To: Bradley 1 Edwards

To: Bradley 1 Edwards Subject: Please can is mall the dots Hi Brad, Hope you're reeling better and enjoying the weekend. Please can you email the &cc we discussed. Including all unsealed dots Many thanks, i mi ll aua lacl(Beny from I -Mobile Sent via BlackBerry from 1-Mobile Sent via BlackBerry from T-Mobile 02596 EFTA01100849 I torn: 10: Subject: Date: NMI GOO 9140 RICOVERY!!!! Monday, august 31, 2009 10:5033 04 Hi Brad, Hope you are well on your way to a Godspeed recovery! Please could you forward the names of the girls in NY, I somehow deleted those emails!!!! Mai m ' irks, Aug 24, 2009 07:38:41 PM, wrote: orry it look me a couple days. I actually forgot about it. If the link still does not allow ou to open il, then I am also giving you aN the information so that you can get it from acer. It is Jane One 102 v. Epstein. Case number 00-80656. Let me know if you need nything else from me and also it you hear of anything that would be helpful. I am still working on some things for you. legtliacungswiaggyAgratifkallin incerely, rad* J. Edwards artner Rothstein Rosenfeldt Adler! Attorneys at Law as Olas City Centre 01 East Los Olas Boulevard, Suite 1650 ort Lauderdale, FL 33301 facsimile 02895 EFTA01100850 from: Slibfa'atodelleotactI.LES Blflb To: Bradley J. icloueds Subject: Out Of Office Auto!Zen: FOS Date: Tuesday. tub 28, 2009 8:59:41 AM I am currently out of the office, returning Wednesday, July 29. I! you need to speak to someone in my absence, please contact my editor, Mary Hladky, at Or if it is 100% urgent you can call me on my cell. I am in a time zone six hours behind Florida time. Thank you. 03070 EFTA01100851 Roan: To: Subject: Date: waisr ae l drat PRIVATE 2. ONFICENTIA1 MonOay, SIP:OWe: ?I. 209 1:31:44 P.M Hi grad, Hope all is going according to plans. Just spoke with Mike. Found a few pieces of info that might help you. foundation under parent's name is registered at Clinton Global Initiative Elissa and Herbert Epstein Philanthropic Fund working for that foundation are a couple of family members including Mark Epstein Jill Epstein White (research) Debra Epstein (Dir of Finance) Bon voyage 03081 EFTA01100852 I Mori: to: atagyj Ediarcl Subject: Re: ? Vote: wediesnay, Otteber 1.1, 2OO19:01:0; FM Thanks Brad, good luck!!! Original Met;Sage Pr Brad om Edwards To: Sent: IA Oct :39 Subject: RE: ? The last email I received from you was weeks ago, so I assume I did not get it. I have a bunch of Lpstein things today up in west palm beach. I'll call you on my way home. Take care. From: (mailtualipmal . a c Sent: W. nee • y, . 4, 2009 S:. lo: Bradley J. Edwards Subject: ? lit Brad, Hope you're feeling better. Did you nut receive my previous email ? Best, Sent via BlackBerry from f -Mobile Sent via BlackBerry from T-Mobile 03189 EFTA01100853 Trot»: To: Subject: Date: nr icaunatta RI: Wetitte5417,1. October 1.1, 2(P1 7:19:m Ni the last email I received from you was weeks ago, so I assume I did not get it. I have a bunch of Epstein things today up in west palm beach. I'll call you on my way home. Take Care. On inal Message From: (miltoggipal. Sent: %V ne ay„ 2009 5: To: Bradley J. Edwards Subject: ? Ili Brad, Mope you're feeling better. Did you not receive my previous email ? at is est Sent via Illackilerry from T-MobIle 03190 EFTA01100854 I rani: Edwrib ' Date: TuctAay, 5rDtetrAter OIL 2009 II:13:00 AM I haven't forgotten about anything. I'm feeling a little better, which you know can also be a problem because you then think you can do mere, and of course I busted a suture out this morning. That delayed me going into work personally, but I will get you things ASAP. I found Evelyn's number, the other lady that worked for MC2 in NY. I think she will be very helpful. She knows everything Marisa knows but is much less sketchy. Also. ' on that Morisse already told you this and that, then she will give you more. Her number is Also. Epstein sent his and I heard it was because he couldn't risk is -I don't know how to go about getting her, but call you 4ncr. In fact, I just called und telt a message for you. Brad - • Sent: Tuesday, September 0 I, 2009 10:47 AM Front: made To: Wadley 1 Edwards Subject: DOCS Ili Brad, Hope you're feeling better this morning. Just a reminder please not to forget to send me the does, thank you Don't sit down too long and try to lie down as much as possible. even it' its on the floor! place towel underneath you and lie down! :) 04015 EFTA01100855 Num: To: MEP Cc: Btace/Callos lisbaystn Subject: IMPORTAK POTENTIAL MEDIA TACTIC Roman pols-kski on0 3E Date: Menlo, Scptenber 28, 2009 8,09.09 AM iii Brad, The media buzz surrounding polanski's arrest in Zurich based on a 7Os warrant for his arrest on charges that he bad sex with 13 year old skid be leveraged in epstein's case now!!!! Maybe mother's in palm beach can create a stir and a vigil against men in power who abuse children? What are your thoughts? Warmly, Sent via BlackBerry from T-Mobile 02913 EFTA01100856 From: eifteT-Lithatin To: Cirragfailaffna 4, Mject: RE: hey Brad! Date: Tuesday, tune f19, )C09 10.00 PM Attachments: 1(0141: 0=21 FYI - The motion to unseal the non-prosecution agreement (agreement between Epstein and the government) is in front of Judge Colbath tomorrow morning at 10.30 in courtroom 11F. I know that Tim wanted to have you guys there and we would love that too. Thanks Beadley..1. Edwards Partner Rothstein Roscnfeldt Adlert Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, EL 33301 facsimile From: Glasser, Glasser, Eric (WPTV) [mato Sent: Tuesday, June 02, 2009 10:24 AM To: Bradley J. Edwards Subject: hey Brad! I .un working on getting you a copy. Peter OK'd it -- so I'll keep you posted. Email me the address you want it sent to, OK? lalk soon, Eric 06655 EFTA01100857 e;icax):33renairomeni lam Fr : Mike Fisten Sea • Se 3 28.2009 23:45:22 To: Cc: Bee: Subject: Note Ili Just stopping by to say Hi, hope you had a pleasant trip back North. keep you posted as issues develop. Also I had a long talk with my agent about you and your project this weekend. He seemed very interested. I have been reading a lot lately about trafficking of children. The more I read the more believe SE has been doing this for some time. Bringing dozens of girls on false immigration documents from Eastern Europe, and Brazil to the US through the modeling agency. Where are all these girls now? Did they sell them? Someone in the news show 60 minutes caught on to this scheme 10 years ago and no one stepped in to stop it "Karim Models founder Brunel, who's currently a partner in MC2, denied allegations in a 1997 ""60 Minutes"" segment that he look advantage of young models who were high on drugs. Bnmel also reportedly left his Trump Tower digs in 1999 after complaints of night carousing, which he also denied. Disgraced former Elite models exec Gerald Marie is also involved with MC2, says our source. Marie was accused of having sex with underage models in a 1999 BBC documentary where he was filmed saying he hoped to seduce contestants in a modeling contest in which the average age of participants was 15. He also dated when she was "" Hope all is good, Mike Mike Fisten, Senior Intelligence Agent Rothstein Rosenfeld' Adler1 Attorneys at Law 401 East Las Ohs Boulevard, Suite 1260 Fort Lauderdale, Florida 33301 Telephone: Facsimile: Cellular: lik ll/CliDectanaills, 420und%20Sellinp/TrIalaksktupit ..teet loiVeDocskMad/MiteFiskne0233$^.2 MoilConleill.hien (1 of 2) RI/6O010 10.28:0$ PM) 19986 EFTA01100858 • 3.1S"chlmIConicni hint www.rra-law.com IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto ate not intended to constitute a ""reliance opinion"" under applicable Treasury Regulations, and accordingly arc not intended or written to be used, and may not be used or relied upon, for the purpose of (i) avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or (ii) promoting, marketing or recommending to another party any tax-related matters addressed herein. NOTICE: ME INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND CONFIDENTIAL. IT IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU [(AVE RECEIVED TITIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPLIONE COLLECT AND DELETE THE MATERIAL FROM ANY COMPUTER. THANK YOU. Lk in(1/1krreunct:Is%2Oa.O%20Scilings/ rtialfanklapilt ..utlian/CD0esiettagAtiktEisten002338^cMnile0tolt lam 12 of 2)111/V2010 0.2S,CIS 19987 EFTA01100859 From: WItraaafi To: Mad/ell Edwards Subject: Re: testae NAN Date: Wednesday, July 15, 2003 1:22:54 Pet No problem Brad. I totally understand being short staffed. No worries. I just want to be the story as complete as possible and, of course, to have your voice in it since you propelled this whole process. Michele On 7/15/09 3:17 PM, "Bradley J. Edwards" > wrote: I'm sorry Michele. My secretary is out, so I forwarded the instruction to another lawyer in the firm and it was delegated to another secretary. I hope you get it today, but like I said we are a person down right now staff-wise, so I will do my best to follow up and get you the response. Bradley J Edwards Partner Rothstein Rosonfeldt Adlert Attorneys at Law Las Ohs City Centre 401 East Las Olas Boulevard. Suite 1650 rdale FL 33301 facsimile From: Michele Dorgan Sent: Wednesday, July 15, 2009 1 : To: Bradley J. Edwards Subject: Epstein filing Hi Brad, I hate to be a pain, but I'm bumping up on deadline fur tomorrow's paper and haven't received your e-mall filing yet and I definitely want to include your position in my story. if you can e-mall me that pleading soon, I will be able to include your position in my story. Thanks in advance, Michele Michele Dorgan, staff writer ea h Dail News phone ax 04905 EFTA01100860 I ruin: [gaily jistayacit To: tlitheir pamae RE: Epstein ring Date: Wednesday, NV 15, 2:X9 1:17:00 PM I'm sorry Michele. My secretary is out. so I forwarded the instruction to another lawyer in the firm and it was delegated to another secretary. I hope you get it today, but like I said we are a person down right now staff-wise, so I will do my best to follow up and get you the response. Blarney J. litvards Partner Rothstein Rnsonfeldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale, FL 33301 facsimile From: Michele Dorgan [rnailto Sent: Wednesday, July 15, 20 To: Bradley ). Ldwards Subject: I pstein filing Hi Brad, I hate to be a pain, but I'm bumping up on deadline for tomorrow's paper and haven't received your e-mail filing yet and I definitely want to include your position In my story. If you can e-mail me that pleading soon, I will be able to include your position in my story. Thanks in advance, Michele • - Michele Dargati, staff writer Palm Bea Ddii News phone fax 04906 EFTA01100861 I rom: keelStL,EandeURIIIIIIELD*2.0th fetid') To: Bradley]. Edwards Subject: RE: iinsren Date: friday. May 22. 2009 )2:21:43 Pr'. 10.4, Thank you. Susan Spencer-Wendel Courts Reporter Beach Post 0) 0 Original Message From: Bradley Edwards (ma' Sent: Fri 5/22/2009 12:13 PM To: Spencer Wendel, Susan (CNI-Palm Beach) Sut)ect: Epstein The case in which the Non-prosecution agreement was released to the victims and victim's attorneys is Jane Doe v. United States of America, 08-80/36. It was released pursuant to protective order which is why 1 cannot discuss the contents of the Non-Prosecution agreement. Bradley J. Frtwards Partner Rothstein Rosenfeld) Adel Attorneys at taw Las Olas City Centre 401 East I as Olas Boulevard, Suite 1650 Fort I auderdale, Ft. 33301 direct line facsimile caladtaaning 05148 EFTA01100862 rrom: tiliallebilebaY 159F191 To: Bradley 1. &Weds Subject: RE. Epsom Date: tresday, May 26, 2009 5:31:30 PM Have called your olfice,we're good tomorrow if you are Tint From: Bradley ). Edwards (manta Soot: Tuesday, May 26, 2009 4:58 PM To: Malloy, Timothy (WPTV) Subject: Epstein lit dim, I was able to reach my client, and we would be able to arrange for an interview tomorrow. Please contact me at your earliest chance. Bradley .1. Edwards Partner Rothstein Rosenfoldt Adler] Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 direct line facsimile 05151 EFTA01100863 From: 5PPICCLIårSk.)-~Lek.Ftikni0 lo: Wadley ). tdwards Subject: RE: Cusick Date: I bursday. May28. 2009 2:13:11 PM Czar Mr. Edwards: Would ou have a moment to give me a call? Eli. Was the young woman you represent interviewed by Channel 5? And tid she/you touch on the sealing issues with 5? Please advise .. as we at the Post do not want to he beat to the punch. Many thanks, Susan Spencer-Wendel Courts Reporter Palm Beach Post r(O0) Original Message From: Bradley I. Edwards [MILO Sent: Fri 5/22/2009 12:13 PM To: Spencer Wendel, Susan (CNI-Palm Death) Subject: Epstein The case in which the Non-prosecution agreement was released to the victims and victim's attorneys is Jane Doe v. United States of America, 08-80736. R was released pursuant to protective order which is why cannot discuss the contents of the Non-Prosecution agreement. Bradley 3. Edwards Partner Rothstein Rosenfeldt Adler' Attorneys at Law Las Olas City Centre .401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 direct line facsimile <ma 05161 EFTA01100864 From: ruattlernatectis To: ache Daman Subject: RE: ecutein Date: Tuesday, :oat 23,200 1:l6:00 PM I sent the request to my secretary and she wilt send you those does today. Bradley J. Edwards Partner Rothstein Roseatekit Adler] Attorneys at Law Las Olas City Centre 401 East Las Otas Boulevard. Suite 1650 Fort Lauderdale, FL 33301 • facsimile • _ • - - - - • From: Michele Michele Dargan [mat° Sent: Tuesday, June 23, 2009 1:11 PM To: Bradley J. Edwards Subject: Re: epstein Brad, Thanks for the link. I appreciate It! Also, would you e-mall those documents that we talked about - your motion to unseal - and the Posts' atty if she has a separate one and also the Epstein attorney document that was filed on Friday. Thanks so much! Michele On 6/23/09 12:52 PM, "Bradley 1 Edwards" wrote: film /Mom radaronline comfexclusives/20091.25LeXclusiveieffrenengeirdle-releacrd-nrisnn-early Bradley J. Edwards Partner Rothstein Rosenfeldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 Mile Michele Dargan, staff writer Palm Beach Daily News phone fax 05203 EFTA01100865 from: etteray.J—EdraVnlå &Chet D.1100.0 L.00jett: RE: epstein Date: Tuesday, June 23, 2M9 2:31:03 PP I nave not seen anyone else report anything similar to the Radar report anywhere. Does that media channel not share with others? I am pretty curious how Radar got the info... Bradley J. Edwards Partner Rothstein Rosenfeld( Adler! Attornoys at Law Las Obs City Centre 401 East I as Glas Boulevard. Suite 1650 'on Lauderdale. FL 33301 - facsimile From: Michele Dargan !mantel Sent: Tuesday, June 23, 2009 1.27 PM To: Bradley J. Edwards Subject: Re: epstein Thanks! On 6/23/09 1: lb PM, "Bradley 3. Edwards" wrote: I sent the request to my secretary and she will send you those does today Bradley J. Edwards Partner Rothstein Rosenfeld( Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale. FL 33301 facsimile From: Michele Dargan [ragjita Sent: Tuesday, June 23, 2009 1:11 PM To: Bradley 3. Edwards Subject: Re: epstein Brad, Thanks for the link. 1 appreciate itl Also, would you e-mail those documents that we talked about - your motion to unseat - and the Posts atLy if she has a separate one and also the Epstein attorney document that was tiled on Friday. thanks so much! Michele On 6/23/09 12:S2 PM, "Bradley 3. Edwards" c wrote: hitoliwww radaronline com/exclusivest2009/0 11X 05207 EFTA01100866 Bradley I Edwards Partner Rothstein Resent°Icit Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale. FL 33301 - facsimile mai < Michele Darwin, staff writer P !In each Dail News hone ax 05208 EFTA01100867 noun: I o: Stohject: Data: CfStkaith tltchdestamae RE: epstein Tuesday, June 23, 2000 5:21:0t) rA Unfortunately she has not had time to send the does. I hope she gets them out today. but it may not happen. There is nothing to really comment on It doesn't surprise me at all that he. despite being a registered sex offender, is being released early, and it also won't be a surprise when he is released without the victims being notified. Par for the course with this case. I will try to gel you the does you want. See you 1 hursday. Bradley .1 Edwards Partner Rothstein Rosenfeld( Adler' Attorneys at Law Las Olas Cily Centre 401 East las Olas Boulevard. Suite 1650 I atderdale, FL 33301 - facsimile From: Michele Dargan [math° Sent: Tuesday, June 23, 2009 4:37 PM To: Bradley J. Edwards Subject: Re: epstein Brad, I haven't received those documents yet. Will she be able to forward them to me today? Also, I am filing a story to the web about his release date. Found out It's July 22 and 1 am citing Radaronline about his involvment in the Bear Stearns case. Do you want to comment on the fact that he's getting released on July 22? M On 6/23/09 1:16 PM, "Bradley J. Edwards" al wrote: I sent the request to my secretary and she will send you those does today. Bradley J. Edwards Partner Rothstein Rusenfoldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Fl. 33301 facsimile From: Michele Dargan Sent: Tuesday, June 23, 2009 1:1 To: Bradley J. Edwards Subject: Re: epstein ()rad, 05220 EFTA01100868 Thanks for the link. I appreciate it! Also, would you e-mail those documents that we talked about - your motion to unseal - and the Posts any if she has a separate one and also the Epstein attorney document that was filed on Friday. Thanks so much! Michele On 6/23/09 12:52 PM, "Bradley 3. Edwards" wrote: 11.1112:Thecaw radarentheSOriketthaveS/2O249/Ofg•xclisive:iellrey_lt • dsiealesurisgmsaty. Bradley .1. Edwards Panne' Rothstein Rosenfoicit Adler; Attorneys at Law Las Olas City Cantle 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale. FL 33301 - facsimile Michele Dargan, staff writer Palm Beach Dail News /) hone ax 05221 EFTA01100869 Dent: :luta I Edwards To: MireIto/Lean subject: erate.n Date: Wednesday, Juni, 24, 2009 9:14410 am blIPSWW,b.U.Sitle,SS.WegESengl2WdallaabalLCAPIIISSUI20.02a 2Z001=043430311M This was a story from 2007 already naming Epstein as the mysterious investor from a sauce other than Radar. Just thought rd share. Bradley J. Edwards Partner Rothstein Resent°Idt Adlert Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale, I-1 33301 - facsimile • --- From: MIchc4e Dargan (mailto Sent: Tuesday, June 23, 2009 4:37 PM To: Bradley 3. Edwards Subject: Re: epstein Brad, I haven't received those documents yet. Will she be able to forward them to me today? Also, I am tiling a story to Ow web about his release date. Found out it's July 22 and I am citing Radarunime about his invelyntent in the Bear Stearns case. Do you want to comment on the fact that he's getting released on July 22? M On 6/23/09 1:16 PM, "Bradley J. Edwards" wrote: I sent the request to my secretary and she will send you those dues today. Bradley J. Edwards Partner Rothstein Rosenfoldt Adler' Attorneys at Law Las Oias City Centre 401 East Las Olus Boulevard, Suite 1650 Foil Lauderdale, FL 33301 facsimile <Jn011ea From: Michele Dargan (Ma Sent: Tuesday, June 23, 2009 1:11 PM To: Bradley J. Edwards Subject: Re: epstein Brad, Thanks for the link. I appreciate it! 05224 EFTA01100870 Also, would you e-mail those documents that we talked about - your motion to unseal - and the Posts' DUN if she has a separate one and also the Epstein attorney document that was filed on friday. Thanks so much! Michele On 6/23/09 12:S2 PM, "Bradley J. Edwards" wrote: MULliVedanada020lilleSt2M&XCIUSIM.020=6LeXCiuSilte:atiCe.V.: • :LeilealethWisotteallY Bradley .1. Edwards Panne: Rothstein Rosenfoldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale. FL 33301 facsimile Michele Dargan, staff writer nil News phone fax 05225 EFTA01100871 (sons: Micfrele_04tailfi To: Bradley S. Edwards Subject: Re: ensteln Date: Tuesday, June 73, 7(109 1:13:17 PM Brad, Thanks for the link. I appreciate it! Also, would you e-mail those documents that we talked about - your motion to unseal - and the Posts' atty if she has a separate one and also the Epstein attorney document that was filed on Friday. Thanks so much! Michele On 6/23/09 12:52 PM, "Bradley J. Edwards' wrote: htto.liwww.radaronline comlexclusiyeaMyteipapi karyedelfrey-enstoky be- released- missal:tea. Bradley J. Edwards Partner Rothstein Rosenfeldt Adlerl Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 facsimile Michele Darwin, staff writer Palm Reach Daily News phone fax 05239 EFTA01100872 Flom: MeChi* Dargao To: Wadley 1. Ede/aids Subject: Re: (cute., Date: Tuesday. lone 73, 7009 I:29:20 eet Thanks! On 6/23/09 1:16 PM, "Bradley J. Edwards" • ca' wrote: I sent the request to my secretary and she will send you those does today. Bradley J. Fdwards Partner Rothstein Rosenfeld( Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, VI. 33301 From: Michele Dargan prtaiitcl Sent: Tuesday, June 23, 2009 1:11 PM To: Bradley 3. Edwards Subject: Re: epstein Brad, Thanks for the link. I appreciate it! Also, would you e-mall those documents that we talked about - your motion to unseal and the Posts atty if she has a separate one and also the Epstein attorney document that was filed on Friday. Thanks so much! Michele On 6/23/09 12:52 PM, "Bradley J. Edwards" > wrote: 09/.06/exclusive-j •m- • leasg.d.. Prison-early Bradley J. Edwards Partner Rothstein Rosenfeld( Adler' Attorneys al Law Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale, Ft. 33301 facsimile ma„,„7- O5277 EFTA01100873 •- Michele Dargan, staff writer it News hone ax 05278 EFTA01100874 From: MILNICRablaa To: Wadley 1 Ectogetls Subject: Re: epstein Date: Tuesday, June 23,2009 2:4r.42 PM I also noticed that Radar is the only one to report that info. Newspapers have a higher standard than online publications and bloggers etc. and newspapers, generally, have to confirm that the info is in fact true. However, we may be able to cite Radar as a s0urce....Believe me, I've been making umpteen calls trying to verify the Info. On 6/23/09 7:31 PM, "Bradley J. Edwards" ja , wrote: I have not seen anyone else report anything similar to the Radar report anywhere. Does that media channel not share with others? I am pretty curious how Radar got the into... Bradley J. Edwards Partner Rothstein Rosonteklt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale, FL 33301 - facsimile • - - • - - • . - • From: Michele Michele Dargan [matt Sent: Tuesday, June 23, 2009 1:21 PM To: Bradley J. Edwards Subject: Re: epstein Thanks! On 6/23/09 1:16 PM, "Bradley J. Edwards" a> wrote: I sent the request to my secretary and she will send you those dots today. Bradley J. Edwards Partner Rothstein Rosenfoldt AcIlerl Attorneys at Law Las Otns City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 facsimile smaS From: Muchete Dar an lit smadt Sent: Tuesday, June 23, 2009 1:11 P To: Bradley J. Edwards Subject: Re: epstein 05324 EFTA01100875 Brad, thanks for the link. I appreciate it! Also, would you e-mail those documents that we talked about - your motion to unseal - and the Posts' atty if she has a separate one and also the Epstein attorney document that was filed on Friday. Thanks so much! Michele On 6/23/09 12:52 PM, "Bradley J. Edwards' MEIR. wrote: htipavintizagamijatconyeitclungsall09106f ' ray-engem- -released- prison-early Bradley J. Edwards Partner Rothstein Rosenfoldt Adler] Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 FL 33301 facsimile <tnai!t0' Michele Dargan, staff writer Palm Beach Dally News phone fax 05325 EFTA01100876 From: athejekty03 To: Wadley ;. Etheards subject: Re: epstein Date: Tuesday, Tune 73, 7009 4:39:33 PM lit ad, I haven't received those documents yet. Will she be able to forward them to me today' Also, I am filing a story to the web about his release date. Found out it's July 22 and I am citing Radaronline about his involvment in the Clear Stearns case. Do you want to comment on the fact that he's getting released on July 22? M On 6/23/09 1:16 I'M, "Bradley J. Edwards- <I wrote: sent lite request to my secretary and she will send you those does today. Bradley .1. Edwards Partner Rothstein Rosenfehlt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 le FL 33301 facsimile Snail] - - • From: Michele Dargan [maS Sent: I uesday, June 23, 2009 1:11 PM To: Bradkiy 1 Edwards Subject: Re: epstein Brad, Thanks for the link. I appreciate it! Also, would you e-mail those documents that we talked about - your motion to unseal - and the Posts' atty if she has a separate one and also the Epstein attorney document that was filed on Friday. Thanks so much; Michele On 6/23/09 12:52 PM, "Bradley 1. Edwards" e wrote: BgplAvww radnionhneththyps 12009AlliekcIUSNe-lenfeY-09.51011-be-relnaSeLE orison-earl% Bradloy J. Edwards Partner Rothstein Rosonteldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fret Lauderdale FL 33301 facsimile 05368 EFTA01100877 [email protected] <mailisd Michele Dorgan, staff writer r• I with Dail News gione DX 05369 EFTA01100878 Front: laILLI4ltI2Z0a2 To: D:adley a. Edwal:15 Subject: 041 40cleln Elate: 'Tuesday, lune 23, ?MO S:28:53 FM Thanks so much. I am 000 to continue to pursue the Bear Stearns angle tomorrow. But, as for now, t will run two graphs citing Radar as the source. It should be up on the web within the hour at www.palmbeachdadynews.com On 6/23/09 5:22 PM, "Bradley 3. Edwards" a- wrote: Unfortunately she has not had lime to send the does. I hope she gels than out today. but it may not happen. There is nothing to really comment on. It doesn't surprise me at all that he, despite being a registered sex offender, is being released early, and it also won't be a surprise when he is released without the victims being notified. Par for the course with this case. I wilt try to get you the dots you want, See you Thursday. Bradley J. Edwards Partner Rothstein Rosenfeldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale, FL 33301 facsimile From: Michele Dargan Sent: Tuesday, June 23, 2009 : To: Bradley J. Edwards Subject: Re: epstein Brad, I haven't received those documents yet. Will she be able to forward them to me today? Also, I am filing a story to the web about his release date. Found out it's July 22 and 1 am citing Radarontine about his involvment in the Bear Stearns case. Do you want to comment on the fact that he's getting released on July 22? On 6/23/09 I:16 PM, "Bradley J. Edwards" wrote: I sent the request to my secretary and she will send you those does to ay. Bradley J. Edwards Partner Rothstein Rosenfoldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 FL 33301 05387 EFTA01100879 - facsimile bedwardsetirra-law.com cjvjll • - • - . - • • - • . • _ • - - • - From: i cmailt0' Sent: Tuesday, June To: Bradley J. Edwards Subject: Re: epstein PM Brad, Thanks (or the link. I appreciate it! Also, would you e-mail those documents that we talked about - your motion to unseal - and the Posts' atty if she has a separate one and also the Epstein attorney document that was filed on Friday. Thanks so much! Michele On 6/23/09 t2:52 PM, "Bradley J. Edwards" > wrote: li tplAvww rartmonlina.com/exclusivest7009/06/exclusive e rev :nAmici. - released- prisenready Wadley J. Edwards Partner Rothstein Rosenfeld) Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale, Fl. 33301 - facsimile «nailtoS Michele Dargan, staff writer Palm Beach Daily News phone fax 05388 EFTA01100880 From: raft,/ I.:award& To: Michele clarao Subject: Epstein applicalk statutes Date: Friday, September 18, 2009 2:55:00 PM Attachments: ianciattli Imoc.922,a I did not pull the conspiracy version. and convictions of conspiracy would add some amount of time. how much I don't know. I hope this helps. I cut the statutes straight from Westtaw. 18 § 2422 United States Cude Annotated Chhenthesa Title 18. Crimes and Criminal Procedure (Refs & Annos1 Earl!. Crimes ads & Annos.1 Chapter 117. Transportation for Illegal Sexual Activity and Related Crimes f 'trig &MOS) § 2422. Coercion and enticement (a) Whoever knowingly persuades, induces, entices, or coerces any individual to travel in interstate or foreign commerce, or in any Territory or Possession of the United Statesitto engage in prostitution, or in any sexual activity for which any person can be charged with a criminal offense, or attempts to do so, shall he fined under this title or imprisoned not more than 20 years, or both. (b) Whoever, using the mail or any facility or means of Interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices, or coerces any individual who has not attained the age of 18 years, to engage In prostitution or any sexual activity for which any person can be charged with a criminal offense, or attempts to do so, shall be fined under this title and imprisoned not less than 10 years or for life 18 U.S.C.A. § 2423 United States Code Annotated Currentnects. Titre 18. Crimes and Criminal Procedure (Bets & Annoc) Part 1. Crimes :Ref% & tagup Chanter 117. Transportation for Illegal Sexual Activity and Related Crimes (Refs Pt ARCM) § 2423. Transportation of minors (a) Transportation with intent to engage in criminal sexual activity.- -A person who knowingly transports an individual who has not attained the age of 18 years in interstate or foreign commerce, or in any commonwealth, territory or possession of the United States, with intent that the individual engage in prostitution, or in any sexual activity for which any person can he charged with a criminal offense, shall be fined under this title and imprisoned not Js than JO years or for life. (b) Travel with intent to engage in illicit sexual conduct.--A person who travels in interstate commerce or travels into the United States, or a United States citizen or an 01280 EFTA01100881 alien admitted for permanent residence in the United States who travels in foreign commerce, for the purpose of engaging in any illicit sexual conduct with another person shall be lined under this title or inionsttned not_morg_than 3a mass, or both. (c) Engaging in illicit sexual conduct in foreign places.--Any United States citizen or alien admitted for permanent residence who travels in foreign commerce, and engages in any illicit sexual conduct with another person shall be fined under this title or imprisoned not more than 30 years, or both. (d) Ancillary offenses.--Whoever. for the purpose of commercial advantage or private iinanciat gain, arranges, induces, procures, or facilitates the travel of a person knowing that such a person is traveling in interstate commerce or foreign commerce for the purpose of engaging in illicit sexual conduct shall be fined under this title, imprisoned not more than 30 years, or both. (e) Attempt and conspiracy.--Whoever atteinatS or consoires to violate subsection (a). (dl shall be punishable in the same manner as a completed violation of that cut/SIX-OM (f) Definition.--As used in this section, the term illicit sexual conduct" means (1) a sexual act (as defined in section 2246) with a person under 18 years of age that would be in violation of chapter 109A if the sexual act occurred in the special maritime and territorial jurisdiction of the United States; or (2) any commercial sex act (as defined in section 1591) with a person under 18 years of age. (g) Defense.--In a prosecution under this section based on illicit sexual conduct as defined in subsection (f)(2), it is a defense, which the defendant must establish by a preponderance of the evidence, that the defendant reasonably believed that the person with whom the defendant engaged in the commercial sex act had attained the age of 18 years. 18 U.S.C.A. § 1591 United States Code Annotated C.Urtattness Title 18. Crimes and Criminal Procedure (ilefs8Arms) Crimes (fiefs 8i Anno5.1 alaULer 71. Peonage, Slavery, and Trafficking in Persons fliefs_ectionns) § 1591. Sex trafficking of children or by force, fraud, or coercion (a) Whoever knowingly-- (1) in or affecting interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States, recruits, entices, harbors, transports, provides, obtains, or maintains by any means a person; or (2) benefits, financially or by receiving anything of value, from participation in a venture which has engaged in an act described in violation of paragraph (1), knowing, or in reckless disregard of the fact, that means of force, threats of force, fraud, coercion described in subsection (e)(2), or any combination of such means will be used to cause the person to engage in a commercial sex act, or that the person has not attained the age of 18 years and will be caused to engage in a commercial sex act, shall be punished as provided in subsection (b). 01281 EFTA01100882 (b) The punishment for an offense under subsection (a) is-- (1) ii the offense was effected by means of force, threats of force, fraud, or coercion described in subsection (e)(2), or by any combination of such means, or if the person recruited, enticed, harbored, transported, provided, or obtained had not_attainolthe ane au 4 years at the time of such offense, by a fine under this title and anurjanfl any_term of years not Ipso than 15 or for life; or (2) if the offense was not so effected, and the person recruited, enticed, harbored, transported, provided, or obtained bad attained the ace of 14 years butlat IBA attained the ane of AS years at the time of such riffense_by e fine under this title, and anorispnment for natiessthaallYeariarfor (c) In a prosecution under subsection (a)(1) in which the defendant had a reasonable opportunity to observe the person so recruited, enticed, harbored, transported, provided, obtained or maintained, the Government need not Drove that the defendant knew that the 'lesson had not attained the age of 18 years. (d) Whoever obstructs, attempts to obstruct, or in any way interferes with or prevents the enforcement of this section, shall be fined under this title, imprisoned for a term not to exceed 20 years, or both. (e) In this section: (1) The term "abuse or threatened abuse of law or legal process" means the use or threatened use of a law or legal process, whether administrative, civil, or criminal, in any manner or for any purpose for which the law was not designed, In order to exert pressure on another person to cause that person to take some action or refrain from taking some action. (2) The term "coercion" means-- (A) threats of serious harm to or physical restraint against any person; (B) any scheme, plan, or pattern intended to cause a person to believe that failure to perform an act would result in serious harm to or physical restraint against any person; or (C) the abuse or threatened abuse of law or the legal process. (3) The term "commercial sex act" means any sex act, on account of which anything of value is given to or received by any person. (4) The term "serious harm" means any harm, whether physical or nonphysical, including psychological, financial, or reputational harm, that is sufficiently serious, under all the surrounding circumstances, to compel a reasonable person of the same background and in the same circumstances to perform or to continue performing commercial sexual activity in order to avoid Incurring that harm. (5) The term "venture" means any group of two or more Individuals associated in fact, whether or not a legal entity. Twelfth, Section 206 of the Adam Walsh Act added 8 II S r iscri to the list of offenses for which a defendant is to be sentenced to life under 1.8.11..W-3552(elf71fAl. The amendment adds 18 U.S.C. 1591 to the list of instant offenses of convictions that are 01282 EFTA01100883 covered sex crimes under § 451.5. USSG, Ch. TWO, Pt. A, Refs & Annos, 18 U.S.C.A. United States Code Annotated Currentness. Federal Sentencing Guidelines Chapter Two. Offense Conduct Part A. Offenses Against the Person 3. Criminal Sexual Abuse and Offenses Related to Registration as a Sex Offender HISTORICAL NOTES 2007 Amendments Chapter Two, Part A, Subpart Three, is amended In the heading by adding at the end "AND OFFENSES RELATED TO REGISTRATION AS A SEX OFFENDERTM. Reason for Amendment: This amendment responds to the Adam Walsh Child Protection and Safety Act of 2006 (the "Adam Walsh Act"), Pub.L. 109-248, which contained a directive to the Commission, created new sexual offenses, and enhanced penalties for existing sexual offenses. The amendment implements the directive by creating two new guidelines, §§ 2A3.5 (Criminal Sexual Abuse and Offenses Related to Registration as a Sex Offender) and 2A3.6 (Aggravated Offenses Relating to Registration as a Sex Offender). It further addresses relevant provisions in the Adam Walsh Act by making changes to Chapter Two, Part A, Subpart 3 (Criminal Sexual Abuse) and Part G (Offenses Involving Commercial Sex Acts, Sexual Exploitation of Minors, and Obscenity), § 211.2 (Obstruction of Justice), § 301.2 (Groups of Closely Related Counts), § 481.5 (Repeat and Dangerous Sex Offender Against Minors), § 551.3 (Conditions of Probation), § 501.2 (Term of Supervised Release), § 501.3 (Conditions of Supervised Release) and Appendix A (Statutory Index). First, section 206 of the Adam Walsh Act amended IR 11 S.0 27416-). to add a new mandatory minimum term of imprisonment of 30 years for offenses related to the aggravated sexual abuse of a child under 12 years old, or of a child between 12 and 16 years old if force, threat, or other means was used. In response to the new mandatory minimum for these offenses, the amendment increases the base offense level at § 2A3.1 (Criminal Sexual Abuse; Attempt to Commit Criminal Sexual Abuse) from level 30 to level 38. The base offense level of 30 has been retained for all other offenses. At least one specific offense characteristic applied to every conviction under .18 U S.C. 2241(cI sentenced under § 2A3.1 in fiscal year 2006. Accordingly, the mandatory minimum 360 months' imprisonment is expected to be reached or exceeded In every case with a base offense level of 38. The amendment provides a new application note that precludes application of the specific offense characteristic at § 2A3.1(b)(1) regarding conduct described in JR U.S C. 2241/al or 011 if the conduct that forms the basis for a conviction under 1,5 U.S.C.. 2241(r). is that the defendant engaged in conduct described In 18 U.S.C. 2241fal or 04 (force, threat, or other means). The amendment also precludes application of the specific offense characteristic for the age of a victim at § 2A3.1(b)(2) if the defendant was convicted under section 2241(c). The heightened base offense level of 38 takes into account the age of the victim. These instructions, therefore, avoid unwarranted double counting. Second, section 207 of the Adam Walsh Act increased the statutory maximum term of Imprisonment under 18 ll.Ss.C. 2243(b1 from 5 years to 15 years for the sexual abuse of a person in official detention or under custodial authority. In response to increased penalty, 01283 EFTA01100884 the amendment increases the base offense level from 12 to 14 in § 2A3.3 (Criminal Sexual Abuse of a Ward or Attempt to Commit Such Acts). The amendment also adds a new definition of "minor" consistent with how this term is defined elsewhere in the guidelines manual. In addition, the amendment includes an application note precluding application of § 3B1.3 (Abuse of Position of Trust or Use of Special Skill) for these offenses because an abuse of position of trust is assumed in all such cases and, therefore, is built into the base offense level. Third, section 206 of the Adam Walsh Act created a new subsection at 18 U S.C. 7244. Section 2244(a)(5) provides a penalty of any term of years if the sexual conduct would have violated 1$__U„S.0 2241(c1 had the contact been a sexual act. Section 2241(c) conduct involves the aggravated sexual abuse of a child under 12 years old or of a child between 12 and 16 years old if force, threat, or other means was used, as defined in 1./ U.S C 2241O1 and Prior to the Adam Walsh Act, the penalty for offenses involving children under 12 years old was "twice that otherwise provided," and the penalty for sexual contact involving behavior described in 18 LI S.C. 2241 was a statutory maximum term of imprisonment of 10 years. The amendment addresses this new offense by increasing the minimum offense level in the age enhancement In subsection (b)(1) of § 2A3.4 (Abusive Sexual Contact or Attempt to Commit Abusive Sexual Contact) from level 20 to level 22. Fourth, section 141 of the Adam Walsh Act created a new offense under 18 U.S C 22Sffial for the failure to register as a sex offender. The basic offense carries a statutory maximum term of imprisonment of 10 years. Section 141 also included a directive to the Commission that when promulgating guidelines for the offense, to consider, among other factors, the seriousness of the sex offender's conviction that gave rise to the requirement to register; relevant further offense conduct during the period for which the defendant failed to register; and the offender's criminal history. The amendment creates a new guideline, § 2A3.5 (Failure to Register as a Sex Offender), to address the directive. The new guideline provides three alternative base offense levels based on the tiered category of the sex offender: level 16 if the defendant was required to register as a Tier III offender; level 14 if the defendant was required to register as a Tier II offender; and level 12 If the defendant was required to register as a Tier I offender. The amendment also provides two specific offense characteristics. First, subsection (b)(1) provides a tiered enhancement to address criminal conduct committed while the defendant Is in a failure to register status. Specifically, § 2A3.5(b)(1) provides a six-level increase if, while in a failure to register status, the defendant committed a sex offense against an adult, a six-level Increase if the defendant committed a felony offense against a minor, and an eight•level increase If the defendant committed a sex offense against a minor. Second, § 2A3.5(b)(2) provides a three-level decrease if the defendant voluntarily corrected the failure to register or voluntarily attempted to register but was prevented from registering by uncontrollable circumstances, and the defendant did nut contribute to the creation of those drcumstances. The reduction covers cases in which (1) the defendant either does not attempt to register until after the relevant registration period has expired but subsequently successfully registers, thereby correcting the failure to register status, or (2) the defendant, either before or after the registration period has expired, attempted to register but circumstances beyond the defendant's control prevented the defendant from successfully registering. An application note specifies that the voluntary attempt to register or to correct the failure to register must have occurred prior to the time the defendant knew or reasonably should have known a jurisdiction had detected the failure to register. The application note also provides that the reduction does not apply if the enhancement for committing one of the enumerated offenses in § 2A3.5(b)(1) applies. 01284 EFTA01100885 Additionally, the amendment adds § 2A3.5 to the list of offenses that are considered groupable under § 3D1.2(d) because the failure to register offense is an ongoing and continuous offense. Fifth, section 141 of the Adam Walsh Act created two new aggravated offenses relating to the registration as a sex offender. Section 141 of the Act created 18 u S.c. ?250(r], which carries a mandatory minimum term of imprisonment of 5 years and a statutory maximum term of imprisonment of 30 years if a defendant commits a crime of violence while in a failure to register status, with the sentence to be consecutive to the punishment provided for the failure to register. Section 702 of the Adam Walsh Act created a new offense at 1811 S C 2260A that prohibits the commission of various enumerated offenses while in a failure to register status. 'I he penalty for this offense is a mandatory term of imprisonment of 10 years to be imposed consecutively to the underlying offense. The amendment creates a new guideline at § 2A3.6 (Aggravated Offenses Relating to Registration as a Sex Offender) to address these new offenses. The new guideline provides that for offenses under section 2250(c), the guideline sentence is the minimum term of imprisonment required by statute, and for offenses under section 2260A, the guideline sentence Is the term of imprisonment required by statute. Chapters Three and Four are not to apply. This is consistent with how the guidelines treat other offenses that carry both a specified term of imprisonment and a requirement that such term be Imposed consecutively. See §§ 3D1.1 (Procedure for Determining Offense Level on Multiple Counts) and 5G1.2 (Sentencing on Multiple Counts of Conviction). The guideline includes en application note that provides an upward departure stating that a sentence above the minimum term required by section 2250(c) is an upward departure from the guideline sentence. An upward departure may be warranted, for example, in a case involving a sex offense committed against a minor or if the offense resulted in serious bodily injury to a minor. Sixth, section 208 of the Adam Walsh Act added a new mandatory minimum term of imprisonment of 15 years under 18 it S.C. 1591(51(11 for sex trafficking of an adult by force, fraud, or coercion. In response, the amendment provides a new base offense level of 34 in § 2G1.1 (Promoting a Commercial Sex Act or Prohibited Sexual Conduct with an Individual Other than a Minor) if the offense of conviction is 18 U.S.C. 1591.0)(1), but retains a base offense level of 14 for all other offenses. In addition, the amendment limits application of the specific offense characteristic at § 2G1.1(b)(1) that applies if the offense involved fraud or coercion only to those offenses receiving a base offense level of 14. Offenses under 18 U S.C. 1591(b)(11 necessarily involve fraud and coercion and, therefore, such conduct is built into the heightened base offense level of 34. This limitation thus avoids unwarranted double counting. Seventh, section 208 of the Adam Walsh Act added a new mandatory minimum term of imprisonment of 15 years under J8 LI.S.0 15911b1(1) for sex trafficking of children under 14 years of age and added a new mandatory minimum term of imprisonment of 10 years and increased the statutory maximum term of imprisonment from 40 years to life under JS U S C. 1591161(21 for sex trafficking of children who had attained the age of 14 years but had not attained the age of 18 years. Further, the Adam Walsh Act increased the mandatory minimum term of imprisonment from S years to 10 years and increased the statutory maximum term of imprisonment from 30 years to life under both 18 11.S C 74771bl for persuading or enticing any person who has not attained the age of 18 years to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense, and IR U,SC 2473Cal, for transporting a person who has not attained the age of 18 years in interstate or foreign commerce, with the intent that the person engage in prostitution, or in any sexual activity for which any person can be charged with 01285 EFTA01100886 a criminal offense. in response, the amendment provides alternative base offense levels in § 2G1.3 (Promoting a Commercial Sex Act or Prohibited Sexual Conduct with a Minor; Transportation of Minors to Engage in a Commercial Sex Act or Prohibited Sexual Conduct; Travel to Engage in Commercial Sex Act or Prohibited Sexual Conduct with a Minor; Sex Trafficking of Children; Use of Interstate Facilities to Transport Information about a Minor) based on the statute of conviction and the conduct described in that conviction. For convictions under j8 U S.C. 1591f tiff 11, the base offense level is 34. For convictions under 1$ U.S.0 1591(h)(71, the base offense level Is 30. The amendment further provides a base offense level of 28 for convictions under la U.S.C. 2427(b). and 2471(a1. The two-level enhancement for the use of a computer at § 261.3(b)(3) applied to 95 percent of offenders convicted under 1ILU.S.c,_2422(b1 and sentenced under § 2G1.3 in fiscal year 2006. In addition, the two-level enhancement for the offense involving a sexual act or sexual contact at § 2G1.3(b)(4) applied to 95 percent of offenders convicted under 18 U S.C. 2473/al and sentenced under this guideline In fiscal year 2006. With application of either enhancement, the mandatory minimum term of imprisonment of 120 months will be reached in the majority of convictions under 111 U.S C. 7472(h1. and 24231a) before application of other guidelines adjustments. Further, the amendment addresses the interaction of two specific offense characteristics with the alternative base offense levels. First, every conviction under 18 U S.0 1591 necessarily Involves a commercial sex act. With the base offense levels being determined based on the statute of conviction, the amendment clarifies that § 2G1.3(b)(4)(B), which provides a two-level enhancement if the offense involved a commercial sex act, does not apply if the defendant Is convicted under 18 U.S.C. 1591 Second, the amendment precludes application of the age enhancement in § 2G1.3(b)(5) if the base offense level is determined under subsection (a)(1) of § 2G1.3 for a conviction under louse- 1591(13)(1). The base offense level provided by subsection (a)(1) of § 2G1.3 takes into account the age of the victim and, therefore, limitations on application of subsections (b)(4)(8) and (b)(5) of § 2G1.3 avoid unwarranted double counting. Eighth, section 503 of the Adam Walsh Act created a new section, 18 U.S.0 7S7A adopting new recordkeeping obligations for the production of any book, magazine, periodical, film, videotape, or digital Image that contains a visual depiction of simulated sexually explicit conduct. Section 2257A has a statutory maximum of one year imprisonment for the failure to comply with the recordkeeping requirements and a statutory maximum term of imprisonment of five years if the violation was to conceal a substantive offense that involves either causing a minor to engage in sexually explicit conduct for the purpose of producing a visual depiction or trafficking in material involving the sexual exploitation of a minor. The new offense is similar to 18 U S C 7757 which Is referenced to § 2G2.5 (Recordkeeping Offenses Involving the Production of Sexually Explicit Materials; Failure to Provide Required Marks in Commercial Electronic Mail). Accordingly, the amendment refers the new offense to § 2G2.5. Ninth, section 701 of the Adam Walsh Act created a new offense in 18 ll S.C. 2257A(01 that prohibits engaging in child exploitation enterprises, defined as violating is ti s r 1,591, 1701 (if the victim is a minor), chapter 109A (Involving a minor victim), chapter 110 (except forja 11 S C. 2257 and .7757A), or chapter 117 (involving a minor victim), as part of a series of felony violations constituting three or more separate incidents and Involving more than one victim, and committing those offenses in concert with three or more other people. The statute provides a mandatory minimum term of imprisonment of 20 years. The amendment creates a new guideline at § 2G2.6 (Child Exploitation Enterprises) to cover this new offense. The guideline provides a base offense level of 35 and four specific 01286 EFTA01100887 offense characteristics. The Commission anticipates these offenses typically will involve conduct encompassing at least one of the specific offense characteristics, resulting in an offense level of at least level 37. Thus, the mandatory minimum term of imprisonment of 740 months typically is expected to be reached or exceeded, before application of other guideline adjustments. Tenth, section 206 of the Adam Walsh Act increased the statutory maximum term of imprisonment from 4 years to 10 years under 18 Q S.C. 2,528(b1 for knowingly using a misleading domain name with the intent to deceive a minor into viewing material harmful to minors on the Internet. In addition, section 703 of the Act created a new section,11 7752C, that carries a statutory maximum term of imprisonment of 10 years for knowingly embedding words or digital images into the source code of a Web site with the intent to deceive a person into viewing material constituting obscenity. Section 2252C(b) carries a statutory maximum term of imprisonment of 20 years for knowingly embedding words or digital images into the source code of a Web site with the Intent to deceive a minor Into viewing material harmful to minors on the Internet. In response to the new offense, the amendment expands the scope of subsection (b)(2) el § 2G3.1 (Importing, Mailing, or Transporting Obscene Matter; Transferring Obscene Matter to a Minor; Misleading Domain Names) by adding to this enhancement "embedded words or digital images into the source code on a Web site." Eleventh, section 141 of the Adam Walsh Act added a new provision in JR USX. 1001 that carries a statutory maximum term of imprisonment of 8 years for falsifying or covering up by any scheme or making materially false or fraudulent statements or making or using any false writings or documents that relate to offenses under chapters 109A, 109B, 110, and 117, and under section 1591 of chapter 77. The amendment adds a new specific offense characteristic at subsection (b)(1)(A) of § 211.2 (Obstruction of Justice) enhancing the offense level by four levels if the defendant was convicted under HI 1001 and the statutory maximum term of 8 years' imprisonment applies because the matter relates to sex offenses. The amendment also added language to Application Note 4 stating an upward departure may be warranted under the guideline in a case involving a particularly serious sex offense. Twelfth vrtinn 70fLollheSdamWalabAstaddeLLSAISCalheistsLoffenses for which a defenrivt Is to he sentenced to life under 18 U 4 C. 3559(001(AI The amendment adds 18 11,1.C. 1591 to the list of instant offenses of convictions that are covered sex crimes under 6 4B1 S Thirteenth, section 141 of the Adam Walsh Act amended 18 U.S.0 3563. and 311,1. The amendment adds a new subdivision to (a)(9) of § SB1.3 and to (a)(7) of § 5D1.3 to require a defendant to comply with the new registration requirements provided by the Adam Walsh Act. The amendment also modifies the language In §§ SB1.3(a)(9) and 5D1.3(a)(7) relating to defendants convicted of a sexual offense described in 18 II sr no4zfrusi. Not all states have implemented the new requirements, continuing to register sex offenders pursuant to the sex offender registry in place prior to July 27, 2006, the date of enactment of the Adam Walsh Act. Thus, It is necessary to maintain the language in the guidelines providing for conditions of probation and supervised release for those offenders. Fourteenth, section 141 of the Act amended 18 11.4.0 35/33(k1 which provides that the authorized term of supervised release for any offense under enumerated sex offenses Is any term of years or life. In response, the amendment adds offenses under chanter 10%1 and sections j2 01 and 1591 of title 111 United Statesinrie or 1R U s r 1201 and 1511 to the definition of sex offense under § 501.2(b)(2) for which the length of the term of supervised release shall be not less than the minimum term of years specified for the offense and may be up to life. 01287 EFTA01100888 Finally, the amendment provides a definition of "minor" in relevant guidelines that is consistent with how this term is defined elsewhere in the guidelines. Outdated background commentary also is deleted by this amendment. The effective date of this amendment is November 1, 2007. Bradley .1. Edwards Partner Rothstein Rosonfoldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 r I FL 33301 facsimile 01288 EFTA01100889 cMailCoriem hun From: go. At: Sep 24, 200 . To: Bradley J. Edwards Cc: Bcc: Subject: T Visas Please read this important. I think you can offer a trafficked victim protection, asylum and an incentive for coining forward on the case. Ask your clients if they know of any victims who were foreign so they can tell them about this and assuage their fears! This is a break through for some of the girls, because they'll be able to bring their families into the US on these visas. According to Acosta some 7000 visas are issued annually and the last time he checked only 1500 -2000 apply annually. That means that the word is NOT out about the visas (on purpose may I add and furthermore, that there is ZERO effort on the part of law enforcement to get it out, fear of having visa abused!!!! More importantly,How are you feeling? Hope you're healing quickly!!! Congress passes Violence Against Women Act of 2000 Immigrants' Rights Update, Vol. 14, No. 6, October 19, 2000 Passed by Congress on Oct. I 1, 2000, the Victims of Trafficking and Violence Protection Act of 2000 (11.R. 3244) includes the Violence Against Women Act of 2000 (VAWA 2000), which expands and improves on the protections for battered spouses and children that were originally enacted in the Violence Against Women Act of 1994 (VAWA 1994). Most notably, VAWA 2000 eliminates the ""extreme hardship"" requirement for self-petitioners and allows all self-petitioners to adjust their status in the United States. The act also creates two new nonimmigrant visas for victims of trafficking and for victims of certain serious crimes, including victims of crimes against women (see ""Congress Creates New ""T"" and ""U"" Visas for Victims of Exploitation ""). Individuals granted these visas may subsequently adjust to permanent resident status. The bill passed both houses by enormous margins (371-1 in the House and 95-0 in the Senate), and President Bill Clinton has promised to swiftly sign it. VA WA 1994. The original VAWA included provisions to address the particular problems faced by battered immigrant women and children. Under pre-VAWA immigration law, immigrant spouses and children of U.S. citizens or lawful permanent residents (LPRs) were dependent on the citizen or LPR to petition to immigrate them, and this dependency left them particularly subject to abuse on the part of that relative. The VAWA created a procedure whereby abused spouses and their children or abused children and their parents can ""self-petition"" to obtain LPR status without the cooperation of the abusing relative. The VAWA also enabled battered spouses and children to obtain suspension of deportation or cancellation of removal if they were present in the U.S. for at least three years rather than 0k MCVOnc tatleA20and%20Seliinpftrial/Dcskuop/li onitINcsieMaileMailetinicnt.hon (I of 4)(1 I/6/201010:10.01 PM) 10586 EFTA01100890 S hbailcontemilhil the seven years normally required for suspension or ten years for cancellation. Obstacles based on family/marital status removed. VAWA 2000 removes a number of obstacles that battered spouses and children have encountered in attempting to use provisions of the VAWA intended to help them. For example, a battered spouse whose marriage is defective because her husband failed to tell her that he was already married is not eligible to immigrate under VAWA 1994. VAWA 2000 corrects this problem by allowing individuals who believed that they were married to a U.S. citizen or ! PR to self-petition. VAWA 2000 also allows individuals to self-petition even though they have been divorced from the citizen or LPR, provided that the marriage terminated within the past two years and a connection between the termination of the marriage and the abuse of the immigrant can be shown. These changes also apply to VAWA suspension of deportation and cancellation of removal. Moreover, individuals may self-petition even if the citizen relative has died, provided they petition within two years of the death. No need to leave U.S. to apply for VAWA visa. The new law allows all VAWA self-petitioncrs to apply for adjustment of status in the United States, regardless of whether they were inspected when they entered the country or whether they subsequently maintained lawful status. ""Extreme Hardship" and other requirements for VAWA self-petitioners. The act also eliminates the disparate treatment of self-petitioners who, under prior law, had to meet certain requirements not applied to regular family immigrant visa applicants. Most significantly, self-petitioners no longer need to show that their deportation would cause "extreme hardship."" This eliminates an enormous evidentiary hurdle from the self-petition procedure. The law also allows abused spouses and children of U.S. employees and military personnel living abroad to self-petition. Under the new law, if the U.S. citizen or LPR parent or spouse subsequently loses that status for reasons related to their abusive conduct, the loss does not affect the abused immigrant's eligibility to immigrate if they petition within two years. Moreover, abused immigrants with approved self-petitions may remarry without causing the petition to he revoked. Good moral character. Self-petitioners under the new law still must show that they have ""good moral character." However, the new law partially exempts them from the bar on establishing good moral character outlined in 1NA section 101(0. Under that provision, immigrants cannot establish good moral character if they have committed or been convicted of certain criminal acts. The new law removes the bar if the act constitutes a ground of admissibility or &portability that is waivable, and the act was connected to the abuse the applicant suffered. This rule also applies to applicants for VAWA suspension or cancellation. Children who ""age out."" Under the act, children who have filed a self-petition or are derivative beneficiaries of a parent's petition 110 longer ""age out,"" or become subject to normal family visa rules, when they become 21 years old. instead, they are treated as self-petitioners under the appropriate category (as unmarried sons or daughters of U.S. citizens or LPRs, or married sons or daughters of citizens), with the parent's priority date. hlr//MUD.Kmncros%20sd%20Se11ingv7rlialA7akloNG. on/Woes/O.1:i eMaileomtnl Inin (2 of O(11/6/2010 10.10:01 I'M) 10587 EFTA01100891 Relaxed continuous physical presence requirement. The act allows applicants for VAWA cancellation of removal to show that they have three years' continuous physical presence in the U.S., despite a single absence longer than 90 clays or cumulative absences exceeding 180 days, if there is a connection between the absence and the abuse perpetrated against the applicant. The act also eliminates application of the ""stop-time role"" (under which service of a Notice to Appear stops the accrual of continuous physical presence) in VAWA cancellation and suspension cases. And it requires the attorney general to parole the children or parents of individuals who are granted VAWA suspension or cancellation. Motions to reopen. The act allows individuals who become eligible for VAWA suspension or cancellation because of the changes made by the new law to move to reopen their proceedings. It also amends the INA's time limitations on motions to reopen, allowing individuals to file a motion to reopen to apply for VAWA cancellation within one year of the entry of a final order. The attorney general may also waive the one-year limitation in cases of extraordinary circumstances or extreme hardship to a child. New waivers of grounds of inadmissibility and deportability. The act establishes waivers of certain grounds of inadmissibility for abused immigrants. There is a waiver of the ground of inadmissibility for reentering the U.S. without inspection following a one-year period of unlawful presence or after having been ordered removed. This waiver is available to individuals who can establish a connection between the abuse they suffered and their departure or reentry. There is also a waiver of the ground of deportability for having a conviction for a crime of domestic violence or for violation of a protective order, if the abused immigrant can show that she was not the primary perpetrator of violence in the relationship. She must also show that she was acting in self- defense or that the crime did not result in serious bodily injury and was connected to the abuse that the immigrant suffered. The act makes available to abused immigrants the INA's waivers for certain criminal grounds (§ 212(h)), fraud or misrepresentation (§ 212(0), and health grounds (§ 212(g)). Expanding the availability of these waivers was considered necessary because they had been limited to spouses of U.S. citizens or LPRs. Abused immigrants may no longer have such a relationship. Public charge. The act amends the public charge ground of exclusion to provide that cash or other benefits received pursuant to 8 U.S.C. section 1641(c) (which permits VAWA beneficiaries to obtain cash and other government assistance in connection with their escape from domestic violence) may not be considered in public charge determinations. Changes to Cuban Adjustment Act, NACARA, and }IRIFA. The act also amends the Cuban Adjustment Act, the adjustment of status provisions of the Nicaraguan Adjustment and Central American Relief Act (NACARA), and the Haitian Refugee Immigration Fairness Act (HRIFA). These amendments allow abused spouses or children who are dependents of individuals eligible for relief under these laws to adjust their status, without having to reside with the principal or maintain the relationship. Under the act, persons who become LPRs through VAWA may also apply for naturalization after they have resided in the U.S. in LPR status for three years. Me://KilDoctimam%20nnd%20SolinisITtigaDesktop/E.. oc*DoakMsi eMailCorticm Mon (1M (11/6/2010 1010:01 PM) 10588 EFTA01100892 .MailfromothIm Sep 24, 2009 08:34:02 PM, wrote: Long day. I will call you tomorrow. Client went through hell today. Ori inal Message Front imaillo Sent: Thursday, September 24, 2009 10:39 AM To: Bradley J. Edwards Subject: Not a mention of the name atter a 2 1/2 hour interview Sent via BlackBerry from T-Mobile //f(14)actimenh%20:mird4ZOSepiotgs/ProaltneAtop/P_ .onielMesleMoi Mailepment Wm hl of 4) I 11/(/201010:10.01 PMI 10589 EFTA01100893 Maileont ai From: Michele Darwin Sent: Jul 29, 2009 13:47:51 To: Bradley J. Edwards Cc: lice: Subject: Re: Epstein Brad, We have no way of getting the members or the banned members lists. However, I spoke to Donald Trump today - nothing like getting it from the horse's mouth! Anyway, he said Epstein is not a member and would not confirm or deny that he ever was a member. He would not comment at all (which is very rare for him) on whether or not Epstein got booted from the club or if he had recruited girls from Mar-A-Lago. Sorry I couldn't be more help. I really thought that he would say something. He usually does comment for all of our stories. That's why this was quite unusual. If you get any info, please pass it on....like if any info comes out during tiepin of anything related to Epstein getting booted from the club or about him recruiting girls from there. You know I will run with it! Michele On 7/28/09 9:28 AM, ""Bradley J. Edwards"" wrote: Hi Michele, I was wondering if you were able to get a members list at the Maralago, and even more importantly if you were able to get a list of banned members from the Maralago? Rumor has it that he was banned for having sex with and attempting to have sex with minors at the club, and we already know of certain minors that he took from the dub to his house. I will take a deposition of someone there if we need to do that to get the true information on this, but there are so many depositions to take in this case (and we are setting them right now around the country) that I would like to avoid this one if we could get the info another way. Thanks Bradley J. Edwards Partner file ///C/Documents542nantrAMSeitinD41) ial/l)cskAopc. oak I haft/Au ttmodcomou him (s 00)(1 I/61:010 10 10.54 Mg 11075 EFTA01100894 UlaJlry lidwaidh017032^i:MailConleni him Rothstein Rosenfeld' Adieu Attorneys at Law Las Olas City Centre 401 Past Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 facsimile Michele Dorgan, staff writer Palm Beach Daily News phone fax illell/CYDociinicals%200m0420Sciiiiirltrial/Desktop/0 .nnicl)ricah:Mai MoilConteot.liten (2 of 2) II 1/N2010 1010.54 PMI 11076 EFTA01100895 From: Michele Dargan Sent: Jul 31, 2009 11:20:03 To: Bradley J. Edwards Cc: Bee: Subject: Re: Epstein • -.. I• • • •••••.- . ..,•••••-•••••.• Brad, 1 didn't get your e-mail until I got in this morning (Friday) so it was too late....you did mean it took place this morning, right? Anything interesting? On 7/30/09 6:06 PM, ""Bmdley J. Edwards"" wrote: Michele, I forgot to tell you that I have a hearing in Hafele's courtroom (1113 1 think) at 8:30 on our motion to add punitive damages. Should be some interesting things said for you. Things that have not been said before. Bradley J. Edwards Partner Rothstein Rosenfeld( Adler] Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 facsimile From: Michele Dargan [mailto Sent: Wednesday, July 29, 2009 1:48 PM To: Bradley J. Edwards Subject: Re: Epstein Brad, We have no way of getting the members or the banned members lists. relc 1/ICK)ncemenIt524MCQUSti I ingsfri ialInnk 10". ..ndenntsiebAnill~eMnilComcm him ( ; orD( II:6/2010 le. 10.9 PM) 11080 EFTA01100896 Maileontoithitn However, I spoke to Donald Trump today — nothing like getting it from the horse's mouth! Anyway, he said Epstein is not a member and would not confirm or deny that he ever was a member. He would not comment at all (which is very rare for him) on whether or not Epstein got booted from the club or if he had recruited girls from Mar-A-Lago. Sony 1 couldn't be more help. 1 really thought that he would say something. Ile usually does comment for all of our stories. That's why this was quite unusual. If you get any info, please pass it on....like if any info comes out during depos of anything related to Epstein getting booted from the club or about him recruiting girls from there. You know 1 will nm with it! Michele On 7/28/09 9:28 AM, ""Bradley J. Edwards" wrote: Hi Michele, I was wondering if you were able to get a members list at the Maralago, and even more importantly if you were able to get a list of banned members from the Maralago? Rumor has it that he was banned for having sex with and attempting to have sex with minors at the club, and we already know of certain minors that he took from the club to his house. I will take a deposition of someone there if we need to do that to get the true information on this, but there are so many depositions to take in this case (and we arc setting them right now around the country) that I would like to avoid this one if we could get the info another way. Thanks Bradley J. Edwards Partner Rothstein Rosenfeldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 Zile MelMocuments%20and%20Secitogs/12ial/Desktooff... ooknocsichloiliendley_tdo-ards012129^eMoileolocni.hint (2 of 3)111/6/2010 10:10:54 PM] 11081 EFTA01100897 L.Iwaids1)I I I 29AeMa i:Coolcoit Michele Dugan, stair writer Palm Reach Daily News phone fax Gk /dCVDocmncnti%20atd%2ptclliup/ftiolpkxknµJE. xinkei sltMail MailConleal.lnm (3 of 3)11i/6/20(0 10.10:54 PM) 11082 EFTA01100898 MaalConleio Mm From: Bradley J. Edwards Sent: Jul 30, 2009 14:36:23 'fo: Michele Dargan Cc: Bcc: Subject: RE: Epstein Thank you. We have our answer then. All the pieces are public record - Complaint riled by Josephsberg regarding Epstein being at the club with Ghislaine Maxwell and taking a 15 year old home with him, a newspaper article that indicated he was banned for similar conduct (don't remember who published it but I read it a few months back), and a no comment from Trump. Ile's banned. Don't worry, we will get the official word. We are setting many depositions soon and certain people that will be set will know that information. 1 will keep you informed. Good work. I'll be in touch. Bradley J. Edwards Partner Rothstein Rosenfeldt Adled Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 facsimile From: Michele Dargan [mato- Sent: Wednesday, July 29, 2009 1:48 PM To: Bradley J. Edwards Subject: Re: Epstein Brad, filc./IICYDocoottnts%2(laoi%20Scoingsftrial/Desktop/13. .00lcIlocSeeMal chluilComot him (1 of 3) (11/6/2010 11:30 11320 EFTA01100899 cMailiConictu Mot We have no way of getting the members or the banned members lists. However, I spoke to Donald Trump today - nothing like getting it from the horse's mouth! Anyway, he said Epstein is not a member and would not confirm or deny that he ever was a member. blc would not comment at all (which is very rare for him) on whether or not Epstein got booted from the club or if he had recruited girls from Mar-A-Lago. Sorry I couldn't be more help. I really thought that he would say something. He usually does comment for all of our stories. That's why this was quite unusual. If you get any info, please pass it °IL...like if any info comes out during depos of anything related to Epstein getting booted from the club or about him recruiting girls from there. You know I will run with it! Michele On 7/28/09 9:28 AM, ""Bradley J. Edwards"" wrote: Ili Michele, I was wondering if you were able to get a members list at the Maratago, and even more importantly if you were able to get a list of banned members front the Maralago? Rumor has it that he was banned for having sex with and attempting to have sex with minors at the club, and we already know of certain minors that he took from the club to his house. 1 will take a deposition of someone there if we need to do that to get the true information on this, but there are so many depositions to take in this case (and we arc setting them right now around the country) that I would like to avoid this one if we could get the info another way. Thanks Bradley J. Edwards Partner Rothstein Rosenfeldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 facsimile role INCYDocunicans%20and%20Sellielpf relating:SW(1We ..0NeDocileMat eMoilemticm Iran (2 of 3) tl I/6(2010 10.11:30 PM) 11321 EFTA01100900 fNiileo.Rcnt Son Mieltele Dugan, stair writer palm Beach Daily News phone fax file tifC1/13octonents9Q0on51420ScoingsffroliOcskloy/P. on/cOocaleMai Moilewonu.lion ()of]) I/6M/I0 IO I I.30 PM) 11322 EFTA01100901 Igmadenroothei. From: Bradley J. Edwards Sett: Jul 30, 2009 18:06:49 To: Michele Dugan Cc: Bee: Subject: RE: Epstein Michele,1 forgot to tell you that I have a hearing in Hatele's courtroom (1113 I think) at 8:30 on our motion to add punitive damages. Should be some interesting things said for you. Things that have not been said before. Bradley J. Edwards Partner Rothstein Rosenfeldt Adlerl Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 facsimile From: Michele Dargan imailto: Sent: Wednesday, July 29, 2009 1:48 PM To: Bradley J. Edwards Subject: Re: Epstein Brad, We have no way of getting the members or the banned members lists. However, I spoke to Donald Trump today - nothing like getting it from the horse's mouth! IlleVCl/Documents%20mKrA2USdiiisgsntialitesktup/E onicDocsieMageMW/Comoothiso( 1 of 3)1111612010 tat 1:30 PMt 11323 EFTA01100902 MadeOigcol !who Anyway, he said Epstein is not a member and would not confirm or deny that he ever was a member. He would not comment at all (which is very rare for him) on whether or not Epstein got booted from the club or if he had recruited girls from Mar-A-tag°. Sorry I couldn't be more help. I really thought that he would say something. He usually does comment for all of our stories. That's why this was quite unusual. If you get any info, please pass it on....Iike if any info comes out during delves of anything related to Epstein getting booted from the club or about him recruiting girls from there. You know I will run with it. Michele On 7/23/09 9:28 AM, ""Bradley J. Edwards"" wrote: Hi Michele, I was wondering if you were able to get a members list at the Maralago, and even more importantly if you were able to get n list of banned members front the Maralago? Rumor has it that he was banned for having sex with and attempting to have sex with minors at the club, and we already know of certain minors that he took from the club to his house. I will take a deposition of someone there if we need to do that to get the true information on this, but there are so many depositions to take in this case (and we are setting them right now around the country) that I would like to avoid this one if we could get the info another way. Thanks Bradley J. Edwards Partner Rothstein Rosenteldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, PL 33301 facsimile Michele Dugan, staff writer rac ///e1/1)ocuntoust420n1%2(Xtiellingilitialifksklop/E .oiVeLhx://cMail hluilConcenthun (2 or 3) (I 1/6/201010:11:30 pmi 11324 EFTA01100903 a .44,6colity,u.m., - .11 Daily News phone fax Id tu a a l/Doc nceits%20sodK2OStitingsflitalt(ksilopiti nokflooktviatlfallil chlittlettotent 1,110 (3 of 3)111/6/20I0 ID I I.30 PMJ 11325 EFTA01100904