EFTA00081293.pdf
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Case 9:08-cv-80736-KAM Document 361-19 Entered on FLSD Docket 02/10/2016 Page 1 of 2
EXHIBIT
19
EFTA00081293
Case 9:08-cv-80736-KAM Document 361-19 Entered on FLSD Docket 02/10/2016 Page 2 of 2
(USAFLS)
iirom:
(USAFLS)
nt:
Tuesday, September 18, 2007 12:44 PM
'Jay Lefkowitz'
ubject:
RE. Draft Agreements?
Hi Jay — It looks like I will be here all afternoon, but earlier is better than later. There arc a number of issues
with your version. but one that you can look at before our call is the calculation of the guidelines on the I 512(d)
counts. The cross-reference to 2X3. I applies, which then takes us to 2G1.3. Giving Mr. Epstein the benefit of
the doubt (that they would treat this as though there were only one victim), he would have a base offense level
of 24, plus 2 for a commercial sex act, totaling 26. Returning to 2X3.1. we would subtract 6 levels and subtract
another 3 levels for acceptance for a total offense level of 17. With criminal history category of I, that results in
24 to 30 months, which is in Zone D.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
From: Jay Lefkowitz [mailto:leficowitz@kirkland.com)
SentLinher
18, 2007 12:11 PM
To: N
(USAFLS)
" object:
RE: Draft Agreements?
— are you free for a call this afternoon? what time works best for you?
Thanks — Jay
09/IEV2007 09:14 AM
To -Jay lencoAftz" steRcmitzekkidantoorn>
cc
Sulaecl RE: Draft Agreements?
Hi Jay I know that the U.S. Attorney will not go below 18 months of prison/jail time (and i would strongly
oppose the suggestion).
Assistant U.S. Attorney
500 S. Australian Ave. Suite 400
West Palm Reach, FL 33401
II!rom: Jay Lefkowitz linallto;JLefkowItz@ktrkland.corn1
Sent: Tuesday, September 18, 2007 8:59 AM
RFP MIA 000113
EFTA00081294
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| Filename | EFTA00081293.pdf |
| File Size | 128.5 KB |
| OCR Confidence | 85.0% |
| Has Readable Text | Yes |
| Text Length | 1,804 characters |
| Indexed | 2026-02-11T10:28:06.341381 |