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J Caseist9-cr-00490-RMB Document 40 Filed 07/26/19 Page 4 of 6 4 who th e 1 the compelling testimony of Annie Farmer and Courtney Wild, 2 testified that they fear for their safety and the safety of 3 others if Mr. Epstein were to be released. 4 I also point out that the presumption of remand, as 5 opposed to the presumption of release, is unusual in our 6 jurisprudence and that it attaches only to very serious crimes, 7 such as sex trafficking involving minor victims, as in this 8 case some allegedly as young as age 14. ) I also discuss evidence of intimidation and threats 10 and compensation paid to potential witnesses and the facts 11 surrounding whether or not Mr. Epstein has been compliant wi 12 his legal obligations as a registered sex offender. 13 When discussing risk of flight, which you obviously 14 can tell comes after, in my analysis, dangerousness to the 15 community, when discussing that aspect, risk of flight, the 16 decision speaks to the seriousness of the charged crimes, to 17 Mr. Epstein's great wealth and his vast resources, which 18 include private planes and frequent international travel and 19 also a foreign residence in Paris. 20 I mention the items very recently seized from Mr. 21 Epstein's New York City mansion pursuant to lawful search 22 warrants, which include sexually explicit photos and discs, 23 some $70,000 in cash, diamonds, and an expired Austrian 24 passport with Mr. Epstein's photo but with a name that is 25 different from Jeffrey Epstein, and also contains a referenc SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR- 00000608