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The Court finds that the Defendant's proposed bail package is inadequate. Among its deficiencies are these:
(1) The bail package is not accompanied or supported by audited or certified financial statements, including details of income and expenses and debt obligations. There is no affidavit from Mr. Epstein. As noted, Defense counsel submitted a cursory one page "Asset Summary - June 30, 2019" on Mr. Epstein's behalf in which he discloses several categories of assets totaling $559,120,954. The Defense states that it "would be impossible for Epstein - given, among other impediments, his detention, inability to quickly access pertinent records, and inability to quickly make a precise valuation of particular assets - to provide a sufficient financial statement by the Court's 5 pm deadline." Dkt. 23 at 4.
The absence of accurate and comprehensive financials, sworn to by the Defendant, does not allow the Court meaningfully to assess Defendants' own proposed bail package nor would it enable the Court to fashion a bail package on its own. The Court would not be able to determine what level of bail - in relation to Epstein's finances - would reasonably assure the Defendant's appearance. Defense counsel proposed at the bail hearing on July 15, 2019 that it would take a few days to prepare accurate financials for Mr. Epstein. He also suggested that he would do so (only) if the Court were agreeable to granting bail. This "offer" appears disingenuous for a person as wealthy and experienced in financial matters as Mr. Epstein. See Tr. 7/15/19 at 50 (Court: "There needs to be a fuller financial picture to know what would be appropriate." Defense Counsel: "Let me be blunt. It was our first effort . . . .") That Mr. Epstein does not have a financial statement, including liabilities and expenses, readily available is difficult to understand.
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DOJ-OGR-00000812