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Document Case 1:19-cr-00290-RMB-DCF Document 32 Filed 07/18/19 Page 28 of 33

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incorporated here by reference. See Minnici, 128 F. App'x at 829–30 ("the alleged activities [we]re of an addictive sexual nature that cannot be suppressed simply by a restrictive set of bail conditions"); see also Millan, 4 F.3d at 1049 ("[T]he protection of the community can be assured only by continued detention."). The Court has carefully considered the issue of Defendant's ability and motivation for fleeing U.S. jurisdiction. The Court finds that the Government has proven by a preponderance of the evidence that, among other things, the Defendant's limited family ties to the United States, his residence in Paris, his extensive overseas travel, his significant wealth and his substantial resources (including private planes), and the potential 45 year term of imprisonment that may be imposed should there be a conviction in this case, provide incentive, motive and wherewithal to flee. Indeed, these factors render him a "classic" flight risk. See, e.g., United States v. Abdullahu, 488 F.Supp.2d 433, 445 (D.N.J. 2007) ("After reviewing the totality of the evidence, the Court has reached the inescapable conclusion that the government has proved by a preponderance of the evidence that no condition or combination of conditions exist that will reasonably assure the defendant's appearance at trial. The defendant faces serious criminal charges . . . The defendant faces a potential ten year prison sentence and involuntary deportation. The defendant does not have permanent and longstanding ties to this area, he has the means and incentive to flee and he has family ties and a place to live in an overseas country that will not extradite him to the United States."). H. Defendant's Proposed Bail Package Having determined that Mr. Epstein is a flight risk (and also a danger to the community), the Court next examines the Defendant's proposed bail package. See 18 U.S.C. § 3142(b)-(f)(2).