DOJ-OGR-00000527.jpg

Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 17 of 74 17 1 your Honor. It does raise the question of how many other safes 2 are there in how many other locations with items like these. 3 The defendant also makes proposals that highlight, 4 rather than mitigate, the dangers of granting bail. His offer 5 to consent to extradition is unenforceable, and it highlights 6 his extensive connections abroad. 7 should say, your Honor —- Forgot to mention -- the 8 passport that just referenced listed at the time his 9 residence as Saudi Arabia, and this was from the 1980's. 10 THE COURT: Would you describe that passport again. 11 I'm not sure caught it. 12 MR. ROSSMILLER: can, your Honor. 13 The passport was issued in the name of a foreign 14 country. It appears to have been issued sometime in the 15 1980's. It is expired currently. It has a photo that appears 16 to be the defendant, and it has a name that is not Jeffrey 17 Epstein. 18 In connection with that, also want to note that the 19 defendant's proposal for private security is inadequate and 20 imoractical and would put the defendant in the position of 21 having complete financial control over the people who are 22 supposed to guard him. 28 As this Court has written: "What more compelling case 24 for an order of detention is there than a case in which only an 25 armed guard and the threat of deadly force is sufficient to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000527