EFTA00080486

Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 7 of 10 
Honorable Henry Pitman 
United States Magistrate Judge 
July 8, 2019 
Page 7 
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. Anderson, 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 
EFTA00080506

Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 8 of 10 
Honorable Henry Pitman 
United States Magistrate Judge 
July 8, 2019 
Page 8 
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. Anderson, 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(e)(3). 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 
EFTA00080507

Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 9 of 10 
Honorable Henry Pitman 
United States Magistrate Judge 
July 8, 2019 
Page 9 
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 then-
counsel 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 "forcied] 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 partially-
nude 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]," "Misc nudes 1," and "Girl pics nude." The defendant, a 
registered sex offender, is not reformed, he is not chastened, he is not repentant;6 rather, he is a 
continuing danger to the community and an individual who faces devastating evidence supporting 
deeply serious charges. 
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."). 
EFTA00080508

Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 10 of 10 
Honorable Henry Pitman 
United States Magistrate Judge 
July 8, 2019 
Page 10 
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 tates Attome 
By: 
Assistant United States Attorney 
Southern District of New York 
Tel: 
Cc: 
Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant 
Hon. Richard M. Berman, United States District Judge 
EFTA00080509

Date: 
Time: 
Case 1:19-cr-0040-RMB Document 11-2 Filed 07.19 Page 1 of 2 
BEACH POLICE DEPARTMEN 
Incident Report 
Page: 
Program: 
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 
of the 
private investigators following 
however; 
I received. other phone calls from 
and 
who 
advised they were able to acquire the private investigators license 
plate information. The subject following them was again driving very 
aggressively and caused 
to run off the road. 
stated 
the vehicle is a green Chevy 
bearing Florida tag 
of 
Florida. 
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 Florida State 
he exact dates of Spring Break 
.. The Spring Break 
was from March 4, 2006 through March 12, 2006. I received a sub oena 
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 on 
, 2006, 
made and received thirty 
five calls during that day. 
The vehicle is registered to 
-06 11:03 AM 
492 
IIIIIV06 11:16 AM 
6 
06 11:22 AM 
887.2 
-06 11:37 AM 
48 
111111[06 11:39 AM 
28.2 
-06 12:02 PM 
727.2 
Dat 
Time 
Seconds 
In/Out 
Outbound 
Inbound 
Inbound 
Outbound 
Inbound 
Inbound 
The table reflects the date of the calls, time of day (EST), duration 
To/From 
EFTA00080510

Case 1:19-cr-00490-RMB Document 11-2 Filed 07/1 19 Page 2 of 2 
likiM BEACH POLICE DEPARTMEN 
Incident Report 
Date: 
Time: 
Page: 
Program: 
Case No 
 
(Continued) 
of call in seconds, inbound or outbound calls and calls made to or 
from 
phone. On 
, 2006, at 11:03 am, 
made a call 
to the victim Illwhich 111111192 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 
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, 
makes 
a call to  
, 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, 
 
 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 
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 
of 2006. I also noted that there was no 
further contact with 
or Jeffrey Epstein during the 
remainder of the month of 
2006. 
On 
2006, 
tele honed me to inform me of the 
meeting that occurred with Att . 
and 
reference 
this case. 
Inv Continues. 
EFTA00080511

Case 1:19-cr-00490-RMB Document 11-3 Filed 07/12/19 Page 1 of 2 
ate: 7/19/06 
PALM BEACH POLICE DEPARTMENT 
ime: 15:01:37 
Page: 
82 
Incident Report 
Program: CMS301L 
1************************NARRATIVE 
# 42 ********* ***************** 
Reported By: RECARSY, JOSEPH 
4/14/06 
Entered By.: ALTOMARO, NICKIE A. 
4/18/06 
The Grand Jury Subpoenas were personally served to the individuals 
they were issued to. On April 5, 2006, at approximately 7:30 p.m., I 
oersonally served the parents ofellawho had informed me that the 
)rivate investigators were still photographing the family. On April 
EFTA00080512

Case 1:19-cr-00490-RMB Document 11-3 Filed 07/12/19 Page 2 of 2 
ite. 7/19/06 
PALM BEACH POLICE DEPARTMENT 
Page: 
83 
[me: 15:01:37 
Incident Report 
Program: CMS301L 
Ise NO 
• 1-05-000368 
(Continued) 
10, 2006, at approximately 2:30 p.m., I served...bat her residence in 
The subpoena was given to her mother, IMO 
I learned through one of the victims 4M that she was personally 
contacted through a source that has maintained contact with Epstein. 
The source assuredflshe would receive monetary compensation for her 
assistance in not cooperating with law enforcement. 
also stated 
she was told, "Those who help him will be compensated and those who 
hurt him will be dealt with." I told...What tampering with a 
witness/victim is an arrestable offense and very serious. I asked her 
who approached her during this encounter. amooriginally 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 victimAIMMOOW identified Sas 
W/F, 
as the person who approached her in Royal Palm Beach while 
ie!elftle during Spring Break in March 2006. 
also stated she 
did not want to pursue the intimidation charges on MOW diftwas 
concerned that the defense attorney was given a copy of the report as 
certain things she had told me in confidence were repeated to her by 
EFTA00080513