Bail Hearing - Government Memorandum (Detention)

GOVERNMENT'S MEMORANDUM IN SUPPORT OF PRETRIAL DETENTION Case: USA v. Epstein, No. 19-cr-490 (S.D.N.Y.) The Government respectfully submits this memorandum in support of its application for pretrial detention of the defendant, Jeffrey Epstein. ARGUMENTS FOR DETENTION: I. FLIGHT RISK - Net worth exceeding $500 million - Private aircraft and pilot's license - Multiple residences including international property (Paris) - Foreign bank accounts and financial holdings - Fake passport discovered in safe with Saudi Arabia as country of residence II. DANGER TO COMMUNITY - Dozens of identified minor victims - Pattern of predatory behavior spanning years - Prior conviction in Florida (2008) did not deter continued conduct - Evidence of victim tampering and intimidation III. NATURE AND SERIOUSNESS OF CHARGES - Maximum sentence of 45 years imprisonment - Charges involve exploitation of minors - Extensive and sophisticated criminal enterprise EVIDENCE FROM SEARCH OF 9 EAST 71ST STREET: - Nude photographs of underage-appearing females - Compact discs with handwritten labels referencing individuals - Fake Austrian passport with Epstein's photo but different name - Large quantities of cash and diamonds Judge Berman denied bail on July 18, 2019, ordering Epstein detained. Source: Court Filings / DOJ Available at: https://www.justice.gov/epstein/court-records