{
  "document_metadata": {
    "page_number": "30",
    "document_number": "Case 1:19-cr-00290-RMB Document 32 Filed 07/18/19 Page 30 of 33",
    "date": "07/18/2019",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "(2) The defense bail package proposes excessive involvement of the Court in routine aspects of Mr. Epstein's proposed home confinement. This is not the Court's function. See United States v. Zarrab, 2016 WL 3681423, at *10 (S.D.N.Y. June 16, 2016) (\"The [bail package] . . . proposed by the defense is not reasonable because, in too many respects, it substitutes judicial oversight and management for (more appropriate) reliance upon trained, experienced, and qualified professionals from the U.S. Bureau of Prisons and the U.S. Marshals Service.\") The Defense package components would embroil the Court in issues, among others, relating to the level of force that may be used to secure the Defendant, who may enter the residence, daily reporting by Mr. Epstein, and reporting by so-called Trustee(s) designated to live with and supervise Mr. Epstein. See United States v. Valerio, 9 F. Supp. 3d 283, 295 (E.D.N.Y. 2014) (\"The questions about the legal authorization for the private security firm to use force against defendant should he violate the terms of his release, and the questions over whether the guards can or should be armed, underscore the legal and practical uncertainties - indeed, the imperfections - of the private jail-like concept envisioned by defendant, as compared to the more secure option of an actual jail.\") (3) The Defense proposal to give advance consent to extradition and waiver of extradition rights is, in the Court's view, an empty gesture. And, it comes into pay only after Mr. Epstein has fled the Court's jurisdiction. According to the Government, \"The Department of Justice's Office of International Affairs is unaware of any country anywhere in the world that would consider an anticipatory extradition waiver binding. And, of course, the defendant could choose to flee to a jurisdiction with which the United States does not have an extradition treaty.\" Dkt. 11 at 7. (4) Although the Defense has stated that Mr. Epstein would be agreeable to putting up \"any amount\" of collateral or signing \"any bond\" the Court would require, there has, to date,",
  "text_blocks": [
    {
      "type": "printed",
      "content": "(2) The defense bail package proposes excessive involvement of the Court in routine aspects of Mr. Epstein's proposed home confinement. This is not the Court's function. See United States v. Zarrab, 2016 WL 3681423, at *10 (S.D.N.Y. June 16, 2016) (\"The [bail package] . . . proposed by the defense is not reasonable because, in too many respects, it substitutes judicial oversight and management for (more appropriate) reliance upon trained, experienced, and qualified professionals from the U.S. Bureau of Prisons and the U.S. Marshals Service.\") The Defense package components would embroil the Court in issues, among others, relating to the level of force that may be used to secure the Defendant, who may enter the residence, daily reporting by Mr. Epstein, and reporting by so-called Trustee(s) designated to live with and supervise Mr. Epstein. See United States v. Valerio, 9 F. Supp. 3d 283, 295 (E.D.N.Y. 2014) (\"The questions about the legal authorization for the private security firm to use force against defendant should he violate the terms of his release, and the questions over whether the guards can or should be armed, underscore the legal and practical uncertainties - indeed, the imperfections - of the private jail-like concept envisioned by defendant, as compared to the more secure option of an actual jail.\")",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "(3) The Defense proposal to give advance consent to extradition and waiver of extradition rights is, in the Court's view, an empty gesture. And, it comes into pay only after Mr. Epstein has fled the Court's jurisdiction. According to the Government, \"The Department of Justice's Office of International Affairs is unaware of any country anywhere in the world that would consider an anticipatory extradition waiver binding. And, of course, the defendant could choose to flee to a jurisdiction with which the United States does not have an extradition treaty.\" Dkt. 11 at 7.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "(4) Although the Defense has stated that Mr. Epstein would be agreeable to putting up \"any amount\" of collateral or signing \"any bond\" the Court would require, there has, to date,",
      "position": "bottom"
    }
  ],
  "entities": {
    "people": [
      "Mr. Epstein"
    ],
    "organizations": [
      "U.S. Bureau of Prisons",
      "U.S. Marshals Service",
      "Department of Justice"
    ],
    "locations": [
      "United States"
    ],
    "dates": [
      "June 16, 2016",
      "July 18, 2019"
    ],
    "reference_numbers": [
      "Case 1:19-cr-00290-RMB",
      "Dkt. 11"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the bail package proposed by the defense for Mr. Epstein. The text is printed and there are no visible stamps or handwritten notes. The document is page 30 of 33."
}