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780 KB

Extraction Summary

2
People
4
Organizations
3
Locations
2
Events
1
Relationships
6
Quotes

Document Information

Type: Legal filing / court memorandum (government's argument for detention)
File Size: 780 KB
Summary

This document is page 12 of a government legal filing from July 18, 2019, arguing for the pretrial detention of Jeffrey Epstein. It details evidence found during a July 6-7, 2019 FBI search of Epstein's NYC mansion, specifically a 'vast trove' of CD's containing thousands of nude photographs of underage girls and women, which the government labels as 'photographic trophies.' The prosecution argues this evidence, along with his 2008 conviction, demonstrates that Epstein poses an ongoing danger to the community.

People (2)

Name Role Context
Jeffrey Epstein Defendant
Subject of the detention hearing; accused of maintaining a trove of lewd photographs and posing a danger to society.
[Redacted Name] Victims/Subjects
Names appearing on labels of compact discs containing nude photographs found in Epstein's residence.

Organizations (4)

Name Type Context
FBI
Conducted the authorized search of Epstein's NYC residence on July 6-7, 2019.
United States Government
The prosecution (Plaintiff); contends the evidence includes thousands of sexually suggestive photographs.
Congress
Mentioned in the context of creating statutory presumption of detention for sex crimes.
Department of Justice (DOJ)
Indicated by the footer 'DOJ-OGR'.

Timeline (2 events)

2008-01-01
Epstein convicted of two Florida sex crimes involving an underage girl.
Florida
2019-07-06
Authorized search of Mr. Epstein’s East 71st Street mansion/NYC residence by the FBI.
New York, NY

Locations (3)

Location Context
Mr. Epstein's NYC residence where the search occurred.
Location of the residence containing the photographic evidence.
Location of Epstein's 2008 sex crime convictions.

Relationships (1)

Jeffrey Epstein Predatory Vulnerable Victims
Court filing states defendant could target another vulnerable victim and maintained photographic trophies of victims.

Key Quotes (6)

"Mr. Epstein’s future behavior will be consistent with past behavior, including the trove of “lewd photographs of young-looking women or girls,” which were recently uncovered"
Source
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Quote #1
"The search results suggest the “possibility that defendant could target another vulnerable victim.”"
Source
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Quote #2
"the FBI found a “substantial collection of photographic trophies of his victims and other young females.”"
Source
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Quote #3
"This evidence includes compact discs labeled “Young [Redacted Name] + [Redacted Name],” “Misc nudes 1,” and “Girl pics nude.”"
Source
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Quote #4
"The Government contends that this evidence includes hundreds or perhaps thousands of “sexually suggestive photographs” of nude underage girls and women"
Source
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Quote #5
"This newly discovered evidence also suggests that Mr. Epstein poses “ongoing and forward-looking danger.”"
Source
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Quote #6

Full Extracted Text

Complete text extracted from the document (2,199 characters)

Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 12 of 33
Mr. Epstein’s future behavior will be consistent with past behavior, including the trove of “lewd photographs of young-looking women or girls,” which were recently uncovered during the July 6-7, 2019, search of Mr. Epstein’s East 71st Street mansion. See Dkt. 11, Ex. 1 at 9. The search results suggest the “possibility that defendant could target another vulnerable victim.” See United States v. Baker, 349 F. Supp. 3d 1113, 1135 (D.N.M. 2018) (where the defendant was alleged to specifically target “vulnerable women” and where he attempted to contact an alleged victim, the court was persuaded that the defendant “would be a danger to society if released”).
Despite having been convicted of the above mentioned (two) Florida sex crimes (in 2008) involving an underage girl, Mr. Epstein, as noted, maintained at his New York residence a “vast trove” of sexually suggestive photographs of nude underage and adult girls. Dkt. 11, Ex. 1 at 9. That is, during the July 6-7, 2019 authorized search of Mr. Epstein’s NYC residence, the FBI found a “substantial collection of photographic trophies of his victims and other young females.” Dkt. 11 at 10. This evidence includes compact discs labeled “Young [Redacted Name] + [Redacted Name],” “Misc nudes 1,” and “Girl pics nude.” Id. The Government contends that this evidence includes hundreds or perhaps thousands of “sexually suggestive photographs” of nude underage girls and women, and that it is corroborative in nature. Id. And, it is consistent with victim recollections of the inside of Mr. Epstein’s residence. Dkt. 11, Ex. 1 at 9. This newly discovered evidence also suggests that Mr. Epstein poses “ongoing and forward-looking danger.” See Dkt. 11 at 10; see also Baker, 349 F. Supp. 3d at 1135; United States v. Goodwin, 2015 WL 6386568, at *3 (W.D. Ky. Oct. 21, 2015).
• The § 1591 Presumption Of Pretrial Remand Reflects The Seriousness Of Mr. Epstein’s Alleged Crimes
The significant harms and dangers of sex crimes involving minors “animated [] Congress to create the statutory presumption of detention.” United States v. Hardy, 2019 WL 2211210, at
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