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Case 1:19-cr-00490-RMB Document 32 _ Filed 07/18/19 Page 17 of 33 19, 2007, Mr. Epstein’s counsel proposed that Mr. Epstein admit that he verbally harassed victims or the family of victims in connection with his “attempt to delay their voluntary receipt of process” in a civil action against Mr. Epstein, in violation of a Federal witness tampering statute. Doe, Dkt. 361-9. And, the Government has recently contended that, on November 28, 2018 and on December 3, 2018 — very soon after the publication of a 3-part investigative report in the Miami Herald (authored by Julie K. Brown) relating to Mr. Epstein’s Florida Non-Prosecution Agreement, dated September 24, 2007 — Mr. Epstein paid $100,000 to “‘a company founded and run by [Individual I],” and he paid $250,000 to [Individual II]. Dkt. 23 at 1. The Government states that Individual I was “a potential co-conspirator—[] for whom Epstein obtained protection in [] the NPA.” Id. Individual I was named and featured prominently in the Miami Herald. See, e.g., Julie K. Brown, “Even From Jail, Sex Abuser Manipulated The System. His Victims Were Kept in The Dark, Miami Herald, Nov. 28, 2018. The Government states that Individual II was also “a potential co-conspirator—{] for whom Epstein also obtained protection in [] the NPA.” Dkt. 23 at 2. She is “one of the employees identified in the Indictment, which alleges that she and two other identified employees facilitated the defendant’s trafficking of minors by, among other things, contacting victims and scheduling their sexual encounters with the defendant at his residences in Manhattan and Palm Beach, Florida.” Id. at 2. Individual II was also named and featured prominently in the Miami Herald report. The Government states there is good reason to infer that Mr. Epstein was attempting to “influence [these two] individuals who were close to him during the time period charged in this case and who might be witnesses against him at a trial.” Dkt. 11 at 11. “Neither of these 17 DOJ-OGR-00000488