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were over 18, some were under, and the identity of a given masseuse on a given day depended entirely on who was available or who was brought to Mr. Epstein home, unsolicited, by a friend. There was, in short, no deliberate effort to target underage girls; to the extent any underage girls visited Mr. Ep
tirely on who was available or who was brought to Mr. Epstein home, unsolicited, by a friend. There was, in sh
hat each has brought a civil lawsuit against Mr. Epstein, with Ms. and her family seeking $50 million from Mr. Epstein, their testimony against Mr. Epstem is per se suspect. The lawyer representing the "victims" made a public statement conceding that they had lied about their ages and then dismissed t
ED STATES DEPARTMENT OF JUSTICE IN THE MATTER OF JEFFREY E. EPSTEIN This submission addresses (i) whether e
mes such that Federal jurisdiction is necessary."). EFTA00225908 • • • SUBMISSION TO THE UNITED STATES DEPARTMENT OF JUSTICE IN THE MATTER OF JEFFREY E. EPSTEIN This submission addresses (i) whether existing federal statutes, 18 U.S.C. §§ 2422(b), 1591 and 2423, apply to the conduct at issue; and (ii) wheth
ED STATES DEPARTMENT OF JUSTICE IN THE MATTER OF JEFFREY E. EPSTEIN This submission addresses (i) whether ex
t, the Government must prove that Mr. Epstein had the specific intent to target a known minor at the time of the call. See Offense Instructions 80, Eleventh Circuit Pattern Jury Instructions-Criminal, (2003), see supra part H.A.I. ("The Defendant can be found guilty of that offense only if . . . the Defendant believed
orney The United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. Sloman, Menchcl and Lourie and Ms. Villafatia: TELEPHONE 12121737.0400 FACSIMILE As you are aware, we represent Jeffrey E. Epstein
rce is involved, the victim must be under 16 years old for a prosecution to lie. -.1-12C1)1 ) We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This was absolutely not the case and we will be prepared to discuss at our meeting the objective evidence de
We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This was
e, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. Sloman, Menchcl and Lourie
e, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. Sloman, Menchcl and Lourie
9th Cir. 2001) (defendant charged with running an illegal escort service and using proceeds from that business to pay credit cards $ Instructive is Eleventh Circuit Pattern Jury Instruction 70.4 which states that the defendant can be found guilty of § 1956(a)(3)(A) only if ( I) he knowingly conducted a financial transac
tuted States Attorney's Othce Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Dear Messrs Re: Jeffrey E. Epstein • and Ms.I=M: As you are aware, we represent Jeffrey E. Epstein in connection with your ongoing investigation. We write to you in advance of our Jun
ance unless force is involved, the victim must be under 16 years old for a prosecution to lie. We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This was absolutely not the case and we will be prepared to discuss at our meeting the objective evidence de
West Palm Beach, Florida 33401 Dear Messrs Re: Jeffrey E. Epstein • and Ms.I=M: As you are aware, we rep
West Palm Beach, Florida 33401 Dear Messrs Re: Jeffrey E. Epstein • and Ms.I=M: As you are aware, we repr
We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This was
9th Cir. 2001) (defendant charged with running an illegal escort service and using proceeds from that business to pay credit cards 5 Instructive is Eleventh Circuit Pattern Jury Instruction 70.4 which states that the defendant can be found guilty of § 1956(a)(3XA) only if (1) he knowingly conducted a financial transacti
00 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Dear and Re: Jeffrey E Epstein and MIS ASS As you are aware, we represent Jeffrey E. Epstein in connection with your ongoing investigation. We write to you in advance of our June 26, 2007, meeting to address some of the concerns that have b
ance unless force is involved, the vice must be under 16 years old for a prosecution to lie. 3 We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This vra absolutely not the case and we will be prepared to discuss at our meeting the objective evidence de
0 West Palm Beach, Florida 33401 Dear and Re: Jeffrey E Epstein and MIS ASS As you are aware, we repre
ein and MIS ASS As you are aware, we represent Jeffrey E. Epstein in connection with your ongoing investig
We understand the Office has taken the view that Mr. Epstein targeted underage high school students. This vra
9th Cir. 2001) (defendant charged with running an illegal escort service and using proceeds from that business to pay credit cards s Instructive is Eleventh Circuit Pattern Jury Instruction 70.4 which states that the defendant can be found guilty of § 1956(a)(3)(A) only if (I) he knowingly conducted a financial transact
ange of plea on June 30, 2008 but did not have any contact with any member of the SAO that day. Later, when the issue arose regarding whether or not Epstein was taking the position that the NPA included USA Acosta's December 2007 letter, I contacted Ms. Behlolavek and SA Krischer to obtain a copy of wha
pstein would be pleading guilty on June 30, 2008, I would not release the witness (id). I formally withdrew the subpoena on June 30, 2008, following Jeffrey Epstein's entry of his guilty plea in state court (Exhibit B-135). These activities took us up to the time of Jeffrey Epstein's June 30, 2008 guilty plea. Fro
IA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020. Re: Jeffrey EpsteinMIM NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office for the Southern Dis
prosecution of any potential co-conspirators of Mr. Epstein, including unidentified co-conspirators. I do n
and agents on how to investigate and prosecute those cases. U.S.'. Alfonso Diaz Cardenas, 07-Cr-80108 AUSA Villafafia assisted in the drafting of Eleventh Circuit Pattern [Criminal] Jury Instructions related to child exploitation offenses, including clarifying that, in cases of actual contact with a child, there is n
ent 45 Entered on FLSD Docket 09/3012008 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DO
LORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, Plaintiff, vs. J
ICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, Plaintiff,
tipulated proposed verdict form in hard copy form and on 3.5" diskette. All requested instructions shall be typed on a separate page, and except for Eleventh Circuit Pattern instructions, must be supported by citations of authority. Any objections to the proposed instructions shall be stated clearly and concisely and al
he written response of Assistant United States Attorney be letter of Jeffrey R. Ra sdate dated April 2, 2019, regarding the crim investigation of Jeffrey Epstein. aparately has sent you encrypted disks containing the exhibits referenced in er written response, and has emailed other exhibits that were not i
L ONLY Re: OPR Investigation Relating to Jeffrey Epstein Federal Criminal Investigation Dear Ms. Ingersol
VIA EMAIL ONLY Re: OPR Investigation Relating to Jeffrey Epstein Federal Criminal Investigation Dear Ms.
er prosecutors and agents on how to investigate and prosecute those cases. • U.S.'. Alfonso Diaz Cardenas, 07-Cr-80108 =isted in the drafting of Eleventh Circuit Pattern [Criminal] Jury Instructions rel exploitation offenses, including clarifying that, in cases of actual contact with a child, there is no requiremen
h Lynn Jasperson, et al., 17-Cr-80194 ■ U.S. v. Jeffrey Williams, 17-Cr-80195 3 EFTA00223091 ■ U.S.
ecutors and agents on how to investigate and prosecute those cases. • U.S. v. Alfonso Diaz Cardenas, 07-Cr-80108 Ms. assisted in the drafting of Eleventh Circuit Pattern [Criminal] Jury Instructions related to child exploitation offenses, including clarifying that, in cases of actual contact with a child, there is n
Entities connected to both Jeffrey Epstein and Eleventh Circuit Pattern
Leon Black
PERSON
Prince Andrew
PERSON
Eric Trump
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
United States
LOCATION
Joe Biden
PERSON
Prince Charles
PERSONSouthern District
LOCATIONJane Doe
PERSON
Barry Diller
PERSON
Department of Justice
ORGANIZATION
Alfredo Rodriguez
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSON
Virginia Giuffre
PERSON
Jay Lefkowitz
PERSON