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Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 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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