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Document Case 1:19-cr-00290-RMB Document 32 Filed 07/18/19 Page 14 of 33

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reasonably assure . . . the safety of the community” if Mr. Epstein is released. Pretrial Services Report, dated July 8, 2019, at 4. Pretrial Services also concluded that Mr. Epstein is a flight risk and recommends that he be detained for that reason as well. Id. In support of its assessment of Mr. Epstein’s dangerousness, Pretrial Services cites the following: the “Nature of [Mr. Epstein’s currently charged] Instant Offence,” i.e., sex trafficking and conspiracy involving minor girls; Mr. Epstein’s “Prior Arrests,” e.g., in Florida in 2006; Mr. Epstein’s “History [and] Conviction Involving [a] Sex [Offense],” which principally refers to Defendant’s 2008 conviction(s) for procuring a person under the age of 18 for prostitution (a felony) and for solicitation of prostitution (also a felony); Mr. Epstein’s status as a registered sex offender in New York, Florida and the Virgin Islands; and Mr. Epstein’s “Pattern of Similar Criminal Activity History.” Id. The Seriousness Of The Crimes That Mr. Epstein Has Been Charged With Is Also Reflected In The Fact That The Crimes Involve Minor Children Mr. Epstein is said by the Government to be “a serial sexual predator” who allegedly victimized dozens (or more) of minor girls, including a 14 year old.1 He was involved in and undertook the alleged sexual activity in several locations, including, his mansion in Manhattan and his estate in Palm Beach, Florida. Indictment ¶ 2. By “actively encourage[ing] certain of his [minor] victims to recruit additional girls to be similarly sexually abused,” Mr. Epstein is said to have “created a vast network of underage victims for him to exploit.” Dkt. 11, Ex. 1 at 2. The Government alleges that Mr. Epstein “intentionally sought out—and knew that he was abusing—minors. Indeed, in some instances, his victims expressly told him they were 1 Mr. Epstein is reported to have remarked that: “I’m not a ‘sexual predator,’ I’m an ‘offender’ . . . It’s the difference between a murderer and a person who steals a bagel.” Amber Southerland, Billionaire Jeffrey Epstein: I’m a sex offender, not a predator, New York Post, Feb. 25, 2011. 14 DOJ-OGR-00000797