DOJ-OGR-00000475.jpg

Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 4 of 33 Defense proposes what they describe as “‘a stringent set of [14] conditions that will effectively guarantee [Mr. Epstein’s] appearance and abate any conceivable danger he’s claimed to present.” Id. at 1. The 14 conditions do not include private security guards 24/7. The 14 conditions do include: (1) “Home detention in Mr. Epstein’s Manhattan residence, with permission to leave only for medical appointments as approved by Pretrial Services, including (at the Court’s discretion) the installation of surveillance cameras at the front and rear entrances to ensure compliance”; (2) “Electronic monitoring with a Global Positioning System”; (3) “An agreement not to seek or obtain any new passport during the pendency of this matter”; (4) “Consent to U.S. extradition from any country and waiver of all rights against such [e]xtradition”; (5) “A substantial [unspecified] personal recognizance bond in an amount set by the Court after reviewing additional information regarding Mr. Epstein’s finances .. . .”; (6) “The bond shall be secured by a mortgage on the Manhattan residence, valued at roughly $77 million. Mr. Epstein’s private jet can be pledged as further collateral”; (7) “Mr. Epstein’s brother Mark will serve as a co-surety of the bond, which shall be further secured by a mortgage on Mark’s home in West Palm Beach, Florida. Mr. Epstein’s friend David Mitchell will also serve as a co-surety and pledge his investment interests in two properties to secure the bond”; (8) “Mr. Epstein shall deregister or otherwise ground his private jet’; (9) Mr. Epstein “shall demobilize, ground, and/or deregister all vehicles or any other means of transportation in the New York area, providing particularized information as to each vehicle’s location;” (10) “Mr. Epstein will provide Pretrial Services and/or the government random access to his residence”; (11) “No person shall enter the residence, other than Mr. Epstein and his attorneys, without prior approval from Pretrial Services and/or the Court”; (12) “Mr. Epstein will report daily by telephone to Pretrial Services (or on any other schedule the Court deems appropriate)”; (13) “A Trustee or Trustees will be appointed to DOJ-OGR-00000475