Hi – Just talked with I am sure that he communicated these thoughts, but I wanted to mention a couple of things that I hoped to talk to you about.
There are two things that I think might be tricks up the sleeves of the defense. First, had mentioned in our Miami meeting with all the defense attorneys that Epstein would be willing to do a split sentence of community control followed by jail time because, in the state system, if you complete community control without a violation, the jail time is converted to probation or more community control. Second, it wasn’t clear that Epstein would be pleading to a child sex offense that involves sex offender registration. Third, I mentioned to that the revised indictment references 19 victims, so 15 months is less than 1 month per victim. I agree that this is a reasonable counteroffer in light of our starting position of 24 months, but this is a really low sentence.
So, whatever the U.S. Attorney decides to do, can we please follow with a version of my written non-prosecution agreement? That will allow us to avoid any state shenanigans and will keep the defense on a strict timeline.
Before this counter-offer, I was going to propose that we include in our response to Messrs. Starr and Lefkowitz one page of the draft overt acts section. I have attached the proposed overt acts related to two of the girls, as an example.
Overt acts insert.wpd
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone:
Fax 561 820-8777
Tracking:
3237
08-80736-CV-MARRA
P-014062
EFTA00189115
## (USAFLS)
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| (USAFLS) Tuesday, September 11, 2007 5:01 PM | |
| (USAFLS) RE: Revised Agreement re Epstein | |
Hi -- I will try to get back as soon as possible. I j long I will be at the hospital. Is it just us three or is attending? What should I be prepared to discuss?
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax 561 820-8777
Subject: Re: Revised Agreement re Epstein
Good. Barry leaves early for jewish holidays any chance u can make 130
Sent from my BlackBerry Wireless Handheld
Subject: RE: Revised Agreement re Epstein
Plead to the three specified charges, a 30 month sentence, split 20 in jail and 10 in "community control," and agree that the girls are victims for purposes of damages. We also put in deadlines for a plea and sentencing date.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone [hidden]
Fax 561 820-8777
-----Original Message-----
Sent: Tuesday, September 11, 2007 2:17 PM
08-80736-CV-MARRA
P-014063