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rt its argument, the Government relies on the presumption "that Congress intends to change the law when it enacts amendments." DE 401-2 at 8 (citing Bailey v. United States 52 Fed. Cl. 105, 110 (2002)). According to the Government, the fact that Congress 19 EFTA00799906 Case 9:08-cv-80736-KAM Docume
informed me that any resolution of the criminal matter was imminent at that time, nor even that such a resolution was being contemplated. In fact, Villafafia gave me the impression that the Federal investigation was on-going, very expansive, and continuously growing, both in the number of identified vict
Florida. Neither Doe 1 nor Doe 2 had any reason to believe that they were victims of a state crime that was being prosecuted. Based on everything Villafafia said, and could not say, there was no possible way I could have believed that this state plea could affect the federal investigation or the rights
se calls, the line prosecutor continually created the impression that no resolution of the case was imminent: During the telephone calls I had with Villafafia between mid and late June 2008, she never informed me that previously, in September 2007, the U.S. Attorney's Office had reached a non-prosecution
the communication itself—not the resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point: The defendant in Bailey contended that attempt under § 2422(6) 'requires the specific intent to commit illegal sexual acts rather than just the intent to persuade or solic
orida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 RE: JEGE, Inc. ("JEGE") and Hyperion Air; Inc. ("Hyperion") Dear Ms. Villafafia: Thank you very much for your letter dated May 15, 2007 concerning the subpoenas issued to JEGE, Inc. and Hyperion Air, Inc., along with your agree
enge to the statute: "The statute only applies to those who `knowingly' persuade or entice, or attempt to persuade or enticesminors. United States' Bailey, 228 F.3d 637, 639 (6th Cir. 2000). See United States'. Pcmfil, 338 F.3d 1° Indeed, this last problem is best illustrated by any cal may claim to h
of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Jeffrey Epstein Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafafia: We write as counsel to Jeffrey Epstein to follow-up on our meeting on June 26, 2007. We thought the meeting was extremely productive and appreciat
enge to the statute: "The statute only applies to those who `knowingly' persuade or entice, or attempt to persuade or entice minors. United States' Bailey, 228 F.3d 637, 639 (6th Cir. 2000). See United States' Panfil, 338 F.3d 1° indeed, this last problem is best illustrated by any calls Haley Robson m
of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Jeffrey Epstein Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafafia: TELEPHONE (alai 737-0400 FACSIMILE 1212)124384192 We write as counsel to Jeffrey Epstein to follow-up on our meeting on June 26, 2007. We thou
— communicate or otherwise interact improperly with persons who turn out to be minors. A prosecution of Mr. Epstein would violate the teachings of Bailey and Panfil. As we believe we persuaded you at the June 26th meeting, Mr. Epstein never targeted minors. On the contrary, what he did — at worst — w
of Florida 500 South Australian Avenue, Suite-400 West Palm Beach, Florida 33401 Jeffrey Epstein Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafafia: We write as counsel to Jeffrey Epstein to follow-up on our meeting on June 26, 2007. We thought the meeting was extremely productive and appreciat
said to act purposefully if 'he consciously desires that result, whatever the likelihood of that result happening from his conduct.' United States !Bailey, 444 U.S. 394, 404 (1980), quoting United Slates u United Slates Gypsum Co., 438 U.S. 22, 445 (1978).7 The Supreme Court has repeatedly interpreted
2/10/2016 Page 1 of 26 EXHIBIT 43 EFTA00184603 Case 9:08-cv-80736-KAM Document 361-43 Entered on FLSD Docket 02/10/2016 Page 2 of 26 Dear Ms. Villafafia and Mr. Lourie: LAW OFFICES Of GERALD B. LuttatiRT, P.C. A PROFESSIONAL CORPORATION 148 EAST 70'" STREET NEW YORK, NEW YORK 10021 GERALD B. LER
Entities connected to both Bailey and Ann Marie C. Villafafia

Jeffrey Epstein
PERSON
United States
LOCATION
George W. Bush
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
Prince Andrew
PERSON
Virginia Giuffre
PERSON
Ghislaine Maxwell
PERSON
Scarlett Johansson
PERSON
Donald Trump
PERSONthe Southern District
LOCATION
Alexander Acosta
PERSON
Julie K. Brown
PERSONJane Doe
PERSON
A. Marie Villafana
PERSONFBI
ORGANIZATION
Bradley Edwards
PERSON
Joe Biden
PERSONMaria Farmer
PERSONJack Goldberger
PERSON