{
  "document_metadata": {
    "page_number": "1",
    "document_number": "23",
    "date": "07/16/19",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 23 Filed 07/16/19 Page 1 of 3 U.S Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 July 16, 2019 VIA ECF REQUEST TO FILE PARTIALLY UNDER SEAL The Honorable Richard M. Berman United States District Judge Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter to provide the Court with additional information in response to the Court's questions at the detention hearing held on July 15, 2019 (the \"Detention Hearing\"). I. Payments to Potential Witnesses In a July 12, 2019 letter, the Government informed the Court that the Government had recently obtained records from a financial institution (\"Institution-1\") that appeared to show the defendant had made suspicious payments shortly after the Miami Herald began publishing, on approximately November 28, 2018, a series of articles relating to the defendant, his alleged sexual misconduct, and the circumstances under which he entered into a non-prosecution agreement (\"NPA\") with the U.S. Attorney's Office for the Southern District of Florida in 2007. The same series highlighted the involvement of several of Epstein's former employees and associates in the alleged sexual abuse. At the Detention Hearing, the Court asked the Government to provide additional information about the individuals to whom these payments appear to have been made. First, records from Institution-1 show that on or about November 30, 2018, or two days after the series in the Miami Herald began, the defendant wired $100,000 from a trust account he controlled to [REDACTED], an individual named as a potential co-conspirator—and for whom Epstein obtained protection in—the NPA. This individual was also named and featured prominently in the Herald series. Second, the same records show that just three days later, on or about December 3, 2018, the defendant wired $250,000 from the same trust account to [REDACTED], who was 1 For the reasons set forth at the Detention Hearing, and with the consent of the Court, the Government is redacting the identities of these individuals in the publicly filed version of this letter. DOJ-OGR-00000440",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 23 Filed 07/16/19 Page 1 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 July 16, 2019",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "VIA ECF REQUEST TO FILE PARTIALLY UNDER SEAL",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Honorable Richard M. Berman United States District Judge Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Berman: The Government respectfully submits this letter to provide the Court with additional information in response to the Court's questions at the detention hearing held on July 15, 2019 (the \"Detention Hearing\").",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "I. Payments to Potential Witnesses In a July 12, 2019 letter, the Government informed the Court that the Government had recently obtained records from a financial institution (\"Institution-1\") that appeared to show the defendant had made suspicious payments shortly after the Miami Herald began publishing, on approximately November 28, 2018, a series of articles relating to the defendant, his alleged sexual misconduct, and the circumstances under which he entered into a non-prosecution agreement (\"NPA\") with the U.S. Attorney's Office for the Southern District of Florida in 2007.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The same series highlighted the involvement of several of Epstein's former employees and associates in the alleged sexual abuse. At the Detention Hearing, the Court asked the Government to provide additional information about the individuals to whom these payments appear to have been made.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "First, records from Institution-1 show that on or about November 30, 2018, or two days after the series in the Miami Herald began, the defendant wired $100,000 from a trust account he controlled to [REDACTED], an individual named as a potential co-conspirator—and for whom Epstein obtained protection in—the NPA. This individual was also named and featured prominently in the Herald series.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Second, the same records show that just three days later, on or about December 3, 2018, the defendant wired $250,000 from the same trust account to [REDACTED], who was",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 For the reasons set forth at the Detention Hearing, and with the consent of the Court, the Government is redacting the identities of these individuals in the publicly filed version of this letter.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000440",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Richard M. Berman",
      "Jeffrey Epstein"
    ],
    "organizations": [
      "U.S Department of Justice",
      "United States Attorney",
      "Southern District of New York",
      "Miami Herald",
      "U.S. Attorney's Office for the Southern District of Florida"
    ],
    "locations": [
      "New York",
      "Florida"
    ],
    "dates": [
      "July 16, 2019",
      "July 15, 2019",
      "July 12, 2019",
      "November 28, 2018",
      "November 30, 2018",
      "December 3, 2018",
      "2007"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "19 Cr. 490 (RMB)",
      "DOJ-OGR-00000440"
    ]
  },
  "additional_notes": "The document is a letter from the U.S. Department of Justice to Judge Richard M. Berman regarding the case United States v. Jeffrey Epstein. The letter discusses payments made by Epstein to potential witnesses and includes redactions to protect the identities of certain individuals."
}