{
  "document_metadata": {
    "page_number": "15",
    "document_number": "Case 18-20190-RMB Document 82 Filed 07/23/201 Page 15 of 33",
    "date": null,
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "underage before or during the period in which he abused them.\" Id. The crimes with which Mr. Epstein is charged carry a maximum sentence of 45 years of incarceration. Id. at 5. \"[T]he deprivation of liberty imposed by imprisonment makes that penalty the best indicator of whether the legislature considered an offense to be . . . 'serious.'\" United States v. Dugan, 667 F.3d 84, 86 (2d Cir. 2011) (quoting Lewis v. United States, 518 U.S. 322, 326 (1996)). And, the crimes Mr. Epstein has been charged with are among the most heinous in the law principally, in the Court's view, because they involve minor girls. 18 U.S.C. § 3142 (e)(3)(E); see also Roger Przybylski, Chapter 5: Adult Sex Offender Recidivism, Sex Offender Management Assessment and Planning Initiative (\"[R]esearchers widely agree that observed recidivism rates are underestimates of the true reoffense rates of sex offenders. Hidden offending presents significant challenges for professionals working in sex offender management as it is difficult to know whether offenders who appear to be nonrecidivists based on official records are truly offense free.\") (emphasis in original). Mr. Epstein Or His Representatives Have Intimidated, Threatened, And/Or Made Payments To Potential Witnesses The Government's evidence includes: (i) Florida police reports describing harassment and intimidation of witnesses involved in the Florida state criminal investigation of Mr. Epstein in 2006, and (ii) emails, dated September 13, 2007 and September 19, 2007 (attached hereto), from Mr. Epstein's former counsel to Federal prosecutors in Florida discussing the \"option\" of Mr. Epstein pleading guilty to witness tampering, harassment, and/or obstruction of justice. A Palm Beach Police Incident Report, dated July 19, 2006, states that one of Mr. Epstein's victims reported that Mr. Epstein's representative said to her: \"Those who help [Mr. Epstein] will be compensated and those who hurt [Mr. Epstein] will be dealt with.\" Dkt. 11, Ex. 3 at 2 (emphasis added.) The Report also states: \"[Mr. Epstein's representative] assured [the 15 DOJ-OGR-00000798",
  "text_blocks": [
    {
      "type": "printed",
      "content": "underage before or during the period in which he abused them.\" Id. The crimes with which Mr. Epstein is charged carry a maximum sentence of 45 years of incarceration. Id. at 5. \"[T]he deprivation of liberty imposed by imprisonment makes that penalty the best indicator of whether the legislature considered an offense to be . . . 'serious.'\" United States v. Dugan, 667 F.3d 84, 86 (2d Cir. 2011) (quoting Lewis v. United States, 518 U.S. 322, 326 (1996)).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "And, the crimes Mr. Epstein has been charged with are among the most heinous in the law principally, in the Court's view, because they involve minor girls. 18 U.S.C. § 3142 (e)(3)(E); see also Roger Przybylski, Chapter 5: Adult Sex Offender Recidivism, Sex Offender Management Assessment and Planning Initiative (\"[R]esearchers widely agree that observed recidivism rates are underestimates of the true reoffense rates of sex offenders. Hidden offending presents significant challenges for professionals working in sex offender management as it is difficult to know whether offenders who appear to be nonrecidivists based on official records are truly offense free.\") (emphasis in original).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Mr. Epstein Or His Representatives Have Intimidated, Threatened, And/Or Made Payments To Potential Witnesses The Government's evidence includes: (i) Florida police reports describing harassment and intimidation of witnesses involved in the Florida state criminal investigation of Mr. Epstein in 2006, and (ii) emails, dated September 13, 2007 and September 19, 2007 (attached hereto), from Mr. Epstein's former counsel to Federal prosecutors in Florida discussing the \"option\" of Mr. Epstein pleading guilty to witness tampering, harassment, and/or obstruction of justice.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A Palm Beach Police Incident Report, dated July 19, 2006, states that one of Mr. Epstein's victims reported that Mr. Epstein's representative said to her: \"Those who help [Mr. Epstein] will be compensated and those who hurt [Mr. Epstein] will be dealt with.\" Dkt. 11, Ex. 3 at 2 (emphasis added.) The Report also states: \"[Mr. Epstein's representative] assured [the",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "15",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000798",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mr. Epstein",
      "Roger Przybylski"
    ],
    "organizations": [],
    "locations": [
      "Florida",
      "Palm Beach"
    ],
    "dates": [
      "July 19, 2006",
      "September 13, 2007",
      "September 19, 2007"
    ],
    "reference_numbers": [
      "Case 18-20190-RMB",
      "Dkt. 11",
      "Ex. 3 at 2",
      "DOJ-OGR-00000798"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Mr. Epstein, discussing his charges and potential witnesses. The text is mostly printed, with some emphasis in original. There are no visible stamps or handwritten text."
}