202. Defendants also actively obstructed law enforcement by denying investigators
     access to Little St. James beyond its boat dock.

203. Defendants also attempted to conceal their criminal sex trafficking and abuse
     conduct by paying large sums of money to participant-witnesses, including by paying for their
     attorneys’ fees and case costs in litigation related to this conduct.

204. Epstein also threatened harm to victims and helped release damaging stories
     about them to damage their credibility when they tried to go public with their stories of being
     trafficked and sexually abused.

205. Epstein also instructed one or more Epstein Enterprise participant-witnesses to
     destroy evidence relevant to ongoing court proceedings involving Defendants’ criminal sex
     trafficking and abuse conduct.

206. Defendants also concealed their fraud on the Government in obtaining unearned
     tax benefits by providing false testimony and submitting false and inaccurate reporting to the
     Economic Development Commission to prevent detection of Defendant Southern Trust
     Company’s non-compliance with requirements concerning the nature of its business and the
     residency of the persons it employed.

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