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811 KB
Extraction Summary
4
People
3
Organizations
1
Locations
3
Events
1
Relationships
6
Quotes
Document Information
Type:
Legal document
File Size:
811 KB
Summary
This document is page 2 of a legal filing dated July 16, 2019, addressed to Judge Richard M. Berman. The filing argues against granting release to a defendant named Epstein, asserting that his immense wealth and financial sophistication create an irrebuttable presumption that he is a flight risk. The document quotes previous court transcripts and letters to argue that Epstein could easily transfer assets abroad, become a fugitive, and continue to earn millions, making any conditions of release, including a bond, meaningless.
People (4)
| Name | Role | Context |
|---|---|---|
| Richard M. Berman | Honorable (Judge) |
Addressee of the document.
|
| Epstein | Defendant (implied) |
Mentioned in the context of his wealth and means, arguing he is a flight risk and cannot be eligible for release.
|
| Fierro |
Named party in the case citation Fierro v. Taylor.
|
|
| Taylor |
Named party in the case citation Fierro v. Taylor.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Court | government agency |
Referred to as the body that should reject the government's effort.
|
| government | government agency |
Party in the legal case arguing against the defendant's release.
|
| SDNY | government agency |
Southern District of New York, the court cited in Fierro v. Taylor.
|
Timeline (3 events)
2019-07-15
A court transcript (Tr.) was created, from which a quote is taken regarding the defense's ability to rebut a presumption.
Court
government
defense
Locations (1)
| Location | Context |
|---|---|
|
Mentioned as the current location of the defendant's assets and a place he could earn money from outside of.
|
Relationships (1)
The document details the government's legal arguments against Epstein's eligibility for release from custody.
Key Quotes (6)
"even if the defense were able at some point to rebut the presumption by providing some more information, there simply is no way that they can meet the standard here"Source
— government (implied from context)
(Quoted from a court transcript dated 7/15/19, arguing against the defendant's release.)
DOJ-OGR-00000446.jpg
Quote #1
"even assuming the defendant’s assets are presently in the United States, nothing … would prevent the defendant from transferring liquid assets out of the country quickly and in anticipation of flight or relocation."Source
— government (implied from context)
(Quoted from a letter dated 7/12/19, arguing the defendant is a flight risk.)
DOJ-OGR-00000446.jpg
Quote #2
"The defendant is an incredibly sophisticated financial actor with decades of experience in the industry and significant ties to financial institutions and actors around the world. He could easily transfer funds and holdings on a moment’s [notice] to places where the [g]overnment would never find them so as to ensure he could live comfortably while a fugitive."Source
— government (implied from context)
(Quoted from a letter dated 7/12/19, describing the defendant's financial sophistication as a reason he is a flight risk.)
DOJ-OGR-00000446.jpg
Quote #3
"even were the defendant to sacrifice literally all of his current assets, there is every indication that he would immediately be able to resume making … tens of millions of dollars per year outside of the United States…."Source
— government (implied from context)
(Quoted from a letter dated 7/12/19, arguing that even forfeiting assets would not prevent the defendant from earning vast sums while a fugitive.)
DOJ-OGR-00000446.jpg
Quote #4
"[T]here would be little to stop the defendant from fleeing, transferring his unknown assets abroad, and then continuing to … earn his vast wealth from a computer terminal beyond the reach of extradition."Source
— government (implied from context)
(Quoted from a letter dated 7/12/19, detailing how the defendant could flee and remain wealthy.)
DOJ-OGR-00000446.jpg
Quote #5
"the notion that any individual co-signer could meaningfully secure a bond for this defendant strains credulity"Source
— government (implied from context)
(Quoted from a letter dated 7/12/19, arguing that a bond would be ineffective.)
DOJ-OGR-00000446.jpg
Quote #6
Full Extracted Text
Complete text extracted from the document (2,102 characters)
Case 1:19-cr-00490-RMB Document 24 Filed 07/16/19 Page 2 of 9
Hon. Richard M. Berman
July 16, 2019
Page 2
July 16, 2019
Page 2
wealth creates an irrebuttable presumption whereby no condition(s) can
reasonably assure personal appearance or protect the public. The Court
should reject the government’s misguided effort to effectively create a per
se rule.² Indeed, for the government, there’s literally nothing a person of
Epstein’s means could say, do or pledge to rebut the operative
presumption and make himself eligible for release.
____________________
massages for money. See Fierro v. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3
(SDNY July 2, 2012) (holding that purchasers of sex from minors fall outside § 1591’s
ambit).
(SDNY July 2, 2012) (holding that purchasers of sex from minors fall outside § 1591’s
ambit).
² E.g., 7/15/19 Tr. 11 (“even if the defense were able at some point to rebut the
presumption by providing some more information, there simply is no way that they
can meet the standard here”); 7/12/19 Ltr. 5 (“even assuming the defendant’s assets
are presently in the United States, nothing … would prevent the defendant from
transferring liquid assets out of the country quickly and in anticipation of flight or
relocation. The defendant is an incredibly sophisticated financial actor with decades
of experience in the industry and significant ties to financial institutions and actors
around the world. He could easily transfer funds and holdings on a moment’s [notice]
to places where the [g]overnment would never find them so as to ensure he could live
comfortably while a fugitive.”); id. (“even were the defendant to sacrifice literally all
of his current assets, there is every indication that he would immediately be able to
resume making … tens of millions of dollars per year outside of the United States….
[T]here would be little to stop the defendant from fleeing, transferring his unknown
assets abroad, and then continuing to … earn his vast wealth from a computer
terminal beyond the reach of extradition.”) (footnote omitted); id. 7 (“the notion that
any individual co-signer could meaningfully secure a bond for this defendant strains
credulity”).
presumption by providing some more information, there simply is no way that they
can meet the standard here”); 7/12/19 Ltr. 5 (“even assuming the defendant’s assets
are presently in the United States, nothing … would prevent the defendant from
transferring liquid assets out of the country quickly and in anticipation of flight or
relocation. The defendant is an incredibly sophisticated financial actor with decades
of experience in the industry and significant ties to financial institutions and actors
around the world. He could easily transfer funds and holdings on a moment’s [notice]
to places where the [g]overnment would never find them so as to ensure he could live
comfortably while a fugitive.”); id. (“even were the defendant to sacrifice literally all
of his current assets, there is every indication that he would immediately be able to
resume making … tens of millions of dollars per year outside of the United States….
[T]here would be little to stop the defendant from fleeing, transferring his unknown
assets abroad, and then continuing to … earn his vast wealth from a computer
terminal beyond the reach of extradition.”) (footnote omitted); id. 7 (“the notion that
any individual co-signer could meaningfully secure a bond for this defendant strains
credulity”).
DOJ-OGR-00000446
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