{
  "document_metadata": {
    "page_number": "18",
    "document_number": "32",
    "date": "07/18/19",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 18 of 33\n\npayments appears to be recurring or repeating during the approximately five years of bank records presently available to the Government. This course of action, and in particular its timing, suggests the defendant was attempting to further influence co-conspirators who might provide information against him in light of the recently re-emerging allegations.\" Id.\n\nA court may order detention if there is a serious risk that the defendant will attempt to threaten, injure, or intimidate a prospective witness or juror. 18 U.S.C. § 3142(f)(2)(B). Even a single incident of witness tampering has been a \"traditional ground for pretrial detention by the courts.\" LaFontaine, 210 F.3d at 132-34 (affirming then-U.S. District Judge Michael B. Mukasey's denial of bail to a defendant who had met with a prospective witness in an effort to persuade the witness to give untruthful testimony and where there was \"no evidence of influence, harassment or intimidation'); see also United States v. Singh, 2012 WL 3260232, at *3 (E.D.N.Y. Aug. 8, 2012).\n\n• Mr. Epstein Has Not Always Been Compliant With His Legal Obligations As A Registered Sex Offender\n\nDefense counsel has contended that Mr. Epstein has been \"scrupulously fulfill[ing] his obligations in every jurisdiction in which he was required to register [as a sex offender],\" since his 2008 Florida convictions. Counsel argues that this shows that he \"is no longer a danger to anyone and will faithfully obey all conditions of release if ordered.\" Dkt. 6 at 3.\n\nThe record shows that Mr. Epstein has challenged his sex offender \"level\" in at least one jurisdiction since 2008 in an effort to minimize his reporting obligations. And, one recent press account states that Epstein is not in compliance in New York State. See Elizabeth Rosner, Tina Moore, Larry Celona, and Bruce Golding, NYPD let convicted pedophile Jeffrey Epstein skip judge-ordered check-in, New York Post, July 10, 2019 (\"July 10, 2019 NY Post Article\")",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 18 of 33",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "payments appears to be recurring or repeating during the approximately five years of bank records presently available to the Government. This course of action, and in particular its timing, suggests the defendant was attempting to further influence co-conspirators who might provide information against him in light of the recently re-emerging allegations.\" Id.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "A court may order detention if there is a serious risk that the defendant will attempt to threaten, injure, or intimidate a prospective witness or juror. 18 U.S.C. § 3142(f)(2)(B). Even a single incident of witness tampering has been a \"traditional ground for pretrial detention by the courts.\" LaFontaine, 210 F.3d at 132-34 (affirming then-U.S. District Judge Michael B. Mukasey's denial of bail to a defendant who had met with a prospective witness in an effort to persuade the witness to give untruthful testimony and where there was \"no evidence of influence, harassment or intimidation'); see also United States v. Singh, 2012 WL 3260232, at *3 (E.D.N.Y. Aug. 8, 2012).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "• Mr. Epstein Has Not Always Been Compliant With His Legal Obligations As A Registered Sex Offender",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Defense counsel has contended that Mr. Epstein has been \"scrupulously fulfill[ing] his obligations in every jurisdiction in which he was required to register [as a sex offender],\" since his 2008 Florida convictions. Counsel argues that this shows that he \"is no longer a danger to anyone and will faithfully obey all conditions of release if ordered.\" Dkt. 6 at 3.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The record shows that Mr. Epstein has challenged his sex offender \"level\" in at least one jurisdiction since 2008 in an effort to minimize his reporting obligations. And, one recent press account states that Epstein is not in compliance in New York State. See Elizabeth Rosner, Tina Moore, Larry Celona, and Bruce Golding, NYPD let convicted pedophile Jeffrey Epstein skip judge-ordered check-in, New York Post, July 10, 2019 (\"July 10, 2019 NY Post Article\")",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "18",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000489",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Michael B. Mukasey",
      "Elizabeth Rosner",
      "Tina Moore",
      "Larry Celona",
      "Bruce Golding"
    ],
    "organizations": [
      "NYPD",
      "New York Post"
    ],
    "locations": [
      "New York State",
      "Florida"
    ],
    "dates": [
      "07/18/19",
      "July 10, 2019",
      "2008",
      "Aug. 8, 2012"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 32",
      "Dkt. 6",
      "18 U.S.C. § 3142(f)(2)(B)",
      "210 F.3d",
      "2012 WL 3260232"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. The text is printed and there are no visible stamps or handwritten notes. The document is page 18 of 33."
}