DOJ-OGR-00000788.pdf

--- Page 1 --- The extracted text is: **Case 1:18-cv-22019-RMB Document 3201 Filed 07/18/19 Page 5 of 33** **Case 1:18-cv-22019-RMB Document 3201 Filed 07/18/19 Page 5 of 33** 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." Id. 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-1 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...