DOJ-OGR-00000452.jpg

Case 1:19-cr-00490-RMB Document 24 Filed 07/16/19 Page 8of9 Hon. Richard M. Berman July 16, 2019 Page 8 1980s, when hijackings were prevalent, in connection to Middle East travel. The passport was for personal protection in the event of travel to dangerous areas, only to be presented to potential kidnapers, hijackers 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 and the prison sentence Epstein completed, there’s no denying that although certain witnesses through their attorney representatives,!! 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-00000452