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Case 1:19-cr-00490-RMB Documentii-1 Filed 07/12/19 Page1of10
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
July 8, 2019
VIA ECF
The Honorable Henry Pitman
United States District Court
Southern District of New York
United States Courthouse
500 Pearl Street
New York, New York 10007
Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Pitman:
The Government respectfully submits this letter in advance of the bail hearing scheduled
for July 8, 2019, in the above-captioned case. For the reasons set forth herein, the Court should
order that the defendant be detained pending trial; he cannot meet his burden of overcoming the
presumption that there is no combination of conditions that would reasonably assure his continued
appearance in this case or protect the safety of the community were he to be released.
As set forth below, the charges in this case are exceptionally serious: the defendant is
alleged to be a serial sexual predator who preyed on dozens of minor girls over a period of years,
and he now faces a potentially massive prison sentence predicated on substantial and multifaceted
evidence of his guilt. In light of the strength of the Government’s evidence and the substantial
incarceratory term the defendant would face upon conviction, there is an extraordinary risk of
flight, particularly given the defendant’s exorbitant wealth, his ownership of and access to private
planes capable of international travel, and his significant international ties. Indeed, the arrest of
the defendant occurred when he arrived in the United States on his private jet after having returned
from a multi-week stay abroad.
Finally, and as detailed herein, the Government has real concerns—grounded in past
experience with this defendant—that if allowed to remain out on bail, the defendant could attempt
to pressure and intimidate witnesses and potential witnesses in this case, including victims and
their families, and otherwise attempt to obstruct justice. As a result, he poses both an acute danger
to the community, including some of its most vulnerable members, and a significant risk of flight.
The defendant thus cannot overcome the statutory presumption that detention is appropriate in this
case, and the Court should order that he be detained pending trial.
DOJ-OGR-00000343