To: "'Jay Lefkowite" <[email protected]>
Subject: Factual proffer
Date: Tue, 18 Sep 2007 18:52:46 +0000
Importance: Normal
Attachments: Epstein_Plea_Proffer.doc
Hi Jay — I didn't want us to get sidetracked during the conference call. I want to make sure that we have a
factual basis for "harassment." Forcibly flyin1 omewhere else is a different 1512 offense with
a 10 year cap. This is the factual proffer that I drafted up earlier this afternoon, to give you an idea of what it
would look like.
When I include a factual proffer in a plea agreement, I usually use prefatory language like: The parties agree
that, had this case proceeded to trial, the United States would have proven the following facts beyond a
reasonable doubt, and that the following facts are true and correct and are sufficient to support a plea of
guilty .
EFTA00215237
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