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636 KB

Extraction Summary

3
People
3
Organizations
2
Locations
3
Events
2
Relationships
5
Quotes

Document Information

Type: Court transcript (southern district of new york)
File Size: 636 KB
Summary

This document is page 18 of a court transcript from July 16, 2019, involving the case United States v. Jeffrey Epstein. The defense attorney is arguing against the government's motion for detention, claiming that double jeopardy applies, that the issue is not trafficking, and that Epstein is not a flight risk given his compliance with law enforcement surveillance in Florida over the previous decade. The attorney suggests traditional bail remedies such as a large cash bond, passport relinquishment, and electronic monitoring.

People (3)

Name Role Context
Defense Attorney (Speaker) Legal Counsel
Arguing for bail/release, claiming flight risk is overstated and challenging the government's case.
Jeffrey Epstein Defendant
referred to as 'he' and 'the defendant'; subject of the bail hearing.
Judge Marra Judge
Mentioned regarding previous litigation in the Southern District of Florida.

Organizations (3)

Name Type Context
Southern District Reporters, P.C.
Court reporting firm listed in footer.
Law Enforcement
Mentioned as having constant knowledge of the defendant's location.
The Government
Prosecuting body (DOJ/US Attorney) referred to regarding their presentation and 'seeking two bites at the apple'.

Timeline (3 events)

2013
Start of representations made in court regarding challenges to the NPA (Non-Prosecution Agreement).
Court
Jeffrey Epstein Legal Counsel
2019-07-16
Court hearing regarding bail/detention (Case 1:19-cr-00490-RMB).
Southern District of New York
Defense Attorney Judge Government Prosecutors
Prior to 2019
Incarceration in the State of Florida.
Florida

Locations (2)

Location Context
Location of previous incarceration and conduct.
Location of Judge Marra's litigation.

Relationships (2)

Jeffrey Epstein Adversarial/Legal The Government
Defense arguing against government's presentation on flight risk and double jeopardy.
Jeffrey Epstein Legal/Judicial Judge Marra
Reference to litigation in Judge Marra's court in Florida.

Key Quotes (5)

"we believe we have extremely powerful motions relating to the government seeking two bites at the apple"
Source
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Quote #1
"We also think fundamentally what's at issue here is not trafficking."
Source
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Quote #2
"Law enforcement knows, if they choose to look, exactly where he is at any time."
Source
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Quote #3
"the defendant never sought to flee, never anticipated a time when he would flee"
Source
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Quote #4
"So the risk of flight, I think, is dramatically overstated in the government's presentation."
Source
DOJ-OGR-00000423.jpg
Quote #5

Full Extracted Text

Complete text extracted from the document (1,641 characters)

Case 1:19-cr-00490-RMB Document 20 Filed 07/16/19 Page 18 of 24 18
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1 traditional issues that we look at, the issues involved, let's
2 start with that, we believe we have extremely powerful motions
3 relating to the government seeking two bites at the apple and
4 for due process reasons, double jeopardy reasons, we don't
5 think that will stand. We also think fundamentally what's at
6 issue here is not trafficking. That's not why the statute was
7 passed.
8 The risk to others, what we have here is at least ten
9 years post incarceration in the State of Florida of conduct
10 that has never been challenged by anyone until now. The
11 registration requirements are onerous. He is under constant
12 surveillance. Law enforcement knows, if they choose to look,
13 exactly where he is at any time.
14 The risk of flight, what is true is from the moment of
15 Judge Marra's litigation in the Southern District of Florida,
16 the defendant knew that there would be challenges to the NPA.
17 From 2013 on, there were representations made in court that
18 that challenge was ongoing, and the defendant never sought to
19 flee, never anticipated a time when he would flee, continued to
20 live his law-abiding life. So the risk of flight, I think, is
21 dramatically overstated in the government's presentation.
22 I think the traditional remedies that the court finds
23 appropriate in case after case -- a large cash bond; passport
24 relinquished; waiving extradition; a bracelet on; some form of
25 supervision that is adequate to guarantee his appearance, it
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00000423

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