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egistration status. Defense coun- sel also stated that Epstein traveled exten- sively over the last eight months and "in- variably returned to the to the United States. That inescapable reality emphati- cally proves he won't flee and entitles him to release - on any and all conditions the Court deems appropriate."
If the defendant comes forward with evidence that he will not endanger the community or flee the juris- diction, the presumption "is not erased." See United States v. Dominguez, 783 F2d 702, 707 (7th Cir. 1986). "Rather, the pre- sumption remains in the case as an eviden- tiary finding militating against releas
in Islands With respect to Mr. Epstein's sex of- fender status in New Mexico, Defense Counsel has submitted a letter, dated Au- gust 19, 2010, from Regina Chacon, Assis- tant Bureau Chief, Law Enforcement Record Bureau of the New Mexico De- partment of Public Safety, which states that Mr. Epstein "is not req
egistration status. Defense coun- sel also stated that Epstein traveled exten- sively over the last eight months and "in- variably returned to the to the United States. That inescapable reality emphati- cally proves he won't flee and entitles him to release - on any and all conditions the Court deems appropriate."
If the defendant comes forward with evidence that he will not endanger the community or flee the juris- diction, the presumption "is not erased." See United States v. Dominguez, 783 F2d 702, 707 (7th Cir. 1986). "Rather, the pre- sumption remains in the case as an eviden- tiary finding militating against releas
in Islands With respect to Mr. Epstein's sex of- fender status in New Mexico, Defense Counsel has submitted a letter, dated Au- gust 19, 2010, from Regina Chacon, Assis- tant Bureau Chief, Law Enforcement Record Bureau of the New Mexico De- partment of Public Safety, which states that Mr. Epstein "is not req
leased to provide any additional information the Court may need. Yours truly, /s Reid Weingarten Steptoe & Johnson, LLP (NYC) 1114 Avenue of the Americas New York, NY 10036 1 EFTA00105512 Case 1:19-cr-00490-RMB Document 25 Filed 07/17/19 Page 2 of 2 Martin G. Weinberg (pro hac vice) Martin G. We
e I of the Adam Walsh Child Protection and Safety Act of 2006. Please contact Teresa Hernandez ats if you have any further questions. Sincerely, Regina Chacon, Accistant Bureau Chief Law Enforcement Records Bureau NM Department of Public Safety CC: Santa Fe County Sheriff File: TH: RC Acreardrrnatrec
pecifically, the nearest cognate crime under New York law For (ho avoidenee-of doubt. the U.S. Virgin liuIond in one of the prineipel-4erritorioa of the-United States calong-witli-Pliene-Rice—Goam—osawkerisan-Samea—anchthe-Isieftheco-K4ariarka4slands4—and-acooRtiogly-is-acovered 5—The-attashed-registrationawm-(Ex
nder that Sstate's sexual offender reporting statute, despite his Florida conviction and the conduct alleged in connection therewith. See Letter of Regina Chacon, New Mexico Department of Public Safety to Jeffery E. Epstein, August 19, 2010 (Exhibit E); see also NMSA 1978, § 29-11A-3(E). Notwithstanding the
Entities connected to both United States and Regina Chacon

Jeffrey Epstein
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George W. Bush
PERSONthe Southern District
LOCATION
Bradley Edwards
PERSON
New York
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Scarlett Johansson
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Julie K. Brown
PERSONMaria Farmer
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New York City
LOCATIONMartin Weinberg
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Jay Lefkowitz
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Southern District of New York
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Michael Jackson
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Stephen Hawking
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U.S. Virgin Islands
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George Mitchell
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Alfredo Rodriguez
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Supreme Court
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Condoleezza Rice
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