Case 19-3324, Document 2, 07/23/2019, 2614674, Page28 of 33
Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 28 of 33
incorporated here by reference. See Minnici, 128 F. App’x at 829–30 (“the alleged activities
[we]re of an addictive sexual nature that cannot be suppressed simply by a restrictive set of bail
conditions”); see also Millan, 4 F.3d at 1049 (“[T]he protection of the community can be assured
only by continued detention.”).
The Court has carefully considered the issue of Defendant’s ability and motivation for
fleeing U.S. jurisdiction. The Court finds that the Government has proven by a preponderance of
the evidence that, among other things, the Defendant’s limited family ties to the United States,
his residence in Paris, his extensive overseas travel, his significant wealth and his substantial
resources (including private planes), and the potential 45 year term of imprisonment that may be
imposed should there be a conviction in this case, provide incentive, motive and wherewithal to
flee. Indeed, these factors render him a “classic” flight risk. See, e.g., United States v. Abdullahu,
488 F.Supp.2d 433, 445 (D.N.J. 2007) (“After reviewing the totality of the evidence, the Court
has reached the inescapable conclusion that the government has proved by a preponderance of
the evidence that no condition or combination of conditions exist that will reasonably assure the
defendant’s appearance at trial. The defendant faces serious criminal charges . . . The defendant
faces a potential ten year prison sentence and involuntary deportation. The defendant does not
have permanent and longstanding ties to this area, he has the means and incentive to flee and he
has family ties and a place to live in an overseas country that will not extradite him to the United
States.”).
H. Defendant’s Proposed Bail Package
Having determined that Mr. Epstein is a flight risk (and also a danger to the community),
the Court next examines the Defendant’s proposed bail package. See 18 U.S.C. § 3142(b)-(f)(2).
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