DOJ-OGR-00000608.pdf

--- Page 1 --- The extracted text is: **Header:** * Case13:19-cr-00490-RMB * Document 40 * Filed 07/26/19 * Page 4 of 6 **Text:** 1. the compelling testimony of Annie Farmer and Courtney Wild, who testified that they fear for their safety and the safety of others if Mr. Epstein were to be released. 2. I also point out that the presumption of remand, as opposed to the presumption of release, is unusual in our jurisprudence and that it attaches only to very serious crimes, such as sex trafficking involving minor victims, as in this case some allegedly as young as age 14. 3. I also discuss evidence of intimidation and threats and compensation paid to potential witnesses and the facts surrounding whether or not Mr. Epstein has been compliant with his legal obligations as a registered sex offender. 4. When discussing risk of flight, which you obviously can tell comes after, in my analysis, dangerousness to the community, when discussing that aspect, risk of flight, the decision speaks to the seriousness of the charged crimes, to Mr. Epstein's great wealth and his vast resources, which include private planes and frequent international travel and also a foreign residence in Paris. 5. I mention the items very recently seized from Mr. Epstein's New York City mansion pursuant to lawful search warrants, which include sexually explicit photos and discs, some $70,000 in cash, diamonds, and an expired Austrian passport with Mr. Epstein's photo but with a name that is different from Jeffrey Epstein, and also contains a reference **Footer:** * SOUTHERN DISTRICT REPORTERS, P.C. * (212) 805-0300 * DOJ-OGR-00000608