DOJ-OGR-00000808.jpg

755 KB

Extraction Summary

2
People
1
Organizations
7
Locations
4
Events
2
Relationships
6
Quotes

Document Information

Type: Legal document
File Size: 755 KB
Summary

This legal document details the arguments between the prosecution (Government) and the defense regarding a foreign (Austrian) passport found in the possession of the defendant, Mr. Epstein. The defense claims Epstein acquired it from a friend in the 1980s for protection during Middle East travel and never used it, while the government argues its existence, along with stamps from various countries and its issuance under an alias, indicates he is a serious flight risk. The document also notes that the defense submitted an asset summary showing Epstein possesses over $56 million in cash.

People (2)

Name Role Context
Mr. Epstein Defendant
The central figure of the document, referred to as "Defendant" and "Mr. Epstein". The document discusses his possessi...
Defense counsel Legal representative
Represents the Defendant (Mr. Epstein) and provides explanations for his possession of a foreign passport and submits...

Organizations (1)

Name Type Context
Government government agency
The prosecuting party in the legal case, arguing that the defendant's possession of a foreign passport makes him a fl...

Timeline (4 events)

1980s
Mr. Epstein acquired an Austrian passport.
1980s
A passport contained stamps indicating entry into France, Spain, the United Kingdom, and Saudi Arabia. The defense claims these stamps predate Epstein's receipt of the passport.
France, Spain, the United Kingdom, and Saudi Arabia
2019-06-30
An "Asset Summary" was created, detailing Mr. Epstein's cash holdings.
2019-07-18
The Defense submitted an explanation regarding the passport.

Locations (7)

Location Context
Mentioned as a country of which the Defendant is not a citizen or permanent resident, besides his primary citizenship.
Mentioned as the region for which the Austrian passport was allegedly acquired for protection during travel.
Mentioned as one of the countries for which the foreign passport contains entry stamps from the 1980s.
Mentioned as one of the countries for which the foreign passport contains entry stamps from the 1980s.
Mentioned as one of the countries for which the foreign passport contains entry stamps from the 1980s.
Mentioned as one of the countries for which the foreign passport contains entry stamps from the 1980s.
Implied by the mention of an "Austrian passport".

Relationships (2)

Mr. Epstein professional Defense counsel
Defense counsel represents Mr. Epstein (the Defendant) in a legal proceeding, submitting documents and arguments on his behalf.
Mr. Epstein personal Unnamed friend
The defense claims that Epstein "was given the passport at issue by a friend".

Key Quotes (6)

"Defendant is currently, or has been in the past, a citizen or legal permanent resident of a country other than the United States."
Source
— Government (from Dkt. 23) (A statement from a previous court document cited in this text.)
DOJ-OGR-00000808.jpg
Quote #1
"Mr. Epstein has no foreign passports."
Source
— Defense counsel (A contention made by the defense, cited from Dkt. 6.)
DOJ-OGR-00000808.jpg
Quote #2
"Epstein . . . acquired the passport in the 1980s, when hijackings were prevalent, in connection to Middle East travel. The passport was for personal protection in the event of travel to dangerous areas, only to be presented to potential kidnapers, hijackers or terrorists should violent episodes occur."
Source
— Defense counsel (The defense's explanation for why Mr. Epstein possessed the Austrian passport.)
DOJ-OGR-00000808.jpg
Quote #3
"The Government is attempting to obtain additional information about the Foreign Passport, including how it was obtained and whether the passport is genuine or fabricated."
Source
— Government (from Dkt. 23) (The government's position on the suspicious nature of the foreign passport.)
DOJ-OGR-00000808.jpg
Quote #4
"the passport contains numerous ingress and egress stamps, including stamps that reflect use of the passport to enter France, Spain, the United Kingdom, and Saudi Arabia in the 1980s."
Source
— Government (The government's argument regarding the contents of the passport, suggesting it was used for travel.)
DOJ-OGR-00000808.jpg
Quote #5
"Epstein was given the passport at issue by a friend . . He never used the document to travel internationally and never presented it to any immigration or customs authority. The passport stamps, predating his receipt of the document, do not reflect Mr. Epstein’s entries or exits."
Source
— Defense counsel (The defense's explanation, submitted on July 18, 2019, for how Epstein obtained the passport and why the stamps are irrelevant.)
DOJ-OGR-00000808.jpg
Quote #6

Full Extracted Text

Complete text extracted from the document (2,147 characters)

Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 25 of 33
“Defendant is currently, or has been in the past, a citizen or legal permanent resident of a country other than the United States.” Dkt. 23 at 2.
Defense counsel contends that Defendant has one active passport that was surrendered and that “Mr. Epstein has no foreign passports.” Dkt. 6 at 3 n. 3. With regard to the Austrian passport, the Defense explains that “Epstein . . . acquired the passport in the 1980s, when hijackings were prevalent, in connection to Middle East travel. The passport was for personal protection in the event of travel to dangerous areas, only to be presented to potential kidnapers, hijackers or terrorists should violent episodes occur.” Dkt. 24 at 8. Details about how the passport was procured by Mr. Epstein in the name of another individual were not provided and are not known to the Government. See Dkt. 23 at 2 (“The Government is attempting to obtain additional information about the Foreign Passport, including how it was obtained and whether the passport is genuine or fabricated. But the defendant’s possession of what purports to be a foreign passport issued under an alias gives rise to the inference the defendant knows how to obtain false travel documents and/or assume other, foreign identities. This adds to the serious risk of flight posed by the defendant.”). The Government also argues that “the passport contains numerous ingress and egress stamps, including stamps that reflect use of the passport to enter France, Spain, the United Kingdom, and Saudi Arabia in the 1980s.” Dkt. 30. By submission dated July 18, 2019, the Defense explains: “Epstein was given the passport at issue by a friend . . He never used the document to travel internationally and never presented it to any immigration or customs authority. The passport stamps, predating his receipt of the document, do not reflect Mr. Epstein’s entries or exits.” Dkt. 31.
Defense counsel has submitted a one page document called “Asset Summary - June 30, 2019.” It indicates that Epstein has cash in the amount of $56,547,773; fixed income valued at
25
DOJ-OGR-00000808

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