EFTA00028785.pdf

"The defendant is a serial sexual predator who is charged with abusing underage girls for years... sexually exploited dozens of minors, including girls"

"Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)"

"charging the defendant with violating Title 18, United States Code Section 1519, and conspiracy to commit the same."

"The Government respectfully submits this letter in response to the defendant's Motion for Pretrial Release"

"The Honorable Richard M. Berman United States District Court Southern District of New York... Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)"

"he paid the victims hundreds of dollars in cash, in at least two different states"

"the defendant actively encouraged certain victims to recruit additional girls to be similarly sexually abused. He paid these victim-recruiters hundred"

"nude and seminude photographs of young females in his Manhattan mansion on the night of his arrest"

"The promise to deregister or otherwise ground his private jet"

"the defendant should be detained pending trial. He poses a tremendous risk of flight and a danger to the community"

"Case 1:19-cr-00490-RMB ... Honorable Richard M. Berman United States District Judge"

"records relating to the defendant recently obtained by the Government from a financial institution (Institution-1), more than $500 million. ... He alr"

"The defendant proposes that the Court accept his Manhattan mansion as the primary security for a personal recognizance bond"

"to be co-signed by the defendant's brother"

"Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19... the defendant"

"commission of the sex trafficking offenses charged there. See 18 U.S.C. § 1594(c)(1)."

"the defendant's Manhattan mansion has been identified in the Indictment as subject to forfeiture"

"while the defendant offers to also pledge his private jet as additional collateral"

"the property of his brother, Mark"

"the property of his brother, Mark (the Palm Beach Property)"

"Honorable Richard M. Berman United States District Judge"

"to be co-signed by the defendant's brother and a friend."

"the private jail-like concept envisioned by defendant... Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19"

"Honorable Richard M. Berman United States District Judge Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19"

"discs found in the defendant's residence"

"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 "

"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"

"identified as one of the defendant's employees in the Indictment."

"the defendant's signature ... provided for in the NPA"

"Case 1:19-cr-00490-RMB ... counsel for defendant"

"Case 1:19-cr-00490-RMB ... Honorable Richard M. Berman United States District Judge"

"Martin Weinberg, Esq., and Reid Weingarten, Esq., counselfor defendant"

"Martin Weinberg, Esq., and Reid Weingarten, Esq., counselfor defendant"

"the defendant's maintenance of a substantial collection of photographic trophies of his victims and other young females in his mansion"

"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 "

"GEOF REY S. BERMAN United States Attorney ... Assistant United States Attorney Southern District of New York"

"the Government ... recommend pretrial detention due to the unusual and concerning confluence of factors in this case"

"He already earns at least $10,000,000 per year ... while living in the U.S. Virgin Islands"

"traveling extensively abroad, and residing in part in Paris, France"

"to be co-signed by the defendant's brother and a friend"

"recently sold a second plane and thus presumably has cash on hand"

"the parent of one of the defendant's victims was driven off the road by a private investigator"

"the parent of one of the defendant's victims was driven off the road by a private investigator."

"the defendant wired $100,000 from a trust account he controlled... Records obtained by the Government from Institution-1"

"the offense with which he is charged. ... Section 1591 applied to both suppliers and consumers of commercial sex acts."

"a lack of criminal record for any defendant would automatically rebut the presumption applicable to crimes such as sex trafficking"

"reported against an individual who was directly in contact with an assistant of the defendant"

"pressure tactics were at the vet), least coordinated closely with individuals in the defendant's orbit"

"Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, N.Y. Post (2011)"