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Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 6 of 33 trust account to... , [an individual] who was also named as a potential co-conspirator.” Id. at 1- 2. According to the Government, the second individual “is also one of the employees identified in the Indictment, which alleges that she and two other identified employees facilitated the defendant’s trafficking of minors by, among other things, contacting victims and scheduling their sexual encounters with the defendant at his residences in Manhattan and Palm Beach, Florida.” Id. at 2. By letter, dated July 16, 2019, Defense counsel states, among other things, that the Court should reject the idea that “‘there’s literally nothing a person of Epstein’s means could say, do or pledge to rebut the operative presumption and make himself eligible for release.” Dkt. 24 at 2. “Epstein contends that § 1591 and the concomitant remand presumption do not contemplate or cover the core conduct at issue here: performing sexual massages for money.” Id. at 1-2 n.1. Defense counsel also states that “Epstein certainly recognizes the Court’s request for further transparency and is committed to providing a complete and accurate disclosure. Accordingly, we propose that the Court preliminarily accept the initial [financial] disclosure proffered last Friday and, if intending to grant bail, include a release condition directing Epstein to tender a comprehensive forensic accounting of his finances as expeditiously as practicable.” Id. at 4. By letters, dated July 16 and July 17, 2019, Defense counsel also submitted information regarding Epstein’s New Mexico sex offender registration status. Defense counsel also stated that Epstein traveled extensively over the last eight months and “invariably returned to the 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.” Id. at 8. DOJ-OGR-00000477