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he discussion at pp 10-21 is 27 EFTA00039409 Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 28 of 33 incorporated here by reference. See Minnici, 128 F. App'x at 829-30 ("the alleged activities [we]re of an addictive sexual nature that cannot be suppressed simply by a restrictive set of bail
mposed by imprisonment makes that penalty the best indicator of whether the legislature considered an offense to be ... 'serious.'" United States v. Dugan, 667 F.3d 84, 86 (2d Cir. 2011) (quoting Lewis v. United States, 518 U.S. 322, 326 (1996)). And, the crimes Mr. Epstein has been charged with arc a
ceiving massag- es from young girls and young women perhaps as many as four times a day - appears likely to be uncontrollable. See United States v. Minnici, 128 F. App'x 827, 829-30 (2d Cir. 2005) (defendant's alleged sex crimes were "of an addictive sexual nature that cannot be suppressed simply by
. v. EPSTEIN Chess425 F.Supp.34 306 (S.D.N.Y. 2019) cator of whether the legislature considered an offense to be .. . `serious." United States v. Dugan, 667 F.3d 84, 86 (2d Cir. 2011) (quoting Lewis v. United States, 518 U.S. 322, 326, 116 S.Ct. 2163, 135 L.Ed2d 590 (1996)). And, the crimes Mr. E
he discussion at pp 10-21 is 27 EFTA00074016 Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 28 of 33 incorporated here by reference. See Minnici, 128 F. App'x at 829-30 ("the alleged activities [we]re of an addictive sexual nature that cannot be suppressed simply by a restrictive set of bail
mposed by imprisonment makes that penalty the best indicator of whether the legislature considered an offense to be ... 'serious.'" United States v. Dugan, 667 F.3d 84, 86 (2d Cir. 2011) (quoting Lewis v. United States, 518 U.S. 322, 326 (1996)). And, the crimes Mr. Epstein has been charged with arc a
he discussion at pp 10-21 is 27 EFTA00074055 Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 28 of 33 incorporated here by reference. See Minnici, 128 F. App'x at 829-30 ("the alleged activities [we]re of an addictive sexual nature that cannot be suppressed simply by a restrictive set of bail
mposed by imprisonment makes that penalty the best indicator of whether the legislature considered an offense to be ... 'serious.'" United States v. Dugan, 667 F.3d 84, 86 (2d Cir. 2011) (quoting Lewis v. United States, 518 U.S. 322, 326 (1996)). And, the crimes Mr. Epstein has been charged with arc a
ceiving massag- es from young girls and young women perhaps as many as four times a day - appears likely to be uncontrollable. See United States v. Minnici, 128 F. Appix 827, 829-30 (2d Cir. 2005) (defendant's alleged sex crimes were "of an addictive sexual nature that cannot be suppressed simply by
. v. EPSTEIN Chess425 F.Supp.34 306 (S.D.N.Y. 2019) cator of whether the legislature considered an offense to be .. . `serious." United States v. Dugan, 667 F.3d 84, 86 (2d Cir. 2011) (quoting Lewis v. United States, 518 U.S. 322, 326, 116 S.Ct. 2163, 135 L.Ed2d 590 (1996)). And, the crimes Mr. E
he discussion at pp 10-21 is 27 EFTA00081973 Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 28 of 33 incorporated here by reference. See Minnici, 128 F. App'x at 829-30 ("the alleged activities [we]re of an addictive sexual nature that cannot be suppressed simply by a restrictive set of bail
mposed by imprisonment makes that penalty the best indicator of whether the legislature considered an offense to be ... 'serious.'" United States v. Dugan, 667 F.3d 84, 86 (2d Cir. 2011) (quoting Lewis v. United States, 518 U.S. 322, 326 (1996)). And, the crimes Mr. Epstein has been charged with arc a
Entities connected to both Minnici and Wray Taps Dugan

Jeffrey Epstein
PERSON
Michael Jackson
PERSON
New York
LOCATION
Julie K. Brown
PERSON
Department of Justice
ORGANIZATION
George Mitchell
PERSON
Oliver Stone
PERSONThe New York Post
ORGANIZATION
United States
LOCATIONthe Southern District
LOCATION
James Baker
PERSON
Palm Beach
LOCATION
Southern District of New York
ORGANIZATION
New York State
LOCATION
New York City
LOCATION
Bradley Edwards
PERSON
Mark Epstein
PERSON
Jes Staley
PERSON
U.S. Virgin Islands
LOCATION
The Palm Beach Post
ORGANIZATION