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Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 8of9 Hon. Richard M. Berman July 16, 2019 Page 8 or terrorists should violent episodes occur. Ninth, the Court is undoubtedly aware of the highly charged context surrounding this prosecution. In November 2018, media reports suggested that Epstein received a plea deal that amounted to a “slap on the wrist.” Putting aside the robust negotiations leading to the non- prosecution agreement (NPA) and the prison sentence that Epstein completed, there can be no dispute that certain witnesses through their attorney representatives,11 the media — e.g., The Miami Herald — and the public were all clamoring for his re-prosecution, Epstein traveled extensively over these eight months and invariably returned to the United States. That inescapable reality emphatically proves he won’t flee and entitles him to release — on any and all conditions the Court deems appropriate. 11 See, e.g., Doe v. US, CV 807-36 (SD Fla.). DOJ-OGR- 00000438