court filing: Case 18-cr-390 (RMB) Document 82 Filed 07/18/19 Page 12 of 33

The document discusses the government's argument for pretrial detention of Jeffrey Epstein, citing new evidence found during a search of his New York residence, including a large collection of sexually suggestive photographs of nude underage girls and women. This evidence is used to argue that Epstein poses an ongoing danger to society and is consistent with his past behavior. The government relies on this evidence and statutory presumptions to support its request for pretrial detention.