EFTA00184304

Case 9:08-cv-80736-KAM Document 361-8 Entered on FLSD Docket 02/10/2016

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## EXHIBIT

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EFTA00184305

Case 9:08-cv-80736-KAM Document 361-8 Entered on FLSD Docket 02/10/2016

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Hi Jay – I didn’t want us to get sidetracked during the conference call. I want to make sure that we have a factual basis for “harassment.” somewhere else is a different 1512 offense with a 10 year cap. This is the factual proffer that I drafted up earlier this afternoon, to give you an idea of what it would look like.

When I include a factual proffer in a plea agreement, I usually use prefatory language like: The parties agree that, had this case proceeded to trial, the United States would have proven the following facts beyond a reasonable doubt, and that the following facts are true and correct and are sufficient to support a plea of guilty.



Epstein Plea

Proffer.doc

A.

Assistant U.S. Attorney

90 S. Australian Ave, Suite 400

West Palm Beach, FL 33401

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RFP MIA 000129