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This document is a page from the Minnesota Law Review (Vol 103), submitted as an exhibit to the House Oversight Committee by attorney David Schoen (associated with Jeffrey Epstein). The text discusses legal theories regarding the judicial and administrative review of decisions *not* to charge (prosecutorial discretion), contrasting the lack of such mechanisms in the U.S. with their prevalence in the E.U. and England. This legal argument is relevant to the controversy surrounding the non-prosecution agreement in the Epstein case and the rights of his victims.