Subject: Re: Epstein

From: To: Subject: Re: Epstein Date: Wed, 28 May 2008 03:45:06 +0000 Importance: Normal Aaaargh. The statute of limitations issue is the state statute of limitations. I think joe says it is two years. The issue is implicated in two ways. First, because of the state's leniency for the first set of girls, the second set have been presented only to us for prosecution. If we cannot go forward, then there will be no prosecution of those crimes. (In response to the argument that joe should just present them now, we believe that some of the victims are unknown to the defense and disclosing them further weakens our case by allowing them to depose and harass those victims.) Second, our "state resolution" of the case requires epstein to plead to something that hasn't been charged yet so further delay will allow him to escape one of the terms of the deal he signed several months ago. (There also is a sol on the private cause of action under 2255 pursuant to which he must pay damages