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of incarceration. Id. at 5. "[T]he deprivation of liberty imposed by impris- onment makes that penalty the best indi- Amber Southerland, Billionaire Jeffrey Ep- stein: I'm a sex offender, not a predator, New York Post. Feb. 25. 2011. EFTA00076825 U.S. v. EPSTEIN Chess425 F.Supp.34 306 (S.D.N.Y. 2019) cator of
Act, each bail package in each case is considered and evaluated on its individual merits by the court. 18 U.S.C.A. § 3142. EFTA00076817 U.S. v. EPSTEIN Cite u423 F.Supp.34 306 (S.D.N.Y. 2019) Pro Hac Vice, United States Attorney's Office, New York, NY, Gloria Rachel Allred, Allred, Maroko & Gold
es etecruutime of We will need ha inlets icw her IC confine, 'he accvnicy of those facts led a second count. we ould rely on the incident wbcre Mr. Epascin's private investigators followed MSfather forcing him off the road. Or, if litre is something mom mom related to any NM we could consider ope that
-85. UNITED STATES of America, Government, v. Jeffrey EPSTEIN, Defendant 19 CR. 490 (RMB) United Stat
ruce Golding, NYPD let convicted pedophile Jeffi•ey Epstein skip judge-ordered check-in, New York Post, Jul
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
of incarceration. Id. at 5. "[T]he deprivation of liberty imposed by impris- onment makes that penalty the best indi- Amber Southerland, Billionaire Jeffrey Ep- stein: I'm a sex offender, not a predator, New York Post. Feb. 25. 2011. EFTA00066201 U.S. v. EPSTEIN Chess425 F.Supp.34 306 (S.D.N.Y. 2019) cator of
Act, each bail package in each case is considered and evaluated on its individual merits by the court. 18 U.S.C.A. § 3142. EFTA00066193 U.S. v. EPSTEIN Cite u423 F.Supp.34 306 (S.D.N.Y. 2019) Pro Hac Vice, United States Attorney's Office, New York, NY, Gloria Rachel Allred, Allred, Maroko & Gold
-85. UNITED STATES of America, Government, v. Jeffrey EPSTEIN, Defendant 19 CR. 490 (RMB) United Stat
ruce Golding, NYPD let convicted pedophile Jeffi•ey Epstein skip judge-ordered check-in, New York Post, Jul
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
vision The United States Attorney's Office Southern District of Florida 99 NE 4th Street Miami, Florida 33132 Dear• Mr. Menthe': July 25, 2007 Jeffiry Epstein TELEPHONE la 1E)7370400 m ailman We have previously provided you with a memo as to why we believe no charge under 18 U.S.C. §2422(b) could or sho
ting this statute. We also posited that the language of the statute would have to be stretched beyond recognition to fit the particular facts of Mr. Epstein's ease.' Enclosed is data that strongly supports the arguments we previously made. We have thoroughly analyzed every prosecution brought under the
.S.C. §2422(b) could or should be brought against Jeffrey Epstein, even assuming the specific conduct that
beyond recognition to fit the particular facts of Mr. Epstein's ease.' Enclosed is data that strongly supports
Crosby, 397 F.3d 103 (2d Cir. 2005). 4 EFTA00079417 - • 1" ."- t....7 S..• MC 1‘,. , yr - . VI ' ^ MiN)l h 7 A a - . U.S. v. Minnici, 128 Fed. Appx. 827 (2nd Cir. 2005) Unpublished Internet Defendant drove 170 miles to engage in sexual activities with "13 yr-old" after engagi
ivision The United States Attorney's Office Southern District of Florida 99 NE 41' Street Miami, Florida 33132 Dear Mr. Menchel: July 25, 2007 Jeffrey Epstein TELEPHONE '212)737-0400 FACSIMILE 12i P) 9/313-SI92 We have previously provided you with a memo as to why we believe no charge under 18 U.S.C.
ting this statute. We also posited that the language of the statute would have to be stretched beyond recognition to fit the particular facts of Mr. Epstein's case.t Enclosed is data that strongly supports the arguments we previously made. We have thoroughly analyzed every prosecution brought under the
Florida 33132 Dear Mr. Menchel: July 25, 2007 Jeffrey Epstein TELEPHONE '212)737-0400 FACSIMILE 12i
beyond recognition to fit the particular facts of Mr. Epstein's case.t Enclosed is data that strongly supports
be reconsidered in light of U.S v. Crosby, 397 F.3d 103 (2d Cir. 2005). 5 EFTA00224139 a SES FACILITY FACTS/COMMUNICATION CHARGaE . U.S. I Minnici, 128 Fed. Appx. 827 (2nd Cir. 2005) l npublislted Internet Defendant drove 170 miles to engage in sexual activities with "13 yr-old" after enga
engage in ... [sexual] conduct ... while he was in `jail'." Mr. Edwards is counsel to one of Mr. Epstein's victims. Reuven Fenton and Kate Sheehy, Jeffrey Epstein had sex den while serving time: lawyer New York Post. July 16, 2019. The Court is also aware of an article published by Palm Beach CBS local news wh
l law and federal rules. The key federal statute that applies here is 18 U.S.C. § 1591 which sets forth the crime of sex trafficking with which Mr. Epstein is charged. Mr. Epstein is also charged with conspiring with others to commit sex trafficking under 18 U.S.C. § 371. With respect to the issue of r
NEW YORK UNITED STATES OF AMERICA, - against - JEFFREY EPSTEIN, Government, Defendant. —x • x USDC
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
engage in ... [sexual] conduct ... while he was in `jail'." Mr. Edwards is counsel to one of Mr. Epstein's victims. Reuven Fenton and Kate Sheehy, Jeffrey Epstein had sex den while serving time: lawyer New York Post. July 16, 2019. The Court is also aware of an article published by Palm Beach CBS local news wh
l law and federal rules. The key federal statute that applies here is 18 U.S.C. § 1591 which sets forth the crime of sex trafficking with which Mr. Epstein is charged. Mr. Epstein is also charged with conspiring with others to commit sex trafficking under 18 U.S.C. § 371. With respect to the issue of r
TED STATES OF AMERICA, Government, - against - JEFFREY EPSTEIN, Defendant. • • x ~'/1WI/1e P— 1- t
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
engage in ... [sexual] conduct ... while he was in `jail'." Mr. Edwards is counsel to one of Mr. Epstein's victims. Reuven Fenton and Kate Sheehy, Jeffrey Epstein had sex den while serving time: lawyer New York Post. July 16, 2019. The Court is also aware of an article published by Palm Beach CBS local news wh
l law and federal rules. The key federal statute that applies here is 18 U.S.C. § 1591 which sets forth the crime of sex trafficking with which Mr. Epstein is charged. Mr. Epstein is also charged with conspiring with others to commit sex trafficking under 18 U.S.C. § 371. With respect to the issue of r
TED STATES OF AMERICA, Government, - against - JEFFREY EPSTEIN, Defendant. • • x ~'/1WI/1e P— 1- t
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
TED STATES OF AMERICA, Government, - against - JEFFREY EPSTEIN, Defendant. • • x ~'/1WI/1e P— 1- t
engage in ... [sexual] conduct ... while he was in `jail'." Mr. Edwards is counsel to one of Mr. Epstein's victims. Reuven Fenton and Kate Sheehy, Jeffrey Epstein had sex den while serving time: lawyer New York Post. July 16, 2019. The Court is also aware of an article published by Palm Beach CBS local news wh
l law and federal rules. The key federal statute that applies here is 18 U.S.C. § 1591 which sets forth the crime of sex trafficking with which Mr. Epstein is charged. Mr. Epstein is also charged with conspiring with others to commit sex trafficking under 18 U.S.C. § 371. With respect to the issue of r
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
Entities connected to both Jeffrey Epstein and Minnici

George Mitchell
PERSON
Alan Dershowitz
PERSONDaphne Wallace
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Jes Staley
PERSON
Harry Reid
PERSON
David Mitchell
PERSONSouthern District
LOCATION
Steve Bannon
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Alfredo Rodriguez
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION
New York
LOCATION
Reid Weingarten
PERSON
New York City
LOCATION