pstein will appear as required without resort to this measure. And we understand and appreciate Your Honor's opposition to it. See United States v. Zarrah, No. 15-CR-867, 2016 WL 3681423 (S.D.N.Y. June 16, 2016). Still, Mr. Epstein stands ready and willing to pay for 24-hour armed guards should the Cou

unding the practice, we respectfully propose it here as a fallback, asking the Court to revisit its propriety despite the reservations expressed in Zarrah. Those reservations, though admirably motivated and sincerely held, raise substantial equal protection concerns. They impair the statutory right to

pstein will appear as required without resort to this measure. And we understand and appreciate Your Honor's opposition to it. See United States v. Zarrah, No. 15-CR-867, 2016 WL 3681423 (S.D.N.Y. June 16, 2016). Still, Mr. Epstein stands ready and willing to pay for 24-hour armed guards should the Cou

unding the practice, we respectfully propose it here as a fallback, asking the Court to revisit its propriety despite the reservations expressed in Zarrah. Those reservations, though admirably motivated and sincerely held, raise substantial equal protection concerns. They impair the statutory right to