This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →
FBI VOL00009
EFTA00076815
25 pages
Pages 21–25
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326
4,i FEDERAL SUPPLEMENT, 3d SERIES
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 continu-
ing to do whatever it is he does to earn his
vast wealth from a computer terminal be-
yond 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 allega-
tion 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 "trus-
tees" 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 re-
lation 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 asso-
ciates who facilitated his exploitation of
minors, by among other things, contacting
victims and scheduling their sexual en-
counters with the defendant, both in New
York and in Florida." Dkt. 11, Ex 1 at 2.
(6) "As a fallback," the Defense sug-
gests 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 be-
havior. This contingency plan is not a part
of Mr. Epstein's 14 point proposal. Never-
theless, the Court is asked by the defense
to "revisit" its legal viewpoint as expressed
in an earlier decision concerning 24/7 pri-
vate home security guards.
[181 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,
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 elimi-
nate the danger to the community or are
superior to detention for purposes of the
Bail Reform Act."); United States v. Co-
lombo, 777 F2d 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 com-
munity.").
Conclusion & Order
Based upon the forgoing, the Govern-
ment's motion for remand (detention) is
granted and the Defense motion for pre-
trial release is denied.
Attachment
EFTA00076835
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U.S. v. EPSTEIN Cite .s425 F.Supp3d 306 (S.D.N.Y. 2019) Attachment—Continued Case 0 013cv.907303•KAM Document 361.11 Entered ors FLSD Docket 02/1(V2016 Page 2 of 3 ant Jute Par lahowir !Annan: kirstrip cool 200flfs 6000 - I .ill be al 7400. set's talk at 9 sm. Already thickly Idol the sane statutes. Look ferhar0 to Speaking In the manning. Pest: 269. From: Sent: 09/11/2607 07.26 PM AST To: LeAtiOalli Subject: at: at fl y .• NITS, I am. I hay* Dan soenishs Same Canty ties oath iltle IS local% fa- alsdemearkws. Do you want totakea loon at as us( 4.11, 16 use isia(o), asdailet 22)(4)(3)(0) and we tan talk aboet then togorro6? : knOw that Saone Mentioned) there being Unity on an airplane. I just want to hake Sure tilt there IS factual Oasis tor the pile 1 1 t the &testi can confer.. I. rot sore exactly sore I will Se tomirrofhprnlall. SO IS It alright if I Cull youe eat. a good evOillall. sssss )ay le1tOwitt (maill0:)lefiOkitt0t1/110, 0.600. to M - AY you free to waft at 9 as toomat? Thanks. 3my e Information «ntaine0 in this chenkakation is confidential: may be attornerclieet privileged: esti COAStitote Inside information: and IS intended Only for P IAA J.IPA 327 EFTA00076836
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328 42s FEDERAL SUPPLEMENT, 3d SERIES Attachment—Continued Case 0:0B-cv-60736.KAM Doanent 361.11 Entered on FLSD Docket 02/102016 Page 3 cd 3 the use of the addressee. It is the PreParte of Kirkland g (Ills lip or Kirkland $ Ellis Internetkeel LW. unauthorized use, disclosure or copying of this eoter unlcation or any part thereof is strictly prohibited lm say be unlawful. If you have received this Ration in error, please notify us immediately by return e.mall or by e•aeil to postfiestergkirkland.coe, zed destroy this cominication and all copies thereof, including all attachments. The Infonetloo contained in this conmeatication is confidential, say be attorney-client privileged, say constitute inside information, and is intended only for the use of the addressee. It Is the property of mid a jilts Li, or Kirkland & kills International lip. Unauthorized use, disclosure or cowing of FhIS ttehhetrettehoranY part thereof is strictly prohibited and say be unlawful. If you have received this corinunication in error, please notify us iniediataly by return freell or by •-seil to posteastorilkireland.coe are destroy this communication awl all copies thereof, including all attachments. • • Pi • 1.1403.11le EFTA00076837
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U.S. v. EPSTEIN Cite .s623 F.Supp3d 306 (S.D.N.Y. 2019) Attachment—Continued Case 908-cv60736-KAM Document 361-10 Emoted on FLSD Docket 02/10,2016 Page 2 of 2 *mom lueihMt. WPM*. 111. 2C0/ 8 m Ake Jay Lelkontz* Omit ameemmts" II. lugs hoping there would be things for Inc to read this morning. but I will ay to remain patien I believe there are only Iwo types of speernents that would apply to ibis case (I) a plea ;Lineman to a :kderal charge or charges; and t2) a nun-prosecution agrcemeal (which is really a deferred prosecution agreement because the defendant agrees chit if he violases the agreement. the US Can prosecute him). A plea agramem is part of the coon file. It is not accessible on-line Ss PACER. but someone cm go to the Clcdes Office to obtain, copy. A non-proseeution agreement would not be made public x tiled with the Cost bin it *oak: remain pin oroa case file. h probably would be subject to a FOIA ropes. but ti is no winch ng that we would distnhie without compulsory process On the et utmccien charges. many of the fats I included S that first Troffer were hypothesized based icon our die:onions and the ages etecruutime of We will need ha inlets icw her IC confine, 'he accvnicy of those facts led a second count. we ould rely on the incident wbcre Mr. Epascin's private investigators followed MSfather forcing him off the road. Or, if litre is something mom mom related to any NM we could consider ope that helps. re SA 008to. 329 EFTA00076838
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330 425 FEDERAL SUPPLEMENT, 3d SERIES Attachment—Continued 0 9O8-cv-60736.KM! Document 361-9 Fitted on FLSO Docket 02/10/2016 Page 2 of 2 Jay Leftover illersarmsastIttra conS . Pint agroornerea Confidential • Foe settlement merpows only Still winking en redline aut pit lank at this On August 200. FRI Spinal Agrrn rave£J to the ha of vestgatiai send am it. tic Southern District of Flossie. Mr. [poem wa informed °filar serske of the As a rrauk. Mr. EpSteia attempted to caner both delay and hinder that receipt ofs Ita attend an official proceeding, rsMrc panktdarly the -'to which Mr. Epstein. In Funicular. changed navel pWts and flee with both to the exited States Vein Islands rather than in an airport in New Jersey in order to attempt ty delay shot: tntipa of whit Mr. Epsteincanoed to be s Mr. Eosins (ergs' verbally harassed both ia come:Won to this allniipt to delay our Vultellaly roc c5x 0 rimoCcas all in Malaita. of IS USC !SI 2.44)( I ). ---orbaso Massa e rem: • : To: fay Letkowee Subject: RE: Draft Agreemain? iii h• limn kiwis the le<mul haw £c the litigant her AIM ar no tneronJum evaintec oleo Y. the :gems teed to tak hi Oern a,3 then lean taiga mupowl Noun proffer. I hoe c' an e nun si nasty and I an ..a in 3e;gniune ,her aviabkhr) The infomucion contained in OW communication is confidential. may he attorney-rhea Pnvtleged. may tonatatne nude information. and is totem:led only for theme of the addressee. S Is the property of . .id, Ellis LLP es Kirkland & Ell ilk.. is lawniatimal LLP. tumhorizet use, disclosure et cop)^ag of tNs . mmunication or any pan thacof is strictly whisked and may be untamful. If soo have waved this BLAKE MARINE GROUP, LLC, Plaintiff, v. FRENKEL & COMPANY, Defendant. 18-CV-10759 (AT) (CIIP) United States District Court, S.D. New York. EFTA00076839
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