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Case 1:19-cr-00490-RMB Document 36 1 know 1£ there are mor 12 cases, all of which involve a 2 minor victim -- kidnapping, sex trafficking of children, 3 aggravated sexual abuse, sexual abuse, offenses resulting in 4 death, sexual exploitation of children, selling and buying of 5 children, the production of sexually explicit depictions of a 6 minor for importation into the United States, crimes involving 7 the transportation of minor victims, coercion and enticement, 8 transport of minors, and use of interstate facilities to ) transmit information about a minor. 10 All of those --— there may be others, but those are the 11 ones we found -- also carried this presumption of remand 12 instead of bail. 13 MR. WEINBERG: Yes, your Honor. 14 THE COURT: Presumption. 15 MR. WEINBERG: Yes, your Honor. If we're looking at 16 1591 -- and I'm not here today to in any way diminish the 17 gravity of the allegations against Mr. Epstein, but it's far 18 away from the heartland of 1591 commercial sex trafficking that 19 deals with servitude and deals with enslavement and deals with 20 pimps, if can use that word, selling women for commercial 21 profit. 22 We've provided the Court with some of the division in 28 the law, including decisions by this Court, by Judge Jones 24 relying on a South Dakota opinion, by the chief justice that 25 finds the statute inapplicable. Filed 07/24/19 Page 29 of 74 29 SOUTHE RN D STR CT REPORT (212) 805-0300 BRS, P.C. DOJ-OGR-00000539