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Case 18-cr-00290-RMB Document 82 Filed 07/18/18 Page 16 of 33
victim that] she would receive monetary compensation for her assistance in not cooperating with law enforcement." Id. Another (undated) Palm Beach Police Incident Report states that the parent of one of Mr. Epstein's alleged victims contacted the Palm Beach Police to report that Mr. Epstein's private investigator had aggressively driven the parent's car off the road. Dkt. 11, Ex. 2 at 1. This same Report states that the parent of another victim reported being "followed aggressively" by Mr. Epstein's private investigator. Id.
The Government contends that these reports together "suggest that an associate of Epstein's was offering to buy victims' silence during the course of the prior investigation," and demonstrate Mr. Epstein's "willingness to use intimidation and aggressive tactics in connection with a criminal investigation." Dkt. 11 at 11.
The Government also submits e-mail evidence (attached to this Order as Exhibit 1) of plea discussions in 2007 between Florida federal prosecutors and Mr. Epstein's attorneys that confirm that Mr. Epstein considered pleading guilty to witness tampering, harassment and/or obstruction of justice in a case involving alleged sex crimes with minor girls. On September 13, 2007, prosecutors wrote to Mr. Epstein's counsel that they have been "spending some quality time . . . looking for misdemeanors [that Mr. Epstein could plead guilty to]," including 18 U.S.C. § 1512(d), a Federal witness tampering statute (a felony) and 18 U.S.C. § 403, a Federal statute criminalizing the violation of the privacy protection of child victims and child witnesses (a misdemeanor). Doe v. United States, 08 Civ. 80756, (S.D. Fla.), Dkt. 361-11. Epstein's counsel replied: "Already thinking about the same statutes." Id. On September 18, 2007, a Federal prosecutor told Mr. Epstein's counsel that if Mr. Epstein pled guilty to obstruction of justice, the factual proffer "could rely on the incident where Mr. Epstein's private investigators followed [a victim's] father, forcing [him] off the road." Id., Dkt. 361-10; see also supra p. 15. On September
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