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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 such elasticity in federal criminal stat
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,
prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen v. United States , 322 U.S. 369, 374 (1944); Crespo v. United States , 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of
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
prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen v. United States , 322 U.S. 369, 374 (1944); Crespo v. United States , 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of
Page: EFTA02857732_p13 →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 →prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen v. United States , 322 U.S. 369, 374 (1944); Crespo v. United States , 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of
Page: EFTA02857810_p12 →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 Mortensen and JEGE, Inc.

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
George W. Bush
PERSONHyperion Air, Inc.
ORGANIZATIONLeon Black
PERSON
Alexander Acosta
PERSON
Department of Justice
ORGANIZATION
Alan Dershowitz
PERSONGerald Lefcourt
PERSONJane Doe
PERSONMaria Farmer
PERSON
Alfredo Rodriguez
PERSON
David Rodgers
PERSON
Hyperion
ORGANIZATIONJack Goldberger
PERSONRoy Black
PERSON
Marc Rich
PERSONAnn Sanchez
PERSONFBI
ORGANIZATION