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Casl48£01%-60490-RMB DbeuMEenPsD Pile OY1SHS2geage 2HF 33 pretrial release. § 3142 states that: “if there is probable cause to believe that the person committed ... an offense involving a minor victim under section .. . 1591,” then “it shall be presumed that no condition or combination of conditions will reasonably assure the appearance of the person as required and the safety of the community.” 18 U.S.C. § 3142(e)(3)(E) (emphasis added); see United States v. Martir, 782 F.2d 1141, 1144 Qd Cir. 1986). The Indictment in this case was returned by a grand jury thus establishing probable cause that the defendant committed the crimes of sex trafficking and sex trafficking conspiracy. See United States v. Contreras, 776 F.2d 51, 55 (2d Cir. 1985) (“[A]n indictment returned by a duly constituted grand jury conclusively establishes the existence of probable cause for the purpose of triggering the rebuttable presumptions set forth in § 3142(e)”). In most federal cases the rebuttable presumption that applies favors pretrial release, not remand. There is another very important issue to be considered in this case. It has to do with “victims” of the crimes charged in the Indictment. Victims refer to the “minor” girls who are alleged to have been sexually trafficked by the Defendant. Under 18 U.S.C. § 3771, victims are entitled to be heard in court, including on the question of whether the defendant is to be released or remanded. Victims have, among other things, been given the opportunity to testify at the bail hearing. B. Counsels’ Submissions The Government’s letter application, dated July 8, 2019, requests that the Court remand Mr. Epstein. It argues that Mr. Epstein “poses [] an acute danger to the community” and, grounded in past experience with this Defendant, that “if [Mr. Epstein is] allowed to remain out on bail, the defendant could attempt to pressure and intimidate witnesses and potential witnesses in this case, including victims and their families, and otherwise attempt to obstruct justice.” Dkt. DOJ-OGR-00000785