Epstein Secrets

with which he is charged provides the motive for him do so and is another significant factor in assessing the risk of flight. See United States v. Jackson, 823 F.2d 4, 7 (2d Cir. 1987). So too is the strength of the evidence, detailed above and in the Government's Detention Memo. Indeed, that evidence,

jurisdiction of his choosing (Le., the one to which he chose to flee). See, e.g., United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at *4 (W.D.N.Y. Dec. 23, 2016); United States v. Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at *3 (D. Or. Aug. 3, 2015); United States v. Young, Nos. 12 Cr. 502, 12

f 10 Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 2 BACKGROUND A. Overview On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed indictment (the "Indictment") charging the defendant with one count of sex trafficking of minors, in violation of 18 U.S.C. § 159

ation, which the non-prosecution agreement identifies as including investigations into the defendant's abuse of minor girls in the Palm Beach area. The Southern District of New York was not a signatory to that agreement, and the defendant was never charged federally.2 In June 2008, the defendant pled guilty in state court to one

safety of any other person and the community"). A finding of risk of flight must be supported by a preponderance of the evidence. United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United States v. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by clear

with which he is charged provides the motive for him do so and is another significant factor in assessing the risk of flight. See United States v. Jackson, 823 F.2d 4, 7 (2d Cir. 1987). So too is the strength of the evidence, detailed above and in the Government's Detention Memo. Indeed, that evidence,

jurisdiction of his choosing (Le., the one to which he chose to flee). See, e.g., United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at *4 (W.D.N.Y. Dec. 23, 2016); United States v. Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at *3 (D. Or. Aug. 3, 2015); United States v. Young, Nos. 12 Cr. 502, 12

--- Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 2 BACKGROUND A. Overview On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed indictment (the "Indictment") charging the defendant with one count of sex trafficking of minors, in violation of 18 U.S.C. § 159

ny other person and the community"). A finding of risk of flight must be supported by a preponderance of the evidence. See, e.g., United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United States v. Chirnurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by clea

ts with which he is charged, and the possibility of a severe sentence is a significant factor in assessing the risk of flight. See United States v. Jackson, 823 F.2d 4, 7 (2d Cir. 1987). And the evidence of his guilt, already robust less than a week ago when the Indictment was unsealed, is growing stro

such purported waivers are unenforceable and effectively meaningless. See, e.g., United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at *4 (W.D.N.Y. Dec. 23, 2016); United States v. Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at *3 (D. Or. Aug. 3, 2015); United States v. Young, Nos. 12 Cr. 502, 12 C

--- Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 2 BACKGROUND A. Overview On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed indictment (the "Indictment") charging the defendant with one count of sex trafficking of minors, in violation of 18 U.S.C. § 159

ny other person and the community"). A finding of risk of flight must be supported by a preponderance of the evidence. See, e.g., United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United States v. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by clear

--- Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 2 BACKGROUND A. Overview On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed indictment (the "Indictment") charging the defendant with one count of sex trafficking of minors, in violation of 18 U.S.C. § 159

ny other person and the community"). A finding of risk of flight must be supported by a preponderance of the evidence. See, e.g., United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United States v. Chirnurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by clea

TA00018506 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 3 of 10 BACKGROUND On June 29, 2020, a federal grand jury in the Southern District of New York returned a sealed indictment (the "Indictment") charging the defendant with one count of conspiracy to entice minors to travel to engage in illegal

ht must be supported by a preponderance of the evidence. See, e.g., United States v. Patriarca, 948 F.2d 789, 793 (1st Cir. 1991); United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United States v. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by clear