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Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page6of9 Hon. Richard M. Berman July 16, 2019 Page 6 appropriate New Mexico official, Detective Deborah Anaya, when he spent any time at his ranch there. (The underlying documents are available upon request.) Sixth, though some studies may well indicate that sex offender recidivism rates “actually go[] up at 15 years,” as Your Honor suggested from the bench,5 others reach the opposite conclusion. For example, a respected study found that the relapse risk drops substantially the longer a person remains sex-offense free in the community. 6 Another determined that it’s mistaken to think of anyone who’s been offense-free for 15 years as high-risk.7 Seventh, to the extent third-party counsel (Mr. Boies) speculated that the alleged November 28 and December 3, 2018 payments8 were 5 7/15/19 Tr. 34. 6 Hanson et al., “High-Risk Sex Offenders May Not Be High Risk Forever,” Journal of Interpersonal Violence (March 2014), https://www.researchgate.net/publication/261069441_ High- Risk Sex Offenders May Not Be High Risk Forever. 7 Ira Mark & Tara Ellman, “Frightening and High’: The Supreme Court’s Crucial Mistake About Sex Crime Statistics” (2015). Constitutional Commentary. 419. https://scholarship.law.umn.edu/concomm/419. 8 7/12/19 Ltr. 11. DOJ-OGR-00000436