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D: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:22:44 PM l • • U.S. Department of Justice United States Attorney | Southern District, ofNew York The Silvio J. Mblld Building One Saint Andrew ’s Plaza New.York- New York 10007 July 8, 2019 VTAECF The: Honorable Henry Pitman United States Distric
ly reported, the defendant is extraordinarily wealthy, and he owns and I maintains luxury properties and residences around the world, including in !Vlanhattan, New York; Palm Beach, Florida; Stanley, New Mexico; and Paris, France. Addition!ally, Epstein owns a private island in the U.S. Virgin Islands whi
h at least 2005, JEFFREY EPSTEIN enticed and recruited, and caused to be entice_d and recruited, 'oo.ze_ns. of minor girls. to visit his mansiprJ in New Yo.Jk, New·York, (the "New Y/:>rk Residence"), arid his estate in Palm Beach', Florida (the "Palm Beach Residence"),, to ,engage in sex acts with him,
2005, JEFFREY EPSTEIN enticed and recruited, and caused to be entice_d and recruited, 'oo.ze_ns. of minor girls. to visit his mansiprJ in New Yo.Jk, New·York, (the "New Y/:>rk Residence"), arid his estate in Palm Beach', Florida (the "Palm Beach Residence"),, to ,engage in sex acts with him, after which
. In this way, EPSTEIN created a vast network of underage victlms for him to sexually, exploit, .oft.en or, a dailY, l:>asis; in locations including New Yqrk c1ng Palm Beach. EPSJEIN's victims were as young as. 14 at the tim_e he abused them, and were, .for various reasons, often particularly vu Iner.abl
rings and the government is entitled to present evidence by way of proffer, among other means. See 18. U.S.C. § 3142(f)(2); see also United States v. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000) (government entitled to proceed by proffer in detention hearings); Ferranti, 66 F.3d at 542 (same); United State
ers of Sex Offenders. ice. People v. Epstein. Indict. # 30129/2010, (N.Y. Sup. Ct.), SORA Hearing Transcript, dated Jan. 18, 2011. At the hearing, New York County Assistant District Attorney Jennifer Gaffney joined in Defense Counsel's appeal to review and overturn the decision of the Board of Examiners of Sex
s not verified and does not show expenses, indebtedness, or liabilities. Law enforcement has informed the Government that a safe in the Defendant's Ncw York home very recently contained "more than $70,000 in cash ... 48 loose diamond stones, ranging in size from approximately I carat to 2.38 carats, as
ed States v. Chimurenga, 760 F.2d 400, 403 (2d Cir. 1985). "[E]ven a single incident of witness tampering .. . [may be] sufficient to revoke bail." LaFontaine, 210 F.3d at 134. To order detention based upon risk of flight, the Court must find by a preponderance of the evidence that "that no conditions cou
ers of Sex Offenders. ice. People v. Epstein. Indict. # 30129/2010, (N.Y. Sup. Ct.), SORA Hearing Transcript, dated Jan. 18, 2011. At the hearing, New York County Assistant District Attorney Jennifer Gaffney joined in Defense Counsel's appeal to review and overturn the decision of the Board of Examiners of Sex
s not verified and does not show expenses, indebtedness, or liabilities. Law enforcement has informed the Government that a safe in the Defendant's Ncw York home very recently contained "more than 570.000 in cash ... 48 loose diamond stones, ranging in size from approximately 1 carat to 2.38 carats, as
ed States v. Chimurenga, 760 F.2d 400, 403 (2d Cir. 1985). "[E]ven a single incident of witness tampering .. . [may be] sufficient to revoke bail." LaFontaine, 210 F.3d at 134. To order detention based upon risk of flight, the Court must find by a preponderance of the evidence that "that no conditions cou
ers of Sex Offenders. ice. People v. Epstein. Indict. # 30129/2010, (N.Y. Sup. Ct.), SORA Hearing Transcript, dated Jan. 18, 2011. At the hearing, New York County Assistant District Attorney joined in Defense Counsel's appeal to review and overturn the decision of the Board of Examiners of Scx Offenders and
s not verified and does not show expenses, indebtedness, or liabilities. Law enforcement has informed the Government that a safe in the Defendant's Ncw York home very recently contained "more than 570.000 in cash ... 48 loose diamond stones, ranging in size from approximately 1 carat to 2.38 carats, as
ed States v. Chimurenga, 760 F.2d 400, 403 (2d Cir. 1985). "[E]ven a single incident of witness tampering .. . [may be] sufficient to revoke bail." LaFontaine, 210 F.3d at 134. To order detention based upon risk of flight, the Court must find by a preponderance of the evidence that "that no conditions cou
ers of Sex Offenders. ice. People v. Epstein. Indict. # 30129/2010, (N.Y. Sup. Ct.), SORA Hearing Transcript, dated Jan. 18, 2011. At the hearing, New York County Assistant District Attorney Jennifer Gaffney joined in Defense Counsel's appeal to review and overturn the decision of the Board of Examiners of Sex
s not verified and does not show expenses, indebtedness, or liabilities. Law enforcement has informed the Government that a safe in the Defendant's Ncw York home very recently contained "more than 570.000 in cash ... 48 loose diamond stones, ranging in size from approximately 1 carat to 2.38 carats, as
ed States v. Chimurenga, 760 F.2d 400, 403 (2d Cir. 1985). "[E]ven a single incident of witness tampering .. . [may be] sufficient to revoke bail." LaFontaine, 210 F.3d at 134. To order detention based upon risk of flight, the Court must find by a preponderance of the evidence that "that no conditions cou
ffender to New York law enforcement See July 10, 2019 NY Post Article. "The NYPD cop assigned to monitor Epstein has repeatedly complained to [the New York County District Attorney's] Sex Crimes Unit that Epstein wasn't in compli- ance, according to a source familiar with the matter." Id. Mr. Epstein's allege
d States v. Chimurenga, 760 F.2d 400, 403 (2d Cir. 1985). "[E]ven a single incident of witness tampering ... [may be] sufficient to revoke bail." LaFontaine, 210 F.3d at 134. [6,7] To order detention based upon risk of flight, the Court must find by a preponderance of the evidence that "that no condi
ffender to New York law enforcement See July 10, 2019 NY Post Article. "The NYPD cop assigned to monitor Epstein has repeatedly complained to [the New York County District Attorney's] Sex Crimes Unit that Epstein wasn't in compli- ance, according to a source familiar with the matter." Id. Mr. Epstein's allege
d States v. Chimurenga, 760 F.2d 400, 403 (2d Cir. 1985). "[E]ven a single incident of witness tampering ... [may be] sufficient to revoke bail." LaFontaine, 210 F.3d at 134. [6,7] To order detention based upon risk of flight, the Court must find by a preponderance of the evidence that "that no condi
Entities connected to both New York City and LaFontaine

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
New York
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Palm Beach
LOCATION
Julie K. Brown
PERSON
U.S. Virgin Islands
LOCATION
New York State
LOCATIONthe Southern District
LOCATION
Michael Jackson
PERSON
Vicky Ward
PERSONMaria Farmer
PERSON
Bradley Edwards
PERSON
George Mitchell
PERSONMartin Weinberg
PERSON
Alfredo Rodriguez
PERSONFBI
ORGANIZATION