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Case 1:19-cr-00490-RMB Document 24 Filed 07/16/19 Page5of9 Hon. Richard M. Berman July 16, 2019 Page 5 during the July 15 argument, Epstein will agree to any monetary condition — consistent with his Sixth Amendment need to retain counsel and pay ordinary expenses, which, at the Court’s discretion, could be subject to supervision by a Court-appointed trustee — that collateralizes his assets as a condition of release. Fourth, to the extent the government complains Epstein lacks meaningful domestic ties, we clarify and emphasize that his brother Mark, a U.S. resident, stands prepared to co-sign and secure a release bond in the full amount of his “own net worth,”’4 which exceeds $100 million — tangible proof of his certainty that Epstein will appear as necessary. Fifth, in response to the Court’s inquiry about Epstein’s New Mexico registration status, the state’s Public Safety Department formally advised in August 2010 that “you are not required to register with the State of New Mexico ... for your 2008 Florida conviction of Procuring Person Under 18 for Prostitution.” Nonetheless, in an abundance of 4 7/12/19 Ltr. 6 (footnote omitted). DOJ-OGR-00000449