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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
rely on the incident where Mr. Epstein's private investigators followed [a victim's] father, forcing [him] off the road." [A, Dkt. 361-10; gee also gu➢ra p. 15. On September 16 EFTA00074005 Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 17 of 33 19, 2007, Mr. Epstein's counsel proposed that M
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
rely on the incident where Mr. Epstein's private investigators followed [a victim's] father, forcing [him] off the road." [A, Dkt. 361-10; gee also gu➢ra p. 15. On September 16 EFTA00074044 Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 17 of 33 19, 2007, Mr. Epstein's counsel proposed that M
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
rely on the incident where Mr. Epstein's private investigators followed [a victim's] father, forcing [him] off the road." [A, Dkt. 361-10; gee also gu➢ra p. 15. On September 16 EFTA00081962 Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 17 of 33 19, 2007, Mr. Epstein's counsel proposed that M
Entities connected to both Wray Taps Dugan and gu➢ra p.

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