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l 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 loudly and clearly against prosecutors seeing
your cooperation in this matter. If you have any questions, please do not hesitate to call. IACK A. GOLDBERGER CC: Gerald B. Lefcourt, Esq. Lilly Ann Sanchez, Esq. 2 08-80736-CV-MARRA RFP WPB 001693 EFTA00209872 i4a1 IA fit hIANUFACTLIPSER PAO 1.4AAL/FAC71REIVS OESVNATK)N Cc ARCRAF7 BOEING 72 7-
Page 28 of 36 the same act are intended to have the same meaning.") (quotation and citation omitted). Two Mann Act cases are particularly apt. In Hansen', Half, 291 U.S. 559 (1934), the Government charged the defendant with violating the Mann Act after she returned to the country with a man with who
mplaint, Jane Doe #101 asserted that Epstein had been convicted of state law crimes and, taking language directly from Alex Acosta's letter to Lilly Ann Sanchez, wrote that Epstein "is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such,
with relatively little disruption, continue to operate their highly lucrative business from any number of overseas locations"); • United States v. Hansen, 108 F. App'x 331 (6th Cir. 2004) (affirming district court order of pretrial release of defendant, a resident and citizen of Denmark-from where def
them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Datod: By: Dated: Dated: 711'4107 Dated: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY LILLY ANN SANCHEZ., ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA00076092 Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 10 of 15 Case 9:08-cv-8073
with relatively little disruption, continue to operate their highly lucrative business from any number of overseas locations"); • United States v. Hansen, 108 F. App'x 331 (6th Cir. 2004) (affirming district court order of pretrial release of defendant, a resident and citizen of Denmark-from where def
them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Datod: By: Dated: Dated: 711'4107 Dated: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY LILLY ANN SANCHEZ., ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA00095895 Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 10 of 15 Case 9:08-cv-8073
Entities connected to both Hansen and Ann Sanchez

Jeffrey Epstein
PERSONGerald Lefcourt
PERSON
Alexander Acosta
PERSON
United States
LOCATIONJack Goldberger
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Department of Justice
ORGANIZATION
Alan Dershowitz
PERSON
Jay Lefkowitz
PERSON
A. Marie Villafana
PERSONFBI
ORGANIZATIONRoy Black
PERSON
Lesley Groff
PERSON
Palm Beach Police Department
ORGANIZATIONJane Doe
PERSON
Kenneth Marra
PERSON
Ken Starr
PERSON
George W. Bush
PERSON