compound their trauma by sidelining them from critical decisions—especially in this climate of heightened concern—is inconsistent with both the letter and the spirit of the CVRA. + +The CVRA, Rule 6(e), and Eleventh Circuit authority all point toward narrow tailoring, maximal privacy protections, and meaningful victim participation before any grand jury material sees daylight. We respectfully ask the Court to adopt the safeguards outlined above. + +Respectfully submitted, + +![]()![]()425 North Andrews Avenue, Suite 2 +Fort Lauderdale, Florida 33301 +Telephone: (954) 524-2820 +Email: [brad@cvlf.com](mailto:brad@cvlf.com) +[brittany@cvlf.com](mailto:brittany@cvlf.com) + +Paul G. Cassell +Utah Appellate Project +S.J. Quinney College of Law at the University of Utah +383 S. University St. +Salt Lake City, UT 84112-0300 +Tel: 801-580-6462 +Email: [pgcassell.law@gmail.com](mailto:pgcassell.law@gmail.com) + +*(institutional address for identification purpose only, not to imply institutional endorsement)* \ No newline at end of file diff --git a/marker2/court-us-v-epstein-cr/EFTA02824649/EFTA02824649.metadata.json b/marker2/court-us-v-epstein-cr/EFTA02824649/EFTA02824649.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d179f3b94147434f2d6b21e63341e1a28576b4d1 --- /dev/null +++ b/marker2/court-us-v-epstein-cr/EFTA02824649/EFTA02824649.metadata.json @@ -0,0 +1,283 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-us-v-epstein-cr/EFTA02824649.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 9669, + "elapsed_seconds": 11.73, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "MEMO ENDORSED", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 39.168000000000006, + 190.35 + ], + [ + 177.95831298828125, + 190.35 + ], + [ + 177.95831298828125, + 206.2330322265625 + ], + [ + 39.168000000000006, + 206.2330322265625 + ] + ] + }, + { + "title": "11. 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