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Case 1:19-cr-00490-RMB Document 32 _ Filed 07/18/19 Page 32 of 33
Defendant and their purported role as independent monitors. (The same problem arises in
relation to private 24/7 security guards.) This is especially problematic where, as here, it is
alleged that employees of the Defendant may have engaged in unlawful acts with and on behalf
of the Defendant. According to the Government, “the defendant worked with others, including
employees and associates who facilitated his exploitation of minors, by among other things,
contacting victims and scheduling their sexual encounters with the defendant, both in New York
and in Florida.” Dkt. 11, Ex. 1 at 2.
(6) “As a fallback,” the Defense suggests the utilization of and the funding of a private
security guard agency to “virtually guarantee” Mr. Epstein’s presence in court and, presumably,
also to supervise his behavior. This contingency plan is not a part of Mr. Epstein’s 14 point
proposal. Nevertheless, the Court is asked by the defense to “revisit” its legal viewpoint as
expressed in an earlier decision concerning 24/7 private home security guards.
Each bail package in each case is considered and evaluated on its individual merits by the
Court. And, in view of the Court’s finding of dangerousness, a new bail proposal likely would be
futile. See, e.g., United Ferranti, 66 F.3d at 544 (“No conceivable conditions could ensure the
safety of the community.”); Orena, 986 F.2d at 632 (“We do not agree that the bail conditions set
by the district court eliminate the danger to the community or are superior to detention for
purposes of the Bail Reform Act.”); United States v. Colombo, 777 F.2d 96, 100 (2d Cir. 1985)
(“These conditions are clearly inadequate to protect the public from one found for bail purposes
to be a danger to the community.”).
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Document Details
| Filename | DOJ-OGR-00000503.jpg |
| File Size | 662.4 KB |
| OCR Confidence | 94.6% |
| Has Readable Text | Yes |
| Text Length | 1,847 characters |
| Indexed | 2026-02-03 16:02:10.504496 |