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Case 1:19-cr-00490-RMB Document 36 1 case. 2 Second, there's an inherent contradiction between the 3 government's tying these two payments by Mr. Epstein in 4 November and early December of 2018 to witnesses as if these 5 are akin to an attemot to influence a witness. 6 If the government's position has any reality to it, 7 that Mr. Epstein reads an article and perceives that a friend 8 may be a witness, then that provides pretty strong evidence 9 that Mr. Epstein was concerned about an investigation. 10 Even if the government kept it secret and yet he 11 repeatedly flew not just out of the country but into the 12 country with the knowledge, with the belief, again, if the 13 government can tie these payments to an understanding, an 14 intent to effect a future investigation, that provides fairly 15 loquent evidence, your Honor, that Mr. Epstein does not intend 16 to flee. 17 And his conduct between November and December 3, 2018, 18 and the present is the antithesis of a defendant who wants to 19 flee. He was arrested flying into Teterboro from Europe. 20 Lastly, Mr. Joseph Jaffe is here, your Honor. If al your Honor in any way wanted him to inform the Court what 22 services he and his company can provide to better or to be one 23 of the multiple conditions that we've offered the Court as a 24 condition of release, he is here. 25 THE COURT: I could ask you through him or him SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 Filed 07/24/19 Page 68 of 74 68 DOJ-OGR-00000578