This legal document argues that 'the defendant' presents a clear risk of flight due to international connections, significant financial means, and a transient lifestyle. The defendant has been in hiding since an indictment against Epstein was unsealed in July 2019, making efforts to avoid detection, including an all-cash property purchase in December 2019 through an anonymized LLC. The document concludes that home confinement with electronic monitoring would be inadequate to prevent the defendant from fleeing.
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