From: ' To:' Et Subject: RE: 2020-03-09, GM, prosecution memo, Ipdate.docx Date: Thu, 12 Mar 2020 16:29:55 +0000 Thanks-- talk soon. I have to jump to another call as soon as we finish this one, but if there are follow ups I should be free later this afternoon. From: Sent: Thursday, March 12, 2020 12:19 PM To: Subject: RE: 2020-03-09, GM, prosecution memoipdate.docx > I would just send this to the chiefs once you're all set with it — I don't think has been able to respond to an Epstein email all week. And of course I'll dial you in at 12:30! Call you in 10 mins. From: Sent: Thursday, March 12, 2020 09:44 To: Cc: Subject: RE: 2020-03-09, GM, prosecution memo, npdate.docx Thanks. do you have any comments before this goes to the chiefs. Let's keep discussing these issues as we pass the draft up. On the perjury question, I think when we have time we should just print the transcript excerpts and talk through them as a team. I think the child endangerment issue is a tough call, and definitely worth continuing to discuss. > From: Sent: Wednesday, March 11, 2020 9:05 PM To: ) Cc: I <a Subject: 2020-03-09, GM, prosecution memo,Epdate.docx I'm very sorry this took so much longer than I expected, but it's good to go from me, and per our usual I just made edits rather than peppering it with track changes or thought bubbles. Two general thoughts, neither of which I think need to hold it up but just to flag (and potentially talk through with chiefs). First, I continue to be torn about using child endangerment as an underlying sexual activity for which any person could be charged. I think the Fourth Circuit really has the better of the argument on that, and I think a reasonable jury certainly could find that the sexual activity of having a girl who is 14 or 15 or 16 even just massage the feet of a grown man who's masturbating would be "likely to be injurious to the physical, mental, or moral welfare" of the girl and that such conduct would