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,
imillaualacl(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!!!!
Maim' 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: waisrae ldrat
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 Bradom 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: nricaunatta
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 ?
atisest
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.WegESengl2WdallaabalLCAPIIISSUI20.02a2Z001=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:
litplAvww 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
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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 OFFENDER TM.
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,
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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
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