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Case 1:19-cr-00490-RMB Document6 Filed 07/11/19 Page 12 of 16 significantly undercuts any suggestion of current dangerousness based on any regulatory classification. Moreover, as discussed above, Mr. Epstein’s strict compliance with the various monitoring requirements associated with his sex-offender registration actually decrease any danger that he might otherwise pose. It is also worth noting that Mr. Epstein is classified as a tier-one sex offender, the lowest classification available, in the U.S. Virgin Islands, where he maintains his primary residence. The defense respectfully suggests that Mr. Epstein’s Virgin Islands designation is more consistent with the circumstances of the actual offenses for which he was convicted, and certainly more consistent with the predictive factor of whether there is a danger of recidivism which the defense contends there is not. Mr. Epstein’s financial means and past international travel do not extinguish this Court’s congressional mandate to order pretrial release in every case where reasonable conditions can assure the appearance of the defendant as required.’ Indeed, numerous courts have rejected government requests for detention, and instead ordered pretrial release, in cases where the charged defendant was either a non-citizen (unlike Mr. Epstein) or a naturalized citizen with substantial if not weightier contacts with foreign jurisdictions, including the following decisions: e United States v. Sabhnani, 493 F.3d 63 (2d Cir. 2007) (reversing district court order of detention of defendants, who were natives of Indonesia, and ordering release despite defendants’ “strong motive to flee” because of serious charges and “strong” evidence of guilt, despite finding that defendants faced “lengthy term of incarceration” if convicted, despite finding defendants possessed “ample means to finance flight,” despite finding that defendants “maintained strong family ties to their native countries as well as personal and professional ties to various locations in Europe and the Middle East,” and despite finding that defendants “could, with relatively little disruption, continue to operate their highly lucrative business from any number of overseas locations”); e United States v. Hansen, 108 F. App’x 331 (6th Cir. 2004) (affirming district court order of pretrial release of defendant, a resident and citizen of Denmark-from where defendant could not be extradited-charged with bulk cash smuggling and forfeiture, noting that the ? This Court’s opinion in Zarrab stands only for the proposition that wealthy defendants should not be provided an unfair advantage. It does not, of course, suggest that wealthy defendants should bear a special disadvantage. The facts supporting the Court’s ruling of pretrial detention in Zarrab are easily distinguishable. The present case does not have national security implications, Mr. Epstein is a United States citizen (and does not possess any dual citizenship), the only foreign country in which Mr. Epstein maintains a residence (France) has an extradition treaty with the United States, Mr. Epstein’s assets are almost all located in the United States (with the exception of his Paris residence), and Mr. Epstein has provided only truthful information to Pretrial Services. 12 DOJ-OGR-00000285