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Case 1:19-cr-00290-RMB Document 82 Filed 07/18/19 Page 25 of 33
"Defendant is currently, or has been in the past, a citizen or legal permanent resident of a country other than the United States." Dkt. 23 at 2.
Defense counsel contends that Defendant has one active passport that was surrendered and that "Mr. Epstein has no foreign passports." Dkt. 6 at 3 n. 3. With regard to the Austrian passport, the Defense explains that "Epstein . . . acquired the passport in the 1980s, when hijackings were prevalent, in connection to Middle East travel. The passport was for personal protection in the event of travel to dangerous areas, only to be presented to potential kidnappers, hijackers or terrorists should violent episodes occur." Dkt. 24 at 8. Details about how the passport was procured by Mr. Epstein in the name of another individual were not provided and are not known to the Government. See Dkt. 23 at 2 ("The Government is attempting to obtain additional information about the Foreign Passport, including how it was obtained and whether the passport is genuine or fabricated. But the defendant's possession of what purports to be a foreign passport issued under an alias gives rise to the inference the defendant knows how to obtain false travel documents and/or assume other, foreign identities. This adds to the serious risk of flight posed by the defendant.") The Government also argues that "the passport contains numerous ingress and egress stamps, including stamps that reflect use of the passport to enter France, Spain, the United Kingdom, and Saudi Arabia in the 1980s." Dkt. 30. By submission dated July 18, 2019, the Defense explains: "Epstein was given the passport at issue by a friend . . . He never used the document to travel internationally and never presented it to any immigration or customs authority. The passport stamps, predating his receipt of the document, do not reflect Mr. Epstein's entries or exits." Dkt. 31.
Defense counsel has submitted a one page document called "Asset Summary - June 30, 2019." It indicates that Epstein has cash in the amount of $56,547,773; fixed income valued at
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