Epstein Secrets

SILVERSTEIN EOWARO 5. NATHAN PASQUALE J. RUFOLO JOHN P. INGLESINO LINDA A. ELFENBEIN TERRY L. TRANTINA JOHN P. WYCISKALA ALAIN WOMAN LISA 0. TAYLOR MARK W. RUFOLO STEVEN D. GORELICK Alan Dershowitz, Esq. Hari 76 UVINGSTON AVENUE ROSELAND, NEW JERSEY 07060 November 19, 2007 LING LAU MELIS

ign country for sexual purposes, or for that matter, that he traveled to a foreign country to engage in illicit sexual activities. 1 Instructive is the Eleventh Circuit Pattern Jury Instruction 70.4 which states that the defendant can be found guilty of § I956(aX3)(A) only If (1) he knowingly conducted a financial transacti

e. Mr. Epstein did not receive money or funds from any criminal conduct which he then used in a financial transaction. 5_ee, e.g., United States v, Taylor, 239 F. 3d 994 (9* Cir. 2001) (defendant charged with running an illegal escort service and using proceeds from that business to pay credit cards us

ay show that Mr. Epstein paid for sexual services, he most certainly did so with untainted, legitimately earned funds. • • • • s Instructive is the Eleventh Circuit Pattern Jury Instrucuun 70.4 which states that the defendant can be found guilty of § 1956(aX3XA) only if (I) he knowingly conducted a financial transaction

ase. Mr. Epstein did not receive money or funds fmm any criminal conduct which he then used in a financial transaction. 5_ee, e.g., United Stotts,. Taylor, 239 F. 3d 994 (9th Cir. 2001) (defendant charged with running an illegal escort service and using proceeds from that business to pay credit cards u

ay show that Mr. Epstein paid for sexual services, he most certainly did so with untainted, legitimately earned funds. • • • • s Instructive is the Eleventh Circuit Pattern Jury Instrucuun 70.4 which states that the defendant can be found guilty of § 1956(aX3XA) only if (I) he knowingly conducted a financial transaction

its reaching the same conclusion. Jones , 471 F.3d at 538-39 (citing United States v. Griffith , 284 F.3d 338, 351 (2d Cir. 2002); United States v. Taylor , 239 F.3d 994, 997 (9th Cir. 2001); United States v. Scisum , 32 F.3d 1479, 1485-86 (10th Cir. 1994); United States v. Hamilton , 456 F.2d 171, 173

use of that facility to entice a minor to engage in "any sexual activity for which any person can be charged with a criminal offense." According to the Eleventh Circuit Pattern Jury Instruction, the determination of what sexual activity is criminal is governed by Florida law. Florida law bars a person from procuring anyone

its reaching the same conclusion. Jones , 471 F.3d at 538-39 (citing United States v. Griffith , 284 F.3d 338, 351 (2d Cir. 2002); United States v. Taylor , 239 F.3d 994, 997 (9th Cir. 2001); United States v. Scisum , 32 F.3d 1479, 1485-86 (10th Cir. 1994); United States v. Hamilton , 456 F.2d 171, 173

use of that facility to entice a minor to engage in "any sexual activity for which any person can be charged with a criminal offense." According to the Eleventh Circuit Pattern Jury Instruction, the determination of what sexual activity is criminal is governed by Florida law. Florida law bars a person from procuring anyone

e in the ease. Mr. Epstein did not receive money or funds from any criminal conduct which he then used in a financial transaction. United States', Taylor 239 F. 3d 994 (9th Cir. 2001) (defendant charged with running an illegal escort service and using proceeds from that business to pay credit cards us

vidence may show that Mr. Epstein paid for sexual services, he most certainly did so with untainted, legitimately earned funds. • 5 Instructive is the Eleventh Circuit Pattern Jury Instruction 70.4 which states that the defendant can be found guilty of § 1956(a)(3XA) only if (I) he knowingly conducted a financial transacti

its reaching the same conclusion. Jones , 471 F.3d at 538-39 (citing United States v. Griffith , 284 F.3d 338, 351 (2d Cir. 2002); United States v. Taylor , 239 F.3d 994, 997 (9th Cir. 2001); United States v. Scisum , 32 F.3d 1479, 1485-86 (10th Cir. 1994); United States v. Hamilton , 456 F.2d 171, 173

use of that facility to entice a minor to engage in "any sexual activity for which any person can be charged with a criminal offense." According to the Eleventh Circuit Pattern Jury Instruction, the determination of what sexual activity is criminal is governed by Florida law. Florida law bars a person from procuring anyone

its reaching the same conclusion. Jones , 471 F.3d at 538-39 (citing United States v. Griffith , 284 F.3d 338, 351 (2d Cir. 2002); United States v. Taylor , 239 F.3d 994, 997 (9th Cir. 2001); United States v. Scisum , 32 F.3d 1479, 1485-86 (10th Cir. 1994); United States v. Hamilton , 456 F.2d 171, 173

use of that facility to entice a minor to engage in "any sexual activity for which any person can be charged with a criminal offense." According to the Eleventh Circuit Pattern Jury Instruction, the determination of what sexual activity is criminal is governed by Florida law. Florida law bars a person from procuring anyone

its reaching the same conclusion. Jones , 471 F.3d at 538-39 (citing United States v. Griffith , 284 F.3d 338, 351 (2d Cir. 2002); United States v. Taylor , 239 F.3d 994, 997 (9th Cir. 2001); United States v. Scisum , 32 F.3d 1479, 1485-86 (10th Cir. 1994); United States v. Hamilton , 456 F.2d 171, 173

use of that facility to entice a minor to engage in "any sexual activity for which any person can be charged with a criminal offense." According to the Eleventh Circuit Pattern Jury Instruction, the determination of what sexual activity is criminal is governed by Florida law. Florida law bars a person from procuring anyone