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775 KB

Extraction Summary

4
People
3
Organizations
2
Locations
4
Events
2
Relationships
2
Quotes

Document Information

Type: Legal document
File Size: 775 KB
Summary

This legal document, part of a court filing, argues for the severity of the crimes Mr. Epstein is charged with, citing their heinous nature involving minors. It presents evidence that Mr. Epstein or his representatives engaged in witness intimidation, threats, and made payments to potential witnesses, referencing Florida police reports from 2006 and emails from his former counsel to federal prosecutors in 2007.

People (4)

Name Role Context
Mr. Epstein Defendant
Subject of criminal charges, investigation, and allegations of witness intimidation.
Roger Przybylski Author
Cited as the author of 'Chapter 5: Adult Sex Offender Recidivism' from the Sex Offender Management Assessment and Pla...
Mr. Epstein's former counsel Attorney
Mentioned as having sent emails to Federal prosecutors in Florida in 2007 regarding witness tampering.
Mr. Epstein's representative Representative
Quoted in a Palm Beach Police Incident Report as having threatened and offered compensation to one of Mr. Epstein's v...

Organizations (3)

Name Type Context
Sex Offender Management Assessment and Planning Initiative Initiative/Program
Cited for its publication on sex offender recidivism rates.
Palm Beach Police government agency
Authored an Incident Report dated July 19, 2006, detailing witness intimidation.
Federal prosecutors in Florida government agency
Recipients of emails from Mr. Epstein's former counsel in 2007.

Timeline (4 events)

2006
Florida state criminal investigation of Mr. Epstein, during which harassment and intimidation of witnesses occurred.
Florida
2006-07-19
A Palm Beach Police Incident Report was filed, stating that one of Mr. Epstein's victims reported being threatened and offered compensation by his representative.
Palm Beach
Mr. Epstein's representative one of Mr. Epstein's victims
2007-09-13
Mr. Epstein's former counsel sent an email to Federal prosecutors in Florida.
Florida
2007-09-19
Mr. Epstein's former counsel sent a second email to Federal prosecutors in Florida.
Florida

Locations (2)

Location Context
Location of a state criminal investigation into Mr. Epstein and where Federal prosecutors received emails from his co...
Location of the police department that filed an incident report related to the case.

Relationships (2)

The document states the counsel is Mr. Epstein's 'former counsel' and acted on his behalf by communicating with prosecutors.
The document states the representative spoke to a victim on Mr. Epstein's behalf, offering compensation and threats.

Key Quotes (2)

"[R]esearchers widely agree that observed recidivism rates are underestimates of the true reoffense rates of sex offenders. Hidden offending presents significant challenges for professionals working in sex offender management as it is difficult to know whether offenders who appear to be nonrecidivists based on official records are truly offense free."
Source
— Sex Offender Management Assessment and Planning Initiative (Quoted to argue that the crimes Mr. Epstein is charged with are heinous and that recidivism is often underreported.)
DOJ-OGR-00000486.jpg
Quote #1
"Those who help [Mr. Epstein] will be compensated and those who hurt [Mr. Epstein] will be dealt with."
Source
— Mr. Epstein's representative (A statement made to one of Mr. Epstein's victims, as documented in a Palm Beach Police Incident Report, used as evidence of witness intimidation and tampering.)
DOJ-OGR-00000486.jpg
Quote #2

Full Extracted Text

Complete text extracted from the document (2,184 characters)

Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 15 of 33
underage before or during the period in which he abused them.” Id. The crimes with which Mr. Epstein is charged carry a maximum sentence of 45 years of incarceration. Id. at 5. “[T]he deprivation of liberty imposed by imprisonment makes that penalty the best indicator of whether the legislature considered an offense to be . . . ‘serious.’” United States v. Dugan, 667 F.3d 84, 86 (2d Cir. 2011) (quoting Lewis v. United States, 518 U.S. 322, 326 (1996)).
And, the crimes Mr. Epstein has been charged with are among the most heinous in the law principally, in the Court’s view, because they involve minor girls. 18 U.S.C. § 3142 (e)(3)(E); see also Roger Przybylski, Chapter 5: Adult Sex Offender Recidivism, Sex Offender Management Assessment and Planning Initiative (“[R]esearchers widely agree that observed recidivism rates are underestimates of the true reoffense rates of sex offenders. Hidden offending presents significant challenges for professionals working in sex offender management as it is difficult to know whether offenders who appear to be nonrecidivists based on official records are truly offense free.”) (emphasis in original).
• Mr. Epstein Or His Representatives Have Intimidated, Threatened, And/Or Made Payments To Potential Witnesses
The Government’s evidence includes: (i) Florida police reports describing harassment and intimidation of witnesses involved in the Florida state criminal investigation of Mr. Epstein in 2006, and (ii) emails, dated September 13, 2007 and September 19, 2007 (attached hereto), from Mr. Epstein’s former counsel to Federal prosecutors in Florida discussing the “option” of Mr. Epstein pleading guilty to witness tampering, harassment, and/or obstruction of justice.
A Palm Beach Police Incident Report, dated July 19, 2006, states that one of Mr. Epstein’s victims reported that Mr. Epstein’s representative said to her: “Those who help [Mr. Epstein] will be compensated and those who hurt [Mr. Epstein] will be dealt with.” Dkt. 11, Ex. 3 at 2 (emphasis added.) The Report also states: “[Mr. Epstein’s representative] assured [the
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