EPSTEIN
page 7 / 28 . OCR, unverified
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 an1ount 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 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"; (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"; (11) "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
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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. 11 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."
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-I 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
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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.