LAW OFFICES OF GERALD B. LEFCOURT, P.C. (212) 737-0400 PRIVILEGED & CONFIDENTIAL ATTORNEY WORK PRODUCT MEMORANDUM DATE: June 13, 2007 FROM: FAF TO: GBL SUBJECT: • Again, this is not about bashing the victims. That being said, in evaluating whether this is an appropriate ("righteous") case to be brought federally it is important to evaluate your witnesses, their allegations, and the plausibility/believability of those allegations. In other words are these the type of "victimslwitnesses the Office wants to step out on a limb for and try and stretch federal criminal statutes beyond their intended purpose. • We have gone into detail with you on many occasions concemi credibility problems with which you are faced when it comes t . We suspect you do not want us to rehash those issues, although if you do we would be more than willing to. o Drug and alcohol use — bragged about it on her o Arrest for marijuana possession o Thefts from just days after the disposition of her marijuana case (and presumably during the period between her arrest and disposition) o Lied about thefts o Lied to get her job at - o Was 18 at the time of the incident — demonstrative proof • That being sai ere are other considerations that must be taken into account with respect to Ms. o First, we do not know what your dealings, if any, have been with Ms. M, but if they were anything like Det. Recarey's dealings, you can see that she was in no way "traumatized" by the alleged incidents in question u s ` EFTA00605219