Epstein Secrets

ule. This is not a matter of mere technical non-compliance. Actual notice cannot be used to override the basic requirements of Rule 4(e)(2)(B). As the Eleventh Circuit has noted, "actual notice of a suit does not dispose of the requirements of service of process." Jackson v. Warden, FCC Coleman-USP, 259 Fed. Appx

ove, and that the Court grant such other and further relief as deemed necessary and proper. Respectfully submitted, s/Christopher E. Knight Lilly Ann Sanchez Fla. Bar No. 195677 Christopher E. Knight Fla. Bar No. 607363 Helaine S. Goodner Fla. Bar No. 462111 FOWLER WHITE BURNETT P.A. Espirito Santo

individual woman. As the 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

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-

constitutional authority to address criminal contempt, absent statutory authority.") citing In re Hipp and Walton v Countrywide Homes Loans. While the Eleventh Circuit has recently reviewed a bankruptcy court's ruling imposing both civil and punitive sanctions in In re McLean, 794 F. 3d 1313 (11th Cir. 2015), it di

ge 2 of 4 Subject: RE: Notice of filing Date: Tuesday, December 7, 2010 at 4:37:23 PM Eastern Standard Time From: Natalie A. Trompet To: Lilly Ann Sanchez CC: Joseph L. Ackerman, Jr. We are working on this now and it will go in Fed Ex tonight for priority overnight delivery. Thank you. N Origina

", to the extent discernable, every case brought under §2422(b) in this district includes use of the intemet. There are only four reported cases in the Eleventh Circuit involving use of the phones only: three of them concern telephone calls to travel agencies advertising overseas underage sex touriand involved expli

ng. I welcome any questions or comments you may have and am available to discuss this and any other issues at your earliest convenience. cc: Lilly Ann Sanchez, Esq. Roy Black, Esq. Very truly yours, Goudf? Gerald B. Lefcourt a t41^- 1 A— l t Alan Dershowitz MIA_CEOS_00099 EFTA00191466

ts production in this case. With regard to item (1) — correspondence with Epstein, the Government withheld the correspondence pending a ruling from the Eleventh Circuit on Epstein's motion to stay production of these materials. With regard to the other items, the Government produced 14,825 pages of documents to the

Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert

ur Office prevails on that Issue, the victims would obviously have no claim under the CVRA. The victims would then pursue their appellate rights in the Eleventh Circuit. If, however, the victims prevail on that issue, then your Office would take "no position" on the remedy sought by the victims for the violation of

vision of your Office. It has been our understanding for quite some time that he frequently corresponded with Epstein's attorneys, especially Lily Ann Sanchez, during the plea discussions, and it is our understanding that he left your Office around the time the non-prosecution agreement was signed. Our pr

009 WL 2567831, fn. I (E.D. Cal. Aug. 18, 2009). U.S.' Zane, 2009 WL 2567832, fn.l (E.D. Cal. Aug. 18 2009). As to the meaning of "actual damages," the Eleventh Circuit in McMillian i t F.D.I.C., 81 F.3d 1041, 1055 (I I th Cir.1996)3, succinctly explained: 3 In McMillian the I 1th Circuit was faced with the task of

ITED STATES ATTORNEY Dated: By: Dated: 77a9-- Dated: Dated: ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 it. EFTA00233437 By signing this agreement, Epstein asserts and certifies that the above has bee

tations to the victims — and having induced reliance by the victims—the Government is stopped from taking a different position now. As explained by the Eleventh Circuit, to make out a claim of estoppel against the Government, a party must adduce evidence of the following: (I) words, conduct, or acquiescence that in

STA UNITED STATES ATTORNEY Dated: Dated: 74/3 — Dated: Dated: By: ASSISTANT U.S. TEO GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA00229978 Case 9:08-cv-80736-KAM Document 48-5 Entered on FLSO Docket 03/21/2011 Page 9 or 15

tations to the victims — and having induced reliance by the victims—the Government is stopped from taking a different position now. As explained by the Eleventh Circuit, to make out a claim of estoppel against the Government, a party must adduce evidence of the following: (I) words, conduct, or acquiescence that in

Dated: By: Dated: 74/9 — Dated: Dated: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY GERALD LISPCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN ••• Page 7 of 7 08-80736-CV-MARRA 000732 EFTA00230556 1 Case 9:08-cv-80736-KAM Document 48-5 Entered on F

September 30, 2019, CVRA petitioner “Jane Doe 1” filed in her true name a petition for a writ of mandamus in the United States Court of Appeals for the Eleventh Circuit, seeking review of the district court’s order denying all of her requested remedies. In its responsive brief, the government argued that “as a mat

fice for United States Attorneys, the component charged with providing close liaison between the Department and the U.S. Attorneys. Another, Lilly Ann Sanchez, had served in the USAO and as a Deputy Chief in the Major Crimes Section before leaving in 2005. In August 2007, immediately after the USAO offer