Epstein Secrets

ll of the terms and conditions of the [Deferred Prosecution] Agreement, as modified by the United States Attorney's December 19, 2007 letter to Ms. Sanchez by close of business on Monday, June 2, 2008, the SDFL will elect to terminate the Agreement." Id., p.1 The Truth: • The Deferred Prosecution Agre

nt can be found guilty of that offense only if...the defendant believed that such individual was less than (18) years of age..."); United States v. Murrell, 368 F.3d 1283, 1286 (I I1° Cir. 2004) (§ 2422(b) requires that the defendant knowingly target a minor). Importantly, then, all the elements must be

der to sustain a conviction. In particular, § 2422(b) requires that the defendant specifically intended to target a minor. ke,ligh, United States v. Murrell, 368 F.3d 1286 (11th Cir. 2004) ("[T]o prove an attempt the government must first prove that [defendant], using the Internet, acted with a specific

Lefcourt and Lilly Ann Sanchez, both counsel to Jeffrey Epstein, that as a result of a telephone conversation had amongst you, Mr. Lefcourt and Ms. Sanchez, you are now seeking documents reflecting: 1. Ownership of JEGE and Hyperion; 2. Assets of JEGE and Hyperion; and 3. Employees of JEGE and Hyperio

statute makes clear, the essence of this crime is 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

NEY DELIVERY BY FACSIMILE Lilly Ann Sanchez Fowler White Burnett, PA 1395 Stickel! Ave, le Floor Miami, FL 33131 Re: Jeffrey Epstein Dear Ms. Sanchez: 99N£ !Street USK FL 13112 003)961.9100 - Tetteatle O03)3366444 - FaesteSk December 19, 2007 I write to follow up on the December le meeting be

facility (the mail, phone, or intemet)—not thereafter—and the scienter element must be present while the facility is being used. See United States'. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004) ("[T]he government must first prove that [Defendant], using the Internet, acted with a specific intent to per

erald Lefcourt and Lilly Sanchez). 8/31/2007--Meeting (US: and 9/7/2007--Meeting (US: Alexander Acosta, DEF: Kenneth Starr, Jay Lefkowitz, Lilly Sanchez). EFTA01718570 9/12/2007--Meeting (US: and , DEF: Jay Lefkowitz, Gerald Lefcourt and Jack Goldberger, STATE OF FLORIDA: Barry Krisher and Lanna

e.g. with himself or a third party), without then actually committing any sex act himself, he would nevertheless violate §2422(b)." United States v. Murrell, 368 F.3d 1283, 1286 (11th Cu. 2004). See also United States v. Bailey 228 F.3d 637, 639 (61° Cir. 2000) ("Congress has made a clear choice to crimi

ce, a conviction under the statute only requires a finding that the defendant had an intent to persuade or to attempt to persuade.’ United States v. Murrell 368 F.3d 1283, 1287 (11th Cir. 2004) (citing United States v. Bailey, 228 F.3d 637, 638-39 (6th Cir.2000)). Thus, the targeted criminal conduct must

e statute makes clear, the essence of this crime is 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(b) ‘requires the specific intent to commit illegal sexual acts r

an “mere solicitation;” it must be more than an offer or the providing of an opportunity to engage in prohibited conduct. See, e.g,. United States v. Sanchez-Berrios, 424 F.3d 65, 76-77 (1* Cir. 2005); United States v. Brown, 43 F.3d 618, 625 (11™ Cir. 1995). The government cannot fairly, or consistent wit

e, a conviction under the statute only requires a finding that the defendant had an intent to persuade or to attempt to persuade.' United States v. Murrell 368 F.3d 1283, 1287 (11th Cir. 2004) (citing United States v. Bailey, 228 F.3d 637, 638-39 (6th Cir.2000)). Thus, the targeted criminal conduct must

statute makes clear, the essence of this crime is 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(b) `requires the specific intent to commit illegal sexual acts

"mere solicitation;" it must be more than an offer or the providing of an opportunity to engage in prohibited conduct. See, e.g,. United States v. Sanchez-Berrios, 424 F.3d 65, 76-77 (ls' Cir. 2005); United States v. Brown, 43 F.3d 618, 625 (11th Cir. 1995). The government cannot fairly, or consistent