{
  "document_metadata": {
    "page_number": "2",
    "document_number": "23",
    "date": "July 16, 2019",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 23 Filed 07/16/19 Page 2 of 3\n\nHon. Richard M. Berman\nUnited States District Judge\nJuly 16, 2019\nPage 2\nalso named as a potential co-conspirator—and for whom Epstein also obtained protection in—the NPA. This individual is also one of the employees identified in the Indictment, which alleges that she and two other identified employees facilitated the defendant’s trafficking of minors by, among other things, contacting victims and scheduling their sexual encounters with the defendant at his residences in Manhattan and Palm Beach, Florida. This individual was also named and featured prominently in the Herald series.\n\nII. Police Report\n\nDuring the Detention Hearing, the parties referenced a redacted copy of a Palm Beach police report, which was annexed to the Government’s July 12, 2019 detention memorandum. At the Court’s request, the Government has provided a supplemental copy of the police report previously filed, with information referred to in open court unredacted. The updated copy of the police report is attached as Exhibit A.\n\nIII. Foreign Passport\n\nDuring the Detention Hearing, the Government informed the Court that it had recently learned that law enforcement agents had seized what appears to be an expired foreign passport (the “Foreign Passport”) from a safe in the defendant’s Manhattan residence during the execution of a search warrant on or about July 6, 2019. The Foreign Passport has a photograph that appears to depict the defendant, but lists a different name. Photographs of that passport are annexed hereto as Exhibit B. In the same safe, agents discovered what appears to be an expired United States passport issued to the defendant, in his true name, within three years of the date on the Foreign Passport. A photograph of that United States passport is annexed hereto as Exhibit C, so that the Court may compare the passports, both of which appear to depict the defendant. Because Exhibits B and C contain personally identifiable information and sensitive information relevant to the ongoing investigation, the Government respectfully requests that Exhibits B and C be filed under seal.\n\nThe Government is attempting to obtain additional information about the Foreign Passport, including how it was obtained and whether the passport is genuine or fabricated. But the defendant’s possession of what purports to be a foreign passport issued under an alias gives rise to the inference the defendant knows how to obtain false travel documents and/or assume other, foreign identities. This adds to the serious risk of flight posed by the defendant.2\n\n2 The Government has asked defense counsel to advise whether the defendant is currently, or has been in the past, a citizen or legal permanent resident of a country other than the United States. To date, defense counsel has declined to respond. Certainly if the defendant is, or has been, a citizen or permanent resident of another country, that would add significantly to the overwhelming evidence of risk of flight.\n\nDOJ-OGR-00000441",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 23 Filed 07/16/19 Page 2 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Hon. Richard M. Berman\nUnited States District Judge\nJuly 16, 2019\nPage 2",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "also named as a potential co-conspirator—and for whom Epstein also obtained protection in—the NPA. This individual is also one of the employees identified in the Indictment, which alleges that she and two other identified employees facilitated the defendant’s trafficking of minors by, among other things, contacting victims and scheduling their sexual encounters with the defendant at his residences in Manhattan and Palm Beach, Florida. This individual was also named and featured prominently in the Herald series.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "II. Police Report",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "During the Detention Hearing, the parties referenced a redacted copy of a Palm Beach police report, which was annexed to the Government’s July 12, 2019 detention memorandum. At the Court’s request, the Government has provided a supplemental copy of the police report previously filed, with information referred to in open court unredacted. The updated copy of the police report is attached as Exhibit A.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "III. Foreign Passport",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "During the Detention Hearing, the Government informed the Court that it had recently learned that law enforcement agents had seized what appears to be an expired foreign passport (the “Foreign Passport”) from a safe in the defendant’s Manhattan residence during the execution of a search warrant on or about July 6, 2019. The Foreign Passport has a photograph that appears to depict the defendant, but lists a different name. Photographs of that passport are annexed hereto as Exhibit B. In the same safe, agents discovered what appears to be an expired United States passport issued to the defendant, in his true name, within three years of the date on the Foreign Passport. A photograph of that United States passport is annexed hereto as Exhibit C, so that the Court may compare the passports, both of which appear to depict the defendant. Because Exhibits B and C contain personally identifiable information and sensitive information relevant to the ongoing investigation, the Government respectfully requests that Exhibits B and C be filed under seal.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government is attempting to obtain additional information about the Foreign Passport, including how it was obtained and whether the passport is genuine or fabricated. But the defendant’s possession of what purports to be a foreign passport issued under an alias gives rise to the inference the defendant knows how to obtain false travel documents and/or assume other, foreign identities. This adds to the serious risk of flight posed by the defendant.2",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2 The Government has asked defense counsel to advise whether the defendant is currently, or has been in the past, a citizen or legal permanent resident of a country other than the United States. To date, defense counsel has declined to respond. Certainly if the defendant is, or has been, a citizen or permanent resident of another country, that would add significantly to the overwhelming evidence of risk of flight.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000441",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Richard M. Berman",
      "Epstein",
      "defendant"
    ],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [
      "Manhattan",
      "Palm Beach",
      "Florida",
      "United States"
    ],
    "dates": [
      "July 16, 2019",
      "July 12, 2019",
      "July 6, 2019"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 23",
      "Exhibit A",
      "Exhibit B",
      "Exhibit C",
      "DOJ-OGR-00000441"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving Jeffrey Epstein. The text is printed and there are no visible stamps or handwritten notes. The document is page 2 of a 3-page document."
}