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atement reveals how inapposite a federal prosecution is to the facts in this case. Importantly, we note that the CEOS review was conducted prior to the Supreme Court's very recent decisions in Santos and Cuellar, which we believe—illuminating as they do the Court's interpretive methodology when it comes to federal
erson ..."). § 2423(b) is not such a statute. Federal court decisions watering down the "for the purpose of " requi ment fly in the face of the two Suprems Court decisions addressing that element. See Hansen'. Huff, 291 U.S. 559 (1934); Mortensen. United States, 322 U.S. 369 (1944). Santos and Cuellar speak l
rney I Member of New Jersey & Florida Bars May 10, 2007 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 VIA HAND-DELIVERY JEGE, Inc. ("JEGE') and Hyperion Air, Inc. ("Hyperion") Dear Ms. IM I write as counsel to the above noted entities to respond to the subpoenas dated April 24,
have rejected the reasonable mistake of age defense to statutory rape absent some express legislative directive." Id. (citations omitted). Further, the "Supreme Court has recognized that the legislature's authority to define an offense includes the power `to exclude elements of knowledge and diligence from its de
gust 6, 2004, Defendants EPSTEIN and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft ownec ndant JEGE, INC. #. On August 19, 2004, Defendants EPSTEIN and traveled from Van Nuys, California to Palm Beach County, Florida aboard the Boeing 727 aircraft owned
have rejected the reasonable mistake of age defense to statutory rape absent some express legislative directive." Id. (citations omitted). Further, the "Supreme Court has recognized that the legislature's authority to define an offense includes the power `to exclude elements of knowledge and diligence from its de
Page: EFTA02857732_p5 →the indictment has been revised to group the overt acts related to each Jane Doe. BEach of the airplanes is held in a separate "shell corporation," JEGE, Inc., and Hyperion Air, Inc. Epstein is the sole shareholder in both of these corporations and they serve no purpose other than to hold and maintain the
Page: EFTA02857732_p29 →have rejected the reasonable mistake of age defense to statutory rape absent some express legislative directive." Id. (citations omitted). Further, the "Supreme Court has recognized that the legislature's authority to define an offense includes the power `to exclude elements of knowledge and diligence from its de
Page: EFTA02857810_p5 →ach County, Florida aboard the Boeing 757 aircraft owned by Defendant JEGE, INC. fiEach of the airplanes is held in a separate "shell corporation," JEGE, Inc., and Hyperion Air, Inc. Epstein is the shareholder in both of these corporations and they serve no purpose other than to hold and maintain the airp
Page: EFTA02857810_p28 →Entities connected to both Supreme Court and JEGE, Inc.

Jeffrey Epstein
PERSON
United States
LOCATION
Donald Trump
PERSON
George W. Bush
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Prince Andrew
PERSON
Scarlett Johansson
PERSON
Wilbur Ross
PERSON
Samantha Power
PERSON
Joe Biden
PERSON
Virginia Giuffre
PERSON
Bill Clinton
PERSON
Colorado
LOCATION
Eric Trump
PERSONMaria Farmer
PERSONthe Southern District
LOCATION
Barry Diller
PERSON