From: ' (USANYS)" )" <• To: Cc: "-(USANYS)" Subject: RE: updates Date: Sat, 06 Jul 2019 20:39:51 +0000 Importance: Normal )'I From Geoff: Where we currently say "In fall 2007, the defendant entered into a non-prosecution agreement with the SDFL in connection with the conduct at issue in that investigation -- i.e., the abuse of numerous minor girls in the Palm Beach area." He would like us to change to: "In fall 2007, the defendant entered into a non-prosecution agreement with the SDFL in connection with the conduct at issue in that investigation, which the non-prosecution agreement identifies as including investigations into the defendant's abuse of minor girls in the Palm Beach area." His concern is their investigation (like ours) involved some girls who were 18 at the time and also we don't want to ourselves characterize the scope of the NPA. Fix the typo: " the defendant cannot overCOME the statutory presumption in favor of detention in this case." "As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. § 3283, which permits the prosecution of sex offenses against children at any time during the lifetime of the minor victim." per our discuss, let's modify this language "he currently is a registered sex offender." Geoff asks "Is it worth pointing out that, I believe, he is in the highest risk category for re-offense?" What about pointing out that he, at least as of 2011, has no appreciation of the gravity of his offense or necessarily re- offense. This is from a NY Post article: "I'm not a sexual predator, I'm an offender. It's the difference between a murderer and a person who steals a bagel." MI think this is a good suggestion "GEOFFREY S. BERMAN ACTING United States Attorney" EFTA00083658