Epstein Secrets

ate or otherwise interact improperly with persons who turn out to be minors. A prosecution of Mr. Epstein would violate the teachings of Bailey and Panfil. As we believe we persuaded you at the June 26'h meeting, Mr. Epstein never targeted minors. On the contrary, what he did — at worst — was akin to

6 Entered on FLSD Docket 02/10/2016 Page 9 of 24 LAW OFPIcES OF GERALD B. LEFCOURT. BC. Jeffrey Matthew Esq. Andrew !Anne Es . Escl• e nite tates Attorney's Office Southern District of Florida July 6, 2007 Page 8 the mail, phone, etc., would be an unnatural and grammatically inaccurate reading of the

ngly' persuade or entice, or attempt to persuade or entice, minors. United States v. Bailey, 228 F.3d 637, 639 (6th Cir. 2000). See United States v. Panfil, 338 F.3d 1° Indeed, this last problem is best illustrated by any call may claim to have made to solicit persons to massage Mr. Epstein. Though M

RENATO C. STABILE FAITH A. FRIEDMAN BY FEDERAL EXPRESS July 6, 2007 Esq., First Assistant United States Attorney Esq., Chief, Criminal Division tates Attorney's Office Southern District of Florida 99 NE 4u' Street Miami, Florida 33132 De uty Chief, Northern Region Assistant United States Attorney e nit

ingly' persuade or entice, or attempt to persuade or entice, minors. United States v. Bailey 228 F.3d 637, 639 (6th Cir. 2000). See United States v. Panfil, 338 F.3d 10 Indeed, this last problem is best illustrated by any calls may claim to have made to solicit persons to massage Mr. Epstein. Though

the exercise of sentencing discretion, allowing the punishment to fit both the crime and the EFTA00284178 LAW orfKC• OF GERALD B. LEECOURT. PC tates Attorney's Office Southern District of Florida July 6, 2007 Page 5 perpetrator. Section 2422(b), with its ten-year mandatory minimum is far too blunt a tool