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749 KB

Extraction Summary

3
People
6
Organizations
2
Locations
2
Events
4
Relationships
5
Quotes

Document Information

Type: Legal document
File Size: 749 KB
Summary

This legal document, filed on July 18, 2019, critiques Mr. Epstein's proposed bail package, arguing that his home confinement plan involves excessive judicial oversight and raises practical concerns about private security. It also dismisses the defense's offer of an anticipatory extradition waiver as an 'empty gesture,' citing the Department of Justice's view that such waivers are not binding and the risk of the defendant fleeing to a non-extradition jurisdiction.

People (3)

Name Role Context
Mr. Epstein Defendant
Subject of the proposed home confinement and bail package, referred to as 'defendant'.
Defendant
Refers to Mr. Epstein, subject of the legal proceedings.
Trustee(s) Supervisor
Designated to live with and supervise Mr. Epstein as part of the bail package.

Organizations (6)

Name Type Context
Court government agency
The judicial body involved in the case, whose function and jurisdiction are discussed.
U.S. Bureau of Prisons government agency
Mentioned as providing trained, experienced, and qualified professionals for oversight.
U.S. Marshals Service government agency
Mentioned as providing trained, experienced, and qualified professionals for oversight.
Defense legal entity
The legal team representing Mr. Epstein, proposing the bail package and extradition waiver.
Government government agency
The prosecuting body, providing an opinion on extradition waivers.
Department of Justice's Office of International Affairs government agency
Cited by the Government as being unaware of any country considering anticipatory extradition waivers binding.

Timeline (2 events)

Mr. Epstein's proposed home confinement as part of a bail package.
Discussion of a proposed advance consent to extradition and waiver of extradition rights by the Defense.

Locations (2)

Location Context
Southern District of New York, location of the court cited in legal precedents.
The country whose jurisdiction and extradition treaties are discussed.

Relationships (4)

Mr. Epstein professional Defense
The Defense proposes a bail package and states Mr. Epstein's willingness to put up collateral.
Mr. Epstein legal Court
The Court is evaluating Mr. Epstein's bail package and jurisdiction.
Mr. Epstein supervisory Trustee(s)
Trustee(s) are designated to live with and supervise Mr. Epstein.
Government legal Court
The Government provides statements and arguments to the Court regarding the case.

Key Quotes (5)

"The [bail package] . . . proposed by the defense is not reasonable because, in too many respects, it substitutes judicial oversight and management for (more appropriate) reliance upon trained, experienced, and qualified professionals from the U.S. Bureau of Prisons and the U.S. Marshals Service."
Source
— Court (via United States v. Zarrab citation) (Critique of the defense's bail package regarding home confinement.)
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Quote #1
"The questions about the legal authorization for the private security firm to use force against defendant should he violate the terms of his release, and the questions over whether the guards can or should be armed, underscore the legal and practical uncertainties - indeed, the imperfections - of the private jail-like concept envisioned by defendant, as compared to the more secure option of an actual jail."
Source
— Court (via United States v. Valerio citation) (Critique of the private security firm aspect of the bail package for Mr. Epstein.)
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Quote #2
"The Department of Justice’s Office of International Affairs is unaware of any country anywhere in the world that would consider an anticipatory extradition waiver binding. And, of course, the defendant could choose to flee to a jurisdiction with which the United States does not have an extradition treaty."
Source
— Government (Statement regarding the ineffectiveness of an anticipatory extradition waiver.)
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Quote #3
"any amount"
Source
— Defense (attributed to Mr. Epstein) (Mr. Epstein's willingness to put up collateral.)
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Quote #4
"any bond"
Source
— Defense (attributed to Mr. Epstein) (Mr. Epstein's willingness to sign a bond.)
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Quote #5

Full Extracted Text

Complete text extracted from the document (2,177 characters)

Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 30 of 33
(2) The defense bail package proposes excessive involvement of the Court in routine aspects of Mr. Epstein’s proposed home confinement. This is not the Court’s function. See United States v. Zarrab, 2016 WL 3681423, at *10 (S.D.N.Y. June 16, 2016) (“The [bail package] . . . proposed by the defense is not reasonable because, in too many respects, it substitutes judicial oversight and management for (more appropriate) reliance upon trained, experienced, and qualified professionals from the U.S. Bureau of Prisons and the U.S. Marshals Service.”). The Defense package components would embroil the Court in issues, among others, relating to the level of force that may be used to secure the Defendant, who may enter the residence, daily reporting by Mr. Epstein, and reporting by so-called Trustee(s) designated to live with and supervise Mr. Epstein. See United States v. Valerio, 9 F. Supp. 3d 283, 295 (E.D.N.Y. 2014) (“The questions about the legal authorization for the private security firm to use force against defendant should he violate the terms of his release, and the questions over whether the guards can or should be armed, underscore the legal and practical uncertainties - indeed, the imperfections - of the private jail-like concept envisioned by defendant, as compared to the more secure option of an actual jail.”).
(3) The Defense proposal to give advance consent to extradition and waiver of extradition rights is, in the Court’s view, an empty gesture. And, it comes into pay only after Mr. Epstein has fled the Court’s jurisdiction. According to the Government, “The Department of Justice’s Office of International Affairs is unaware of any country anywhere in the world that would consider an anticipatory extradition waiver binding. And, of course, the defendant could choose to flee to a jurisdiction with which the United States does not have an extradition treaty.” Dkt. 11 at 7.
(4) Although the Defense has stated that Mr. Epstein would be agreeable to putting up “any amount” of collateral or signing “any bond” the Court would require, there has, to date,
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