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Case 1:19-cr-00490-RMB Document 36
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guaranteed bail to anyone who wasn't
(e)
fFfense,
tention impairs a
Case 1:19-cr-00490-RMB Document36- Filed 07/24/19 Page 19 of 74 ie
1 defendant.
2 THE COURT: Could you go back to those Florida police
3 reports and tell us what you think they demonstrate.
4 MR. R
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Case 1:19-cr-00490-RMB Document 36
assure the
your Honor
With respect to danger to
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Case 1:19-cr-00490-RMB Document 36
representing
even a fraction of
Filed 07/24/19
his wealth.
TH!
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don't really
COURT: i
Case 1:19-cr-00490-RMB Document 36
Filed 07/24/19
Page 17 of 74 17
1 your Honor. It does raise the question of how many other safes
2 are there in how many other locations with items like these.
3
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Case 1:19-cr-00490-RMB Document 36
include a list of
It does not include a list of
Case 1:19-cr-00490-RMB Document 36
Filed 07/24/19
Page 14 of 74 1a
we
our
And that additional
was already indicted by a grand
£ dozens of alleged
Ficant corroborated
for which this
prison.
Case 1:19-cr-00490-RMB Document36 _ Filed 07/24/19
Page 13 of 74 1
1 obtained records from a financial institution that has been
2 associated with the defendant confirming that the defendant
3 rep
Case 1:19-cr-00490-RMB Document 36
Filed 07/24/19
Page 11 of 74
11
1 provided no specific detailed financial information in its
2 submission. I'll get into that in a little bit more ina
3 moment
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Case 1:19-cr-00490-RMB Document36 _ Filed 07/24/19 Page 10 of 74 10
the defense wha
ay
Case 1:19-cr-00490-RMB Document36 _ Filed 07/24/19
legal or administrative proceedings i
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Case 1:19-cr-00490-RMB
Document 36
Filed 07/24/19 Page 9 of 74 2
1 not do that.
2 Four, the government, as you probably know, has
3 conducted a search of Mr. Epstein's home on East Vist Street on
4
Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 7 of 74 7
1 So the question is the following: Mr. Epstein has
2 been required to register as a sex offender in several states
5 going back I b
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Case 1:19-cr-00490
presumption that bail will be granted.
respect to the charges here.
The presumption of
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Case 1:19-cr-00490-RMB
Document 36
heard on their respectiv
The government always
Case 1:19-cr-00490-RMB
Document 36
Filed 07/24/19
Page 4 of 74 4
1 required and the safety of the community." It goes on to
2 conclude that: "Therefore, pretrial services respectfully
3 recommends
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Case 1:19-cr-00490-RMB
THE COURT:
For your
information and for the people sitting in the
Document 36 Filed 07/24/19 Page 3of 74 a
Good morni
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Jase PAQ-cr-00490-RMB
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David
Boies
Brad
Fdwards
Paul
U.S.
Byrne,
Amanda
Case 1:19-cr-00490-RMB”™ Document 32-T_ Filed O/7/I8/IJ- Page Zora
Case 9:08-cv-80736-KAM Document 361-11 Entered on FLSD Docket 02/10/2016 Page 3 of 3
the use of the addressee. It is the property o
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 30 of 33
(2) The defense bail package proposes excessive involvement of the Court in routine
aspects of Mr. Epstein’s proposed home confinement.
Case 1:19-cr-00490-RMB Document 32 _ Filed 07/18/19 Page 32 of 33
Defendant and their purported role as independent monitors. (The same problem arises in
relation to private 24/7 security guards.) Th
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 33 of 33
Conclusion & Order
Based upon the forgoing, the Government’s motion for remand (detention) is granted and
the Defense motion for pretr
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 29 of 33
The Court finds that the Defendant’s proposed bail package is inadequate. Among its
deficiencies are these:
(1) The bail package is no
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 28 of 33
incorporated here by reference. See Minnici, 128 F. App’x at 829-30 (“the alleged activities
[we]re of an addictive sexual nature that
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 27 of 33
David Boies, who, as noted, represents identified victims in this case, advised the Court
that while a civil case was proceeding agains
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 25 of 33
“Defendant is currently, or has been in the past, a citizen or legal permanent resident of a country
other than the United States.” Dkt
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 26 of 33
$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
Case 1:19-cr-00490-RMB Document 32 _ Filed 07/18/19 Page 24 of 33
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 i
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 22 of 33
United States v. King, 849 F.2d 485, 488 (11th Cir. 1988) (quoting United States v. Portes, 786
F.2d 765 (7th Cir. 1985)). The Court f
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 20 of 33
was unanimously affirmed, on November 17, 2011, by a panel of five judges of the Appellate
Division of the New York State Supreme Court
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 21 of 33
release he would have been brought back to the Stockade and work release would have been
terminated.” Chuck Weber, PBSO disputes claim
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 19 of 33
(“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”)
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 18 of 33
payments appears to be recurring or repeating during the approximately five years of bank
records presently available to the Government
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 15 of 33
underage before or during the period in which he abused them.” Id. The crimes with which Mr.
Epstein is charged carry a maximum sentenc
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 14 of 33
reasonably assure . . . the safety of the community” if Mr. Epstein is released. Pretrial Services
Report, dated July 8, 2019, at 4. Pr
Case 1:19-cr-00490-RMB Document 32 _ Filed 07/18/19 Page 13 of 33
*10 (D.D.C. May 22, 2019). The presumption of remand “reflects Congress’s substantive
judgment that particular classes of offenders
Case 1:19-cr-00490-RMB Document 32 _ Filed 07/18/19 Page 12 of 33
Mr. Epstein’s future behavior will be consistent with past behavior, including the trove of “lewd
photographs of young-looking women
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 11 of 33
Epstein victims would “continu[e] to be victimized” and that Mr. Epstein’s wealth and privilege
and notoriety would make it difficult f
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 10 of 33
community (by clear and convincing evidence) and that Mr. Epstein presents a risk of flight (by
a preponderance of the evidence). Id. E
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 9 of 33
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
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 8 of 33
i
{
t
i
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 Sta
Case 1:19-cr-00490-RMB Document 32 _ Filed 07/18/19 Page 5of33 |
live in Mr. Epstein’s residence and report any violation to Pretrial Services and/or the Court”,
(14) “Any other condition the Court d
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 6 of 33
trust account to... , [an individual] who was also named as a potential co-conspirator.” Id. at 1-
2. According to the Government, the s
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 4 of 33
Defense proposes what they describe as “‘a stringent set of [14] conditions that will effectively
guarantee [Mr. Epstein’s] appearance a
Case 1:19-cr-00490-RMB Document 31 _ Filed 07/18/19 Pageiof1
LAW OFFICE OF
MARC FERNICH
MARC FERNICH [email protected]
ALSO ADMITTED IN MASSACHUSETTS
July 18, 2019
BY ECF
Hon. Richard M. Berman
U
Case 1:19-cr-00490-RMB Document 25-1 Filed 07/17/19 Page 2 of 2
(gam | NEW MEXICO KG»
DEPARTMENT OF PUBLICSAFETY Gee
POST OFFICE BOX 1628 * SANTA FE, NEW MEXICO 87504-1628
Orrict or tHe Secacrary Sa
Case 1:19-cr-00490-RMB Document 25-2 Filed 07/17/19 Page1of8
EXHIBIT B
DOJ-OGR-00000458
Case 1:19-cr-00490-RMB Document 25-1 Filed 07/17/19 Page1of2
EXHIBIT A
DOJ-OGR-00000456
Case 1:19-cr-00490-RMB Document 25 _ Filed 07/17/19 Page 2of2
Martin G. Weinberg (pro hac vice)
Martin G. Weinberg, P.C.
20 Park Plaza, Suite 1000
Boston, MA 02116
(617) 227-3700
Fax: (617) 338-9
Case 1:19-cr-00490-RMB Document 24 _ Filed 07/16/19 Page /7of9
Hon. Richard M. Berman
July 16, 2019
Page 7
Seventh, to the extent third-party counsel (Mr. Boies) speculated
that the November 28 and