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Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 30 of 33
(2) The defense bail package proposes excessive involvement of the Court in routine
aspects of Mr. Epstein’s proposed home confinement. This is not the Court’s function. See
United States v. Zarrab, 2016 WL 3681423, at *10 (S.D.N.Y. June 16, 2016) (“The [bail
package] . . . proposed by the defense is not reasonable because, in too many respects, it
substitutes judicial oversight and management for (more appropriate) reliance upon trained,
experienced, and qualified professionals from the U.S. Bureau of Prisons and the U.S. Marshals
Service.”). The Defense package components would embroil the Court in issues, among others,
relating to the level of force that may be used to secure the Defendant, who may enter the
residence, daily reporting by Mr. Epstein, and reporting by so-called Trustee(s) designated to live
with and supervise Mr. Epstein. See United States v. Valerio, 9 F. Supp. 3d 283, 295 (E.D.N.Y.
2014) (“The questions about the legal authorization for the private security firm to use force
against defendant should he violate the terms of his release, and the questions over whether the
guards can or should be armed, underscore the legal and practical uncertainties - indeed, the
imperfections - of the private jail-like concept envisioned by defendant, as compared to the more
secure option of an actual jail.”).
(3) The Defense proposal to give advance consent to extradition and waiver of extradition
rights is, in the Court’s view, an empty gesture. And, it comes into pay only after Mr. Epstein has
fled the Court’s jurisdiction. According to the Government, “The Department of Justice’s Office
of International Affairs is unaware of any country anywhere in the world that would consider an
anticipatory extradition waiver binding. And, of course, the defendant could choose to flee to a
jurisdiction with which the United States does not have an extradition treaty.” Dkt. 1] at 7.
(4) Although the Defense has stated that Mr. Epstein would be agreeable to putting up
“any amount” of collateral or signing “any bond” the Court would require, there has, to date,
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Document Details
| Filename | DOJ-OGR-00000501.jpg |
| File Size | 749.3 KB |
| OCR Confidence | 94.1% |
| Has Readable Text | Yes |
| Text Length | 2,178 characters |
| Indexed | 2026-02-03 16:02:10.798698 |