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835 KB
Extraction Summary
4
People
3
Organizations
1
Locations
2
Events
1
Relationships
6
Quotes
Document Information
Type:
Legal document
File Size:
835 KB
Summary
This legal document, part of a filing to Judge Richard M. Berman, argues against the government's position that Jeffrey Epstein's wealth creates an 'irrebuttable presumption' that he is a flight risk and should be denied release. The filing contends that this amounts to a 'per se rule' that is contrary to law. It cites government arguments from other court records which detail Epstein's financial sophistication, international ties, and ability to transfer assets and earn millions abroad as reasons why no bail conditions could be effective.
People (4)
| Name | Role | Context |
|---|---|---|
| Richard M. Berman | Honorable (Judge) |
The document is addressed to Hon. Richard M. Berman.
|
| Epstein | Defendant |
Mentioned throughout as the subject of the legal argument, referred to as 'defendant' and by name. His wealth is the ...
|
| Fierro | Party in a legal case |
Mentioned in a case citation: 'Fierro v. Taylor'.
|
| Taylor | Party in a legal case |
Mentioned in a case citation: 'Fierro v. Taylor'.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Court | Government agency |
Mentioned as the body that should reject the government's argument.
|
| government | Government agency |
Presented as the opposing party in the legal argument, whose 'misguided effort' is being challenged.
|
| SDNY | Court |
Mentioned in a case citation as the court for Fierro v. Taylor (Southern District of New York).
|
Timeline (2 events)
2019-07-15
A court transcript (Tr.) from this date is cited, where an argument was made that the defense could not meet the standard to rebut the presumption of flight risk.
Court
defense
government
Locations (1)
| Location | Context |
|---|---|
|
Mentioned as the current location of the defendant's assets and a place he could earn money outside of.
|
Relationships (1)
The document outlines the government's argument for detaining Epstein and Epstein's (implied) counter-argument against it, positioning them as opposing parties in a legal case.
Key Quotes (6)
"even if the defense were able to at some point to rebut the presumption by providing some more information, there simply is no way that they can meet the standard here"Source
— Unknown (from 7/15/19 Transcript)
(Cited as an example of the government's argument that Epstein cannot be released.)
DOJ-OGR-00000432.jpg
Quote #1
"even assuming the defendant’s assets are presently in the United States, nothing … would prevent the defendant from transferring liquid assets out of the country quickly and in anticipation of flight or relocation."Source
— Unknown (from 7/12/19 Letter)
(Cited to support the argument that the defendant is a flight risk due to his ability to move assets.)
DOJ-OGR-00000432.jpg
Quote #2
"The defendant is an incredibly sophisticated financial actor with decades of experience in the industry and significant ties to financial institutions and actors around the world. He could easily transfer funds and holdings on a moment’s [notice] to places where the [g]overnment would never find them so as to ensure he could live comfortably while a fugitive."Source
— Unknown (from 7/12/19 Letter)
(Cited to describe the defendant's financial capabilities as a reason he is a flight risk.)
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Quote #3
"even were the defendant to sacrifice literally all of his current assets, there is every indication that he would immediately be able to resume making … tens of millions of dollars per year outside of the United States…."Source
— Unknown (from 7/12/19 Letter)
(Cited to argue that even forfeiting his assets would not prevent the defendant from having the means to live as a fugitive.)
DOJ-OGR-00000432.jpg
Quote #4
"[T]here would be little to stop the defendant from fleeing, transferring his unknown assets abroad, and then continuing to … earn his vast wealth from a computer terminal beyond the reach of extradition."Source
— Unknown (from 7/12/19 Letter)
(Cited to argue the defendant's ability to flee and continue earning money makes him a flight risk.)
DOJ-OGR-00000432.jpg
Quote #5
"the notion that any individual co-signer could meaningfully secure a bond for this defendant strains credulity"Source
— Unknown (from 7/12/19 Letter)
(Cited to argue that a bond would be ineffective in securing the defendant's appearance.)
DOJ-OGR-00000432.jpg
Quote #6
Full Extracted Text
Complete text extracted from the document (2,171 characters)
Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 2 of 9
Hon. Richard M. Berman
July 16, 2019
Page 2
July 16, 2019
Page 2
Epstein’s wealth creates an irrebuttable presumption whereby no
condition(s) can reasonably assure personal appearance or protect the
public. The Court should reject the government’s misguided effort to
effectively create a per se rule.2 Indeed, for the government, there’s
literally nothing a person of Epstein’s means could say, do or pledge to
rebut the operative presumption and make himself eligible for release.
condition(s) can reasonably assure personal appearance or protect the
public. The Court should reject the government’s misguided effort to
effectively create a per se rule.2 Indeed, for the government, there’s
literally nothing a person of Epstein’s means could say, do or pledge to
rebut the operative presumption and make himself eligible for release.
That cannot be the law. Such a construction turns the statute’s
____________________
massages for money. See Fierro v. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3
(SDNY July 2, 2012) (holding that sex purchasers from minors fall outside § 1591’s
ambit).
massages for money. See Fierro v. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3
(SDNY July 2, 2012) (holding that sex purchasers from minors fall outside § 1591’s
ambit).
2 E.g., 7/15/19 Tr. 11 (“even if the defense were able to at some point to rebut the
presumption by providing some more information, there simply is no way that they
can meet the standard here”); 7/12/19 Ltr. 5 (“even assuming the defendant’s assets
are presently in the United States, nothing … would prevent the defendant from
transferring liquid assets out of the country quickly and in anticipation of flight or
relocation. The defendant is an incredibly sophisticated financial actor with decades
of experience in the industry and significant ties to financial institutions and actors
around the world. He could easily transfer funds and holdings on a moment’s [notice]
to places where the [g]overnment would never find them so as to ensure he could live
comfortably while a fugitive.”); id. (“even were the defendant to sacrifice literally all
of his current assets, there is every indication that he would immediately be able to
resume making … tens of millions of dollars per year outside of the United States….
[T]here would be little to stop the defendant from fleeing, transferring his unknown
assets abroad, and then continuing to … earn his vast wealth from a computer
terminal beyond the reach of extradition.”) (footnote omitted); id. 7 (“the notion that
any individual co-signer could meaningfully secure a bond for this defendant strains
credulity”).
presumption by providing some more information, there simply is no way that they
can meet the standard here”); 7/12/19 Ltr. 5 (“even assuming the defendant’s assets
are presently in the United States, nothing … would prevent the defendant from
transferring liquid assets out of the country quickly and in anticipation of flight or
relocation. The defendant is an incredibly sophisticated financial actor with decades
of experience in the industry and significant ties to financial institutions and actors
around the world. He could easily transfer funds and holdings on a moment’s [notice]
to places where the [g]overnment would never find them so as to ensure he could live
comfortably while a fugitive.”); id. (“even were the defendant to sacrifice literally all
of his current assets, there is every indication that he would immediately be able to
resume making … tens of millions of dollars per year outside of the United States….
[T]here would be little to stop the defendant from fleeing, transferring his unknown
assets abroad, and then continuing to … earn his vast wealth from a computer
terminal beyond the reach of extradition.”) (footnote omitted); id. 7 (“the notion that
any individual co-signer could meaningfully secure a bond for this defendant strains
credulity”).
DOJ-OGR-00000432
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