Thanks for coordinating with them—and this summary looks great to me.¶
I spoke with =. Bottom line, she thinks it’s a close call between making take a felony plea and declining to prosecute, but she ultimately comes down in favor of a felony plea. She does not think we should charge with sex trafficking.¶
I= asked me to send her and I= a draft of the summary of their views that we plan to send up to the brass. Below is what I’d propose:¶
Our Office’s Human Trafficking Coordinators have reviewed the prosecution team’s Update Memo as well as submission, and are aware of the details of the Epstein investigation. In the Coordinators’ experience, our Office ordinarily would decline to prosecute a victim-participant like absent certain aggravating factors, such as the use of violence by the victim-participant on others, or the victim-perpetrator continuing to run a sex trafficking operation in the absence of her abuser. Because those aggravating factors are not present here, the Coordinators believe it is a very close call between declining to prosecute and requiring to enter a felony plea. Ultimately, though, the Coordinators support a felony plea disposition along the lines set forth in submission given the unique circumstances of her case. In particular, the Coordinators believe that the large number of underage victims, together with obstructive conduct, warrant a felony plea. The Coordinators support such a disposition, in part, because a plea will allow victims to gain a sense of closure and to have their voices heard at sentencing if they choose. Given the mitigating factors presented in submission—most notably the sexual abuse she suffered at Epstein’s hands—the Coordinators do not believe that our Office should charge with sex trafficking.¶
What do you think?¶
| Cc: Subject: Re: memo |
|---|
| I have a call tentatively scheduled with has not confirmed whether she’s joining. tomorrow afternoon. |
| On Apr 6, 2020, at 10:42 PM, wrote: |
| and/or =? comments ask about that specifically so wanted to check. Have we heard anything from |
| Assistant U.S. Attorney |
Southern District of New York¶