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Document Case 1:19-cr-00290-RMB Document 82 Filed 07/23/19 Page 11 of 33

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Case 1:19-cr-00290-RMB Document 82 Filed 07/23/19 Page 11 of 33 Epstein victims would “continu[e] to be victimized” and that Mr. Epstein’s wealth and privilege and notoriety would make it difficult for “[other] victims to come forward.” Id. at 72. Ms. Courtney Wild was introduced by her counsel, Brad Edwards, and said she was “sexually abused by Jeffrey Epstein starting at the age of 14.” Id. at 73-74. She asked the Court to “keep [Mr. Epstein] in detention [] for the safety of any other girls out there that are going through what [she’s] going through.” Id. at 74. Ms. Wild said that Mr. Epstein is a “scary person to have walking the streets.” Id. • Mr. Epstein Poses A Threat to Additional Young Girls If He Is Released At the remand/release hearing on Monday, July 15, 2019, as noted, the Court heard poignant testimony from two of Mr. Epstein’s alleged victims about their fears and anxiety over his potential release, even if under strict conditions of home confinement. The Court is also concerned for new victims. Mr. Epstein’s alleged excessive attraction to sexual conduct with or in the presence of minor girls – which is said to include his soliciting and receiving massages from young girls and young women perhaps as many as four times a day – appears likely to be uncontrollable. See United States v. Minnici, 128 F. App’x 827, 829–30 (2d Cir. 2005) (defendant’s alleged sex crimes were “of an addictive sexual nature that cannot be suppressed simply by a restrictive set of bail conditions”). Accordingly, Mr. Epstein’s past sexual conduct is not likely to have abated or been successfully suppressed by fierce determination, as his Defense Counsel suggests. Defense Counsel contends that: “[H]e wasn’t a predator that couldn’t control his conduct. He disciplined himself.” 7/15/19 Tr. at 31-32. Defense Counsel also argues that “appreciating the gravity of these charges . . . putting aside the age of these witnesses and putting the consent issue aside, it’s not like [Epstein is] an out-of-control rapist.” 7/15/19 Tr. at 36. It seems fair to say that 11 DOJ-OGR-00000794