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Cas€48£01%-60490-RMEDbeuMeRPSA Piles DH IE92grdge1F OF 33 Mr. Epstein’s future behavior will be consistent with past behavior, including the trove of “lewd photographs of young-looking women or girls,” which were recently uncovered during the July 6-7, 2019, search of Mr. Epstein’s East 71st Street mansion. See Dkt. 11, Ex. 1 at 9. The search results suggest the “possibility that defendant could target another vulnerable victim.” See United States v. Baker, 349 F. Supp. 3d 1113, 1135 (D.N.M. 2018) (where the defendant was alleged to specifically target “vulnerable women” and where he attempted to contact an alleged victim, the court was persuaded that the defendant “would be a danger to society if released”’). Despite having been convicted of the above mentioned (two) Florida sex crimes (in 2008) involving an underage girl, Mr. Epstein, as noted, maintained at his New York residence a “‘vast trove” of sexually suggestive photographs of nude underage and adult girls. Dkt. 11, Ex. 1 at 9. That is, during the July 6-7, 2019 authorized search of Mr. Epstein’s NYC residence, the FBI found a “substantial collection of photographic trophies of his victims and other young females.” Dkt. 11 at 10. This evidence includes compact discs labeled “Young [Redacted Name] + [Redacted Name],” “Misc nudes 1,” and Girl pics nude.” Id. The Government contends that this evidence includes hundreds or perhaps thousands of “sexually suggestive photographs” of nude underage girls and women, and that it is corroborative in nature. Id. And, it is consistent with victim recollections of the inside of Mr. Epstein’s residence. Dkt. 11, Ex. 1 at 9. This newly discovered evidence also suggests that Mr. Epstein poses “ongoing and forward-looking danger.” See Dkt. 11 at 10; see also Baker, 349 F. Supp. 3d at 1135; United States v. Goodwin, 2015 WL 6386568, at *3 (W.D. Ky. Oct. 21, 2015). e The § 1591 Presumption Of Pretrial Remand Reflects The Seriousness Of Mr. Epstein’s Alleged Crimes The significant harms and dangers of sex crimes involving minors “animated [] Congress to create the statutory presumption of detention.” United States v. Hardy, 2019 WL 2211210, at 12 DOJ-OGR-00000795