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Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 3 of 16

in the U.S. Virgin Islands, his principal residence, Florida, and New York. Mr. Epstein has
scrupulously fulfilled his obligations in every jurisdiction in which he was required to register
throughout the 10-year hiatus between his release and present arrest. All of his travel has been
meticulously reported to the registration authorities so that they have been aware of his precise
location every single day for the past 10 years. Better still, the pending charges date back 14-17
years, from 2002 to 2005. Yet, tellingly, they allege no recurrence of the conduct underlying the
NPA and Florida state conviction at any time in the ensuing decade and a half (2005-2019).
Together, these unique factors are powerful indicia that Mr. Epstein is no longer a danger to
anyone and will faithfully obey all conditions of release if ordered.

In sum, Mr. Epstein has substantial grounds to challenge the allegations charged by the
government in its indictment, and he has every intention of doing so in a lawful, professional,
and principled manner. He intends to fight the current charges on their merits and, more, to
contest their legality given the inextricable intertwining of the current investigation and his NPA
which promised him immunity and a global settlement for offenses including those brought
under 18 U.S.C. § 1591. Any perception that Mr. Epstein poses any conceivable danger or flight
risk may be readily dispelled by a slate of highly restrictive conditions, which amply suffice to
secure his release:

1. Home detention in Mr. Epstein’s Manhattan residence, with permission to leave only for
medical appointments as approved by Pretrial Services, including (at the Court’s
discretion) the installation of surveillance cameras at the front and rear entrances to
ensure compliance.
2. Electronic monitoring with a Global Positioning System.²
3. An agreement not to seek or obtain any new passport during the pendency of this matter.³

² “A radio frequency (‘RF’) bracelet is the more conventional ‘ankle bracelet’ that has been used
over time. GPS monitoring is a more recent phenomenon that is distinct from RF monitoring.
While both units are placed on the ankle, the former tracks an offender’s movements in real time,
while the latter is contingent upon proximity to a base unit connected to a landline at an
offender’s home. Statistically, GPS monitoring is more effective than RF monitoring at
preventing recidivism.” United States v. Paulino, 335 F. Supp. 3d 600, 617 n.5 (S.D.N.Y. 2018)
(citations omitted).

³ Mr. Epstein has only one active passport permitting current travel – not three, as the
government fancies. That one active U.S. passport has now been surrendered. Mr. Epstein has no
foreign passports.

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