o sue under 2255 and Epstein claims that they are ineligible because 371 isn't one of the enumerated sections listed in 2255. There is very little Il th Circuit case law related to ABA pleas, but the cases from other circuits suggest that there should be no problem. I would recommend that we not mention or

y Epstein (work release) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by Il th Circuit] N/A Page 28 of 69 EFTA00179650 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 30 of 70 Bates Range Description