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Tara Ellman

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This document is page 6 of a legal filing dated July 16, 2019, addressed to Judge Richard M. Berman. The author asserts that Epstein consistently notified New Mexico official Detective Deborah Anaya of his presence at his residence there. The filing also counters a point made by the judge, arguing against the idea that sex offender recidivism rates increase after 15 years by citing studies suggesting the risk of relapse substantially drops over time for offense-free individuals.

Legal document
2025-11-20
Analysis Source

DOJ-OGR-00000436.jpg

This document is page 6 of a legal filing dated July 16, 2019, addressed to Judge Richard M. Berman. The author refutes the judge's suggestion that sex offender recidivism rates increase after 15 years, citing two studies that conclude the opposite. The document also mentions a New Mexico detective, Deborah Anaya, and speculation by a third-party counsel, Mr. Boies, regarding alleged payments in late 2018.

Legal document
2025-11-20
Analysis Source
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