Memorandum Subject Operation Leap Year: Second Addendum to Prosecution Memorandum USAO No. 2006R01181 September 13, 2007 I a Pe/e & Z/11/o4 VO To R. Alexander Acosta United States Attorney First Assistant U.S. Attorney Deputy Chief, Criminal Division, West Palm Beach Chief, Criminal Section I, Northern Division, WPB From AUSA, Northern Region, WPB This memorandum addresses the changes made to the Operation Leap Year indictment package, which incorporate comments from the last review. Some changes are stylistic and others are substantive. For strategic reasons, I would like to present the indictment to the grand jury on Tuesday, September 25, 2007. The first section of this memorandum discusses the stylistic changes and the second section discusses the substantive changes, including the new victims who have been added. [NB: THIS MEMORANDUM WAS AMENDED ON FEBRUARY 19, 2008 TO CORRECT THE NUMBERING OF THE JANE DOE'S IN ACCORDANCE WITH THE THIRD ADDENDUM TO THE PROSECUTION MEMORANDUM) A. Stylistic Changes The biggest stylistic change appears in the overt acts section of Count 1. In the original EFTA00234505