{
  "document_metadata": {
    "page_number": "9",
    "document_number": "11-1",
    "date": "07/12/19",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 9 of 10\n\nHonorable Henry Pitman\nUnited States Magistrate Judge\nJuly 8, 2019\nPage 9\nharassed both [redacted] in connection to this attempt to delay their voluntary receipt of process all in violation of 18 USC 1512(d)(1).\"5 Doe v. United States, 08 Civ. 80736 (S.D. Fla.), Dkts. 361 at 3-4, 361-7 through 361-11. In addition to 18 U.S.C. § 1512(d), prosecutors also proposed that the defendant could plead guilty to 18 U.S.C. § 403, that is, a knowing or intentional violation of the privacy protection of child victims and child witnesses, to which the defendant's then-counsel replied: \"Already thinking about the same statutes.\" Id. Dkt. 361-11. They also discussed a possible obstruction plea that \"could rely on the incident where Mr. Epstein's private investigators followed [redacted] father, forcing off the road.\" Id. Dkt. 361-10.\n\nThe defendant's apparent previous willingness to obstruct a federal investigation, harass or tamper with witnesses, and hire private investigators that \"forc[ed] off the road\" the father of an individual relevant in the investigation is alarming. It should especially weigh on the Court's consideration here because the defendant was apparently willing to take those steps before even being charged and thus facing federal indictment; the incentive to interfere in the Government's case here, where an Indictment has been returned, is exponentially greater. And as discussed above, the defendant has nearly limitless means to do so.\n\nFinally, despite having been previously convicted of a sex offense involving an underage victim, the defendant has continued to maintain a vast trove of lewd photographs of young-looking women or girls in his Manhattan mansion. In a search of the New York Residence on the night of his arrest, on July 6, 2019, pursuant to judicially-authorized warrants, law enforcement officers discovered not only specific evidence consistent with victim recollections of the inside of the mansion, further strengthening the evidence of the conduct charged in the Indictment, but also at least hundreds—and perhaps thousands—of sexually suggestive photographs of fully- or partially-nude females. While these items were only seized this weekend and are still being reviewed, some of the nude or partially-nude photographs appear to be of underage girls, including at least one girl who, according to her counsel, was underage at the time the relevant photographs were taken. Additionally, some of the photographs referenced herein were discovered in a locked safe, in which law enforcement officers also found compact discs with hand-written labels including the following: \"Young [Name] + [Name],\" \"Misc nudes 1,\" and \"Girl pics nude.\" The defendant, a registered sex offender, is not reformed, he is not chastened, he is not repentant;6 rather, he is a continuing danger to the community and an individual who faces devastating evidence supporting deeply serious charges.\n\n5 The redactions above are contained in the publicly filed version of the quoted document.\n6 See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I’m a sex offender, not a predator, N.Y. Post (2011) (\"'I’m not a sexual predator, I’m an \"offender,\" the financier told The Post yesterday. 'It's the difference between a murderer and a person who steals a bagel.'\"); Philip Weiss, The Fantasist, New York Magazine (2007) (\"'It's the Icarus story, someone who flies too close to the sun,' I said. 'Did Icarus like massages?' Epstein asked.\")\n\nDOJ-OGR-00000351",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 9 of 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Honorable Henry Pitman\nUnited States Magistrate Judge\nJuly 8, 2019\nPage 9",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "harassed both [redacted] in connection to this attempt to delay their voluntary receipt of process all in violation of 18 USC 1512(d)(1).\"5 Doe v. United States, 08 Civ. 80736 (S.D. Fla.), Dkts. 361 at 3-4, 361-7 through 361-11. In addition to 18 U.S.C. § 1512(d), prosecutors also proposed that the defendant could plead guilty to 18 U.S.C. § 403, that is, a knowing or intentional violation of the privacy protection of child victims and child witnesses, to which the defendant's then-counsel replied: \"Already thinking about the same statutes.\" Id. Dkt. 361-11. They also discussed a possible obstruction plea that \"could rely on the incident where Mr. Epstein's private investigators followed [redacted] father, forcing off the road.\" Id. Dkt. 361-10.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defendant's apparent previous willingness to obstruct a federal investigation, harass or tamper with witnesses, and hire private investigators that \"forc[ed] off the road\" the father of an individual relevant in the investigation is alarming. It should especially weigh on the Court's consideration here because the defendant was apparently willing to take those steps before even being charged and thus facing federal indictment; the incentive to interfere in the Government's case here, where an Indictment has been returned, is exponentially greater. And as discussed above, the defendant has nearly limitless means to do so.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Finally, despite having been previously convicted of a sex offense involving an underage victim, the defendant has continued to maintain a vast trove of lewd photographs of young-looking women or girls in his Manhattan mansion. In a search of the New York Residence on the night of his arrest, on July 6, 2019, pursuant to judicially-authorized warrants, law enforcement officers discovered not only specific evidence consistent with victim recollections of the inside of the mansion, further strengthening the evidence of the conduct charged in the Indictment, but also at least hundreds—and perhaps thousands—of sexually suggestive photographs of fully- or partially-nude females. While these items were only seized this weekend and are still being reviewed, some of the nude or partially-nude photographs appear to be of underage girls, including at least one girl who, according to her counsel, was underage at the time the relevant photographs were taken. Additionally, some of the photographs referenced herein were discovered in a locked safe, in which law enforcement officers also found compact discs with hand-written labels including the following: \"Young [Name] + [Name],\" \"Misc nudes 1,\" and \"Girl pics nude.\" The defendant, a registered sex offender, is not reformed, he is not chastened, he is not repentant;6 rather, he is a continuing danger to the community and an individual who faces devastating evidence supporting deeply serious charges.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "5 The redactions above are contained in the publicly filed version of the quoted document.\n6 See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I’m a sex offender, not a predator, N.Y. Post (2011) (\"'I’m not a sexual predator, I’m an \"offender,\" the financier told The Post yesterday. 'It's the difference between a murderer and a person who steals a bagel.'\"); Philip Weiss, The Fantasist, New York Magazine (2007) (\"'It's the Icarus story, someone who flies too close to the sun,' I said. 'Did Icarus like massages?' Epstein asked.\")",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000351",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Henry Pitman",
      "Jeffrey Epstein",
      "Amber Southerland",
      "Philip Weiss"
    ],
    "organizations": [
      "United States Magistrate Judge",
      "N.Y. Post",
      "New York Magazine"
    ],
    "locations": [
      "Florida",
      "Manhattan",
      "New York"
    ],
    "dates": [
      "July 8, 2019",
      "July 6, 2019",
      "2011",
      "2007",
      "07/12/19"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 11-1",
      "08 Civ. 80736",
      "Dkts. 361",
      "Dkt. 361-11",
      "Dkt. 361-10",
      "DOJ-OGR-00000351"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. It includes references to legal statutes, court documents, and news articles. The text is mostly printed, with no visible handwriting or stamps. The document is page 9 of a 10-page document."
}