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This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

EFTA00076815

25 pages
Pages 21–25 / 25
Page 21 / 25
326 
4,i FEDERAL SUPPLEMENT, 3d SERIES 
abroad, and residing in part in Paris, 
France; there would be little to stop the 
defendant from fleeing, transferring his 
unknown assets abroad, and then continu-
ing to do whatever it is he does to earn his 
vast wealth from a computer terminal be-
yond the reach of extradition." Dkt. 11 at 5 
(emphasis omitted). The Defendant, it 
should also be noted, is already at risk of 
losing some of his real property because 
the Indictment contains a forfeiture allega-
tion regarding any property that was used 
or intended to be used to commit or to 
facilitate the sex trafficking offenses and 
that includes, but it is not limited to, the 
property located at 9 East 71st Street, 
New York, New York. 
(5) The appointment and role of "trus-
tees" who will presumably live with Mr. 
Epstein and monitor his compliance with 
bail conditions are unacceptably vague. 
They do not, for example, address the 
conflict that is created by the salary the 
"trustees" are earning from the Defendant 
and their purported role as independent 
monitors. (The same problem arises in re-
lation to private 24/7 security guards.) This 
is especially problematic where, as here, it 
is alleged that employees of the Defendant 
may have engaged in unlawful acts with 
and on behalf of the Defendant. According 
to the Government, "the defendant worked 
with others, including employees and asso-
ciates who facilitated his exploitation of 
minors, by among other things, contacting 
victims and scheduling their sexual en-
counters with the defendant, both in New 
York and in Florida." Dkt. 11, Ex 1 at 2. 
(6) "As a fallback," the Defense sug-
gests the utilization of and the funding of a 
private security guard agency to "virtually 
guarantee" Mr. Epstein's presence in court 
and, presumably, also to supervise his be-
havior. This contingency plan is not a part 
of Mr. Epstein's 14 point proposal. Never-
theless, the Court is asked by the defense 
to "revisit" its legal viewpoint as expressed 
in an earlier decision concerning 24/7 pri-
vate home security guards. 
[181 Each bail package in each case is 
considered and evaluated on its individual 
merits by the Court. And, in view of the 
Court's finding of dangerousness, a new 
bail proposal likely would be futile. See, 
g, United Ferranti, 66 F.3d at 544 ("No 
conceivable conditions could ensure the 
safety of the community."); Orena, 986 
F.2d at 632 ("We do not agree that the bail 
conditions set by the district court elimi-
nate the danger to the community or are 
superior to detention for purposes of the 
Bail Reform Act."); United States v. Co-
lombo, 777 F2d 96, 100 (2d Cir. 1985) 
("These conditions are clearly inadequate 
to protect the public from one found for 
bail purposes to be a danger to the com-
munity."). 
Conclusion & Order 
Based upon the forgoing, the Govern-
ment's motion for remand (detention) is 
granted and the Defense motion for pre-
trial release is denied. 
Attachment 
EFTA00076835
Page 22 / 25
U.S. v. EPSTEIN 
Cite .s425 F.Supp3d 306 (S.D.N.Y. 2019) 
Attachment—Continued 
Case 0 013cv.907303•KAM Document 361.11 Entered ors FLSD Docket 02/1(V2016 Page 2 of 3 
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From: 
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To: 
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Information «ntaine0 in this chenkakation is 
confidential: may be attornerclieet 
privileged: esti 
COAStitote Inside information: and IS intended Only for 
P IAA J.IPA 
327 
EFTA00076836
Page 23 / 25
328 
42s FEDERAL SUPPLEMENT, 3d SERIES 
Attachment—Continued 
Case 0:0B-cv-60736.KAM Doanent 361.11 Entered on FLSD Docket 02/102016 Page 3 cd 3 
the use of the addressee. It is the PreParte of 
Kirkland g (Ills lip or Kirkland $ Ellis Internetkeel LW. 
unauthorized use, disclosure or copying of this 
eoter
unlcation or any part thereof is strictly prohibited 
lm
say be unlawful. If you have received this 
Ration in error, please notify us immediately by 
return e.mall or by e•aeil to postfiestergkirkland.coe, zed 
destroy this cominication and all copies thereof, 
including all attachments. 
The Infonetloo contained in this conmeatication is 
confidential, say be attorney-client privileged, say 
constitute inside information, and is intended only for 
the use of the addressee. It Is the property of 
 
mid a jilts Li, or Kirkland & kills International lip. 
Unauthorized use, disclosure or cowing of FhIS 
ttehhetrettehoranY part thereof is strictly prohibited 
and say be unlawful. If you have received this 
corinunication in error, please notify us iniediataly by 
return freell or by •-seil to posteastorilkireland.coe are 
destroy this communication awl all copies thereof, 
including all attachments. 
• 
• 
Pi • 1.1403.11le 
EFTA00076837
Page 24 / 25
U.S. v. EPSTEIN 
Cite .s623 F.Supp3d 306 (S.D.N.Y. 2019) 
Attachment—Continued 
Case 908-cv60736-KAM Document 361-10 Emoted on FLSD Docket 02/10,2016 Page 2 of 2 
*mom 
lueihMt. WPM*. 111. 2C0/ 8 m Ake 
Jay Lelkontz* 
Omit ameemmts" 
II. 
lugs hoping there would be things for Inc to read this morning. but I will ay to remain patien 
I believe there are only Iwo types of speernents that would apply to ibis case (I) a plea ;Lineman to a :kderal 
charge or charges; and t2) a nun-prosecution agrcemeal (which is really a deferred prosecution agreement 
because the defendant agrees chit if he violases the agreement. the US Can prosecute him). 
A plea agramem is part of the coon file. It is not accessible on-line Ss PACER. but someone cm go to the 
Clcdes Office to obtain, copy. 
A non-proseeution agreement would not be made public x tiled with the Cost bin it *oak: remain pin oroa 
case file. h probably would be subject to a FOIA ropes. but ti is no winch ng that we would distnhie 
without compulsory process 
On the et utmccien charges. many of the fats I included S that first Troffer were hypothesized based icon our 
die:onions and the ages etecruutime of
 We will need ha inlets icw her IC confine, 'he accvnicy of 
those facts led a second count. we ould rely on the incident wbcre Mr. Epascin's private investigators 
followed MSfather forcing him off the road. Or, if litre is something mom mom related to any NM 
we could consider 
ope that helps. 
re SA 008to. 
329 
EFTA00076838
Page 25 / 25
330 
425 FEDERAL SUPPLEMENT, 3d SERIES 
Attachment—Continued 
0 9O8-cv-60736.KM! Document 361-9 Fitted on FLSO Docket 02/10/2016 Page 2 of 2 
Jay Leftover illersarmsastIttra conS 
. Pint agroornerea 
Confidential • Foe settlement merpows only 
Still winking en redline aut pit lank at this 
On August 
200. FRI Spinal Agrrn 
rave£J to the ha of 
vestgatiai send am it. tic 
Southern District of Flossie. Mr. [poem wa informed °filar serske of the 
As a 
rrauk. Mr. EpSteia attempted to caner both 
delay and hinder that 
receipt ofs 
Ita attend an official proceeding, rsMrc panktdarly the -'to 
which 
Mr. Epstein. In Funicular. changed navel pWts and flee with both 
to the exited States Vein Islands rather than in an airport in New Jersey in order to attempt ty 
delay shot: tntipa of whit Mr. Epsteincanoed to be s 
Mr. Eosins (ergs' 
verbally harassed both 
ia come:Won to this allniipt to delay our Vultellaly 
roc c5x 0 rimoCcas all in Malaita. of IS USC !SI 2.44)( I ). 
---orbaso Massa e 
rem: 
•
: 
To: fay Letkowee 
Subject: RE: Draft Agreemain? 
iii h• limn kiwis the le<mul haw £c the litigant 
her AIM ar 
no tneronJum 
evaintec oleo Y. the :gems teed to tak hi Oern a,3 then lean taiga mupowl Noun proffer. I hoe c' an e 
nun si nasty and I an ..a in 3e;gniune ,her aviabkhr) 
The infomucion contained in OW communication is 
confidential. may he attorney-rhea Pnvtleged. may 
tonatatne nude information. and is totem:led only for 
theme of the addressee. S Is the property of 
. .id, 
Ellis 
LLP 
es 
Kirkland 
& 
Ell
ilk..
is lawniatimal LLP. 
tumhorizet use, disclosure et cop)^ag of tNs 
. mmunication or any pan thacof is strictly whisked 
and may be untamful. If soo have waved this 
BLAKE MARINE GROUP, 
LLC, Plaintiff, 
v. 
FRENKEL & COMPANY, Defendant. 
18-CV-10759 (AT) (CIIP) 
United States District Court, 
S.D. New York. 
EFTA00076839
Pages 21–25 / 25