DOJ-OGR-00000788.jpg

749 KB

Extraction Summary

2
People
6
Organizations
4
Locations
5
Events
1
Relationships
3
Quotes

Document Information

Type: Legal document
File Size: 749 KB
Summary

This legal document, part of a court filing, details the prosecution's (Government's) argument against granting bail to the defendant, Mr. Epstein. The Government cites Epstein's vast wealth ($559M), a history of witness obstruction, and recent suspicious wire transfers totaling $350,000 to a potential co-conspirator as evidence that his proposed release conditions are 'woefully inadequate' and that he poses a flight risk.

People (2)

Name Role Context
Mr. Epstein Defendant
The central figure in the legal proceedings, whose finances, proposed bail conditions, and alleged suspicious activit...
unnamed individual potential co-conspirator
Recipient of a $100,000 wire transfer from a trust account controlled by Mr. Epstein.

Organizations (6)

Name Type Context
Pretrial Services government agency
Mentioned as an entity to which violations of release conditions should be reported.
the Court government agency
The judicial body overseeing the case, which sets conditions for release and receives filings from both the Defense a...
The Defense legal team
Legal representation for Mr. Epstein, proposing bail conditions and filing documents on his behalf.
The Government legal team
The prosecution, arguing against the proposed bail package and providing evidence of Mr. Epstein's alleged obstructio...
Institution-1 financial institution
The source of records showing wire transfers made by the defendant.
Miami Herald media company
A newspaper whose series of articles is mentioned as a timeline marker for when suspicious wire transfers began.

Timeline (5 events)

2018-11-30
The defendant, Mr. Epstein, wired $100,000 from a trust account to a potential co-conspirator.
2018-12-03
The defendant, Mr. Epstein, wired $250,000 from the same trust account.
2019-07-12
The Defense filed a one-page document detailing five groups of assets owned by Mr. Epstein, totaling $559,120,954.
The Court
2019-07-12
The Government responded to the Defense motion, arguing Mr. Epstein has a history of obstruction and manipulation of witnesses.
The Court
2019-07-16
The Court received a letter from the Government detailing suspicious payments and other findings.
The Court
The Government The Court

Locations (4)

Location Context
Proposed location for Mr. Epstein to live under certain bail conditions.
Location where media reports about Mr. Epstein's conduct reemerged.
Origin of a police report mentioned in a letter from the Government.
Location where cash, diamonds, and an expired Austrian passport were found.

Relationships (1)

Mr. Epstein co-conspirator unnamed individual
The document states that Mr. Epstein wired $100,000 to an individual who was named as a 'potential co-conspirator'.

Key Quotes (3)

"has a history of obstruction and manipulation of witnesses, including . . . as recently as within the past year, when media reports about his conduct [in Florida] reemerged."
Source
— The Government (Part of the Government's argument in response to the Defense's motion for bail.)
DOJ-OGR-00000788.jpg
Quote #1
"woefully inadequate."
Source
— The Government (The Government's contention regarding the defendant's proposed conditions of release.)
DOJ-OGR-00000788.jpg
Quote #2
"[R]ecords from Institution-1 show that on or about November 30, 2018, or two days after the series in the Miami Herald began, the defendant wired $100,000 from a trust account he controlled to . . . , an individual named as a potential co-conspirator."
Source
— The Government (An example provided by the Government of allegedly suspicious payments made by the Defendant.)
DOJ-OGR-00000788.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (2,098 characters)

Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 5 of 33
live in Mr. Epstein’s residence and report any violation to Pretrial Services and/or the Court”;
(14) “Any other condition the Court deems necessary to reasonably assure Mr. Epstein’s
appearance.” Id. at 3-4. The Defense also proposes as a “fallback” “round-the-clock, privately
funded security guards [which] will virtually guarantee - not just reasonably assure - Mr.
Epstein’s presence in the circumstances of this case.” Id. at 10. The bail package originally was
not accompanied by a financial statement reflecting Mr. Epstein’s finances. However, on July
12, 2019, the Defense filed a one-page document which includes five groups of assets owned by
Mr. Epstein totaling $559,120,954. Dkt. 14 at 18.
The Government responded to the Defense motion on July 12, 2019, arguing, among
other things, that Mr. Epstein “has a history of obstruction and manipulation of witnesses,
including . . . as recently as within the past year, when media reports about his conduct [in
Florida] reemerged.” Dkt. 11 at 1. The Government filing was made against a “backdrop of
significant—and rapidly-expanding—evidence, serious charges, and the prospect of a lengthy
prison sentence.” Id. It contends that the defendant’s proposed conditions of release are
“woefully inadequate.” Id.
The Court also received a letter from the Government, dated July 16, 2019, providing,
among other things, details about allegedly suspicious payments made by the Defendant in 2018;
a Palm Beach, Florida police report; Mr. Epstein’s expired Austrian passport in another name but
with Mr. Epstein’s photo; and a pile of cash and diamonds found in Mr. Epstein’s safe. For
example, the Government says: “[R]ecords from Institution-1 show that on or about November
30, 2018, or two days after the series in the Miami Herald began, the defendant wired $100,000
from a trust account he controlled to . . . , an individual named as a potential co-conspirator.”
Dkt. 23 at 1. And, “on or about December 3, 2018, the defendant wired $250,000 from the same
5
DOJ-OGR-00000788

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