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

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

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

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

llo did not mention in its opinion"). 16 EFTA00089170 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

nship), including to the United States, and has never derogated from that principle outside the European Union. See Ex. C; see also United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL "taken a number of surprising turns," including the "suppression of video evidence, the indeterminate stay of procee

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

] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) ("it is contrary to underlying principles of detention and release on bail th

] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) ("it is contrary to underlying principles of detention and release on bail th

] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) ("it is contrary to underlying principles of detention and release on bail th

] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) ("it is contrary to underlying principles of detention and release on bail th

] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) ("it is contrary to underlying principles of detention and release on bail th

] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) ("it is contrary to underlying principles of detention and release on bail th

] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) ("it is contrary to underlying principles of detention and release on bail th

] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) ("it is contrary to underlying principles of detention and release on bail th

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

] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) ("it is contrary to underlying principles of detention and release on bail th

] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) ("it is contrary to underlying principles of detention and release on bail th

] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) ("it is contrary to underlying principles of detention and release on bail th

ow[ing] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Accord, e.g., United States v. Cilins, No. 13 Cr. 315 EFTA00030253 --- PAGE BREAK --- Honorable Richard M. Berman United States District Judge July 12, 2019 Page 8 (WHP), 2013 WL

] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) ("it is contrary to underlying principles of detention and release on bail th

] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013) ("it is contrary to underlying principles of detention and release on bail th