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Casl48£01%-40490-RMEDbeuMERPSA Pile OHIS/1192 Gra gGed 7 OF 33 David Boies, who, as noted, represents identified victims in this case, advised the Court that while a civil case was proceeding against the Defendant “we had situations in which we had witnesses who were cooperating with us and then were contacted by either Mr. Epstein or his lawyers and who then stopped cooperating with us.” 7/15/19 Tr. at 71; see also United States v. Boustani, 356 F.Supp.3d 246 (E.D.N.Y. 2019) (“[T]he combination of Defendant’s alleged deceptive actions, access to substantial financial resources, frequent international travel, complete lack of ties to the United States, and extensive ties to foreign countries without extradition demonstrates Defendant poses a serious risk of flight.” ); United States v. Epstein, 155 F.Supp.2d 323, 326 (E.D. Penn. 2001) (“The crucial factor, however, is defendant’s lack of ties to the United States and his extensive ties to Brazil with which no extradition treaty exists. In our view, his forfeiture of $1 million worth of assets in the United States would not deter him from flight when in Brazil he has significant wealth, a lucrative job, the presence of his family, and insulation from ever being forced to stand trial.”). Viewing the totality of the circumstances, the Court finds that the Government has shown by a preponderance of the evidence that Defendant is a serious risk of flight and that no conditions can be set that will reasonably assure his appearance at trial. ““While other judges in this district have found that an armed security guard may be sufficient to assure a defendant’s appearance, even when he is a serious risk of flight . . . this Court does not believe that that condition, even coupled with the additional conditions proposed, would be sufficient.” United Cilins, 2013 WL 3802012, at *3. e The Danger Posed By The Defendant’s Release As demonstrated infra, Mr. Epstein’s dangerousness is considerable and includes sex crimes with minor girls and tampering with potential witnesses. The discussion at pp 10-21 is 27 DOJ-OGR-00000810