Epstein Secrets

t "may reasonably assure the appear- ance of [the defendant] at trial will not [necessarily] assure the safety of the com- munity." United States v. Rodriguez, 950 F.2d 85, 89 (2d Cir. 1991). [8] The Bail Reform Act sets forth the following four• factors to be considered in the release/remand analysis:

of flight ... this Court does not believe that that condition, even coupled with the additional conditions proposed, would be sufficient" U.S. v.Cilins, 2013 WL 3802012, at *3. • The Danger Posed By The Defen- dant's Release As demonstrated infra, Mr. Epstein's dangerousness is considerable and

g that Defendant poses "a serious flight risk and that no conditions can be set to rea- sonably assure his appearance for trial." United States v. Cilins, 2013 WL 3802012, at *2 (S.D.N.Y. July 19, 2013). • Weight Of The Evidence The Government's evidence against Mr. Epstein appears strong. The evi

t "may reasonably assure the appear- ance of [the defendant] at trial will not [necessarily] assure the safety of the com- munity." United States v. Rodriguez, 950 F.2d 85, 89 (2d Cir. 1991). [8] The Bail Reform Act sets forth the following four• factors to be considered in the release/remand analysis:

of flight ... this Court does not believe that that condition, even coupled with the additional conditions proposed, would be sufficient" U.S. v.Cilins, 2013 WL 3802012, at *3. • The Danger Posed By The Defen- dant's Release As demonstrated infra, Mr. Epstein's dangerousness is considerable and

g that Defendant poses "a serious flight risk and that no conditions can be set to rea- sonably assure his appearance for trial." United States v. Cilins, 2013 WL 3802012, at *2 (S.D.N.Y. July 19, 2013). • Weight Of The Evidence The Government's evidence against Mr. Epstein appears strong. The evi

tates v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quoting United States v. Mercedes, 254 F.3d 433, 436 (2d Cir. 2001)); see also United States v. Rodriguez, 950 F.2d 85, 88 (2d Cir. 1991) ("IA] defendant must introduce some evidence contrary to the presumed fact in order to rebut the presumption."). Non

nited States v. Boustani, 932 F.3d 79 (2d Or. 2019) 6, 25, 26 United States v. Chen, 820 F. Supp. 1205, 1209 (N.D. Cal. 1992) 15 United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012 (S.D.N.Y. July 19, 2013) 16, 19 United States v. Cirillo, No. 99-1514, 1999 WL 1456536 (3d Cir. July 13, 199

o United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at '2 (S.D.N.Y. July 19, 2013) ("Because France refuses to extradite its citizens, Cilins can avoid prosecution on this Indictment if he can reach French soil."). In other words, even assuming the Government could locate the defendant, i

L 1494027, at *3 (S.D.N.Y. Apr. 4, 2019) (citing Rodriguez v. Vill. Green Realty, Inc., 788 F.3d 31, 47 (2d

lar). "Evidence should be excluded on a motion in limine only when the evidence is clearly inadmissible on all potential grounds." United States v. Cilins, No. 13 CR. 315 (WHP), 2014 WL 173414, at *2 (S.D.N.Y. Jan. 15, 2014) (citation and internal quotation marks omitted). B. Discussion The defense's