{ "document_metadata": { "page_number": "5", "document_number": "18-cr-00490-RMB-Document 32", "date": "07/22/2019", "document_type": "Court Document", "has_handwriting": false, "has_stamps": false }, "full_text": "Case 1:18-cr-00490-RMB Document 32 Filed 07/18/19 Page 5 of 33\nlive in Mr. Epstein's residence and report any violation to Pretrial Services and/or the Court\";\n(14) \"Any other condition the Court deems necessary to reasonably assure Mr. Epstein's appearance.\" Id. at 3-4. The Defense also proposes as a \"fallback\" \"round-the-clock, privately funded security guards [which] will virtually guarantee - not just reasonably assure - Mr. Epstein's presence in the circumstances of this case.\" Id. at 10. The bail package originally was not accompanied by a financial statement reflecting Mr. Epstein's finances. However, on July 12, 2019, the Defense filed a one-page document which includes five groups of assets owned by Mr. Epstein totaling $559,120,954. Dkt. 14 at 18.\nThe Government responded to the Defense motion on July 12, 2019, arguing, among other things, that Mr. Epstein \"has a history of obstruction and manipulation of witnesses, including . . . as recently as within the past year, when media reports about his conduct [in Florida] reemerged.\" Dkt.11 at 1. The Government filing was made against a \"backdrop of significant—and rapidly-expanding—evidence, serious charges, and the prospect of a lengthy prison sentence.\" Id. It contends that the defendant's proposed conditions of release are \"woefully inadequate.\" Id.\nThe Court also received a letter from the Government, dated July 16, 2019, providing, among other things, details about allegedly suspicious payments made by the Defendant in 2018; a Palm Beach, Florida police report; Mr. Epstein's expired Austrian passport in another name but with Mr. Epstein's photo; and a pile of cash and diamonds found in Mr. Epstein's safe. For example, the Government says: \"[R]ecords from Institution-1 show that on or about November 30, 2018, or two days after the series in the Miami Herald began, the defendant wired $100,000 from a trust account he controlled to . . . , an individual named as a potential co-conspirator.\" Dkt. 23 at 1. And, \"on or about December 3, 2018, the defendant wired $250,000 from the same\n5\nDOJ-OGR-00000788", "text_blocks": [ { "type": "printed", "content": "Case 1:18-cr-00490-RMB Document 32 Filed 07/18/19 Page 5 of 33", "position": "header" }, { "type": "printed", "content": "live in Mr. Epstein's residence and report any violation to Pretrial Services and/or the Court\";\n(14) \"Any other condition the Court deems necessary to reasonably assure Mr. Epstein's appearance.\" Id. at 3-4. The Defense also proposes as a \"fallback\" \"round-the-clock, privately funded security guards [which] will virtually guarantee - not just reasonably assure - Mr. Epstein's presence in the circumstances of this case.\" Id. at 10. The bail package originally was not accompanied by a financial statement reflecting Mr. Epstein's finances. However, on July 12, 2019, the Defense filed a one-page document which includes five groups of assets owned by Mr. Epstein totaling $559,120,954. Dkt. 14 at 18.", "position": "top" }, { "type": "printed", "content": "The Government responded to the Defense motion on July 12, 2019, arguing, among other things, that Mr. Epstein \"has a history of obstruction and manipulation of witnesses, including . . . as recently as within the past year, when media reports about his conduct [in Florida] reemerged.\" Dkt.11 at 1. The Government filing was made against a \"backdrop of significant—and rapidly-expanding—evidence, serious charges, and the prospect of a lengthy prison sentence.\" Id. It contends that the defendant's proposed conditions of release are \"woefully inadequate.\" Id.", "position": "middle" }, { "type": "printed", "content": "The Court also received a letter from the Government, dated July 16, 2019, providing, among other things, details about allegedly suspicious payments made by the Defendant in 2018; a Palm Beach, Florida police report; Mr. Epstein's expired Austrian passport in another name but with Mr. Epstein's photo; and a pile of cash and diamonds found in Mr. Epstein's safe. For example, the Government says: \"[R]ecords from Institution-1 show that on or about November 30, 2018, or two days after the series in the Miami Herald began, the defendant wired $100,000 from a trust account he controlled to . . . , an individual named as a potential co-conspirator.\" Dkt. 23 at 1. And, \"on or about December 3, 2018, the defendant wired $250,000 from the same", "position": "middle" }, { "type": "printed", "content": "5", "position": "footer" }, { "type": "printed", "content": "DOJ-OGR-00000788", "position": "footer" } ], "entities": { "people": [ "Mr. Epstein" ], "organizations": [ "Pretrial Services", "The Court", "The Defense", "The Government", "Miami Herald" ], "locations": [ "Florida", "Palm Beach", "Austria" ], "dates": [ "July 12, 2019", "July 16, 2019", "November 30, 2018", "December 3, 2018", "2018" ], "reference_numbers": [ "18-cr-00490-RMB", "Dkt. 14", "Dkt. 11", "Dkt. 23", "DOJ-OGR-00000788" ] }, "additional_notes": "The document appears to be a court filing related to the case of Mr. Epstein. The text is mostly printed, with no visible handwriting or stamps. The document is page 5 of 33." }