Epstein Secrets

month rule proffered by the BOP related to the supposed optimum time in a halfway house. In fact, the evidence presented in the case in which Judge Marsh invalidated the earlier regulation established that the six-month norm was based on erroneous assumptions. Most glaringly, the evidence disclosed t

fails to address a critical question that Congress determined should be addressed by fair and neutral rule-making, not by administrative fiat. 1601 Flab Anne, Room 700, Seattle, Waslalostoa 00101 - Menotti (206) S53-1100 Fax (206) 513-0120 56 of 61 EFTA00100226 Thomas R. Kane November 16, 2011 Page 3

month rule proffered by the BOP related to the supposed optimum time in a halfway house. In fact, the evidence presented in the case in which Judge Marsh invalidated the earlier regulation established that the six-month norm was based on erroneous assumptions. Most glaringly, the evidence disclosed t

fails to address a critical question that Congress determined should be addressed by fair and neutral rule-making, not by administrative fiat. 1601 Flab Anne, Room 700, Seattle, Waslalostoa 00101 - Menotti (206) S53-1100 Fax (206) 513-0120 56 of 61 EFTA00064963 Thomas R. Kane November 16, 2011 Page 3

month rule proffered by the BOP related to the supposed optimum time in a halfway house. In fact, the evidence presented in the case in which Judge Marsh invalidated the earlier regulation established that the six-month norm was based on erroneous assumptions. Most glaringly, the evidence disclosed t

fails to address a critical question that Congress determined should be addressed by fair and neutral rule-making, not by administrative fiat. 1601 Flab Anne, Room 700, Seattle, Waslalostoa 00101 - Menotti (206) S53-1100 Fax (206) 513-0120 56 of 61 EFTA00094081 Thomas R. Kane November 16, 2011 Page 3