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w best to use the broad discretion you enjoy in choosing whether to prosecute. In this regard, we suggest that having a greater understanding of who Jeffrey Epstein is as a person may help inform how best to proceed. Jeffrey Epstein was raised in a middle class neighborhood in Brooklyn, New York, by hardworking
hen it enacted this law.3 Though §2422(b) is susceptible to multiple interpretations, it was designed to address a specific a problem with which Mr. Epstein's case has nothing in common. If stretched to reach beyond the core concern of the statute, a host of problems immediately arise. A simple reading
igned to address a specific a problem with which Mr. Epstein's case has nothing in common. If stretched to re
s ttorney's Office Southern District of Florida Jeffrey Epstein Dear We write as counsel to Jeffrey Eps
very special thanks to generous support gil et”ey Epstein. for making this meeting happen. This meeting wa
e simply by employing an intennediary to carry out his intended objective. Id. at 1287. Fact patterns similar to Murrell's exist in United States v Hornaday, 392 F.3d 1306 (11t Cir. 2004); United States v. Houston, 177 Fed. Appx. 57 (11" Cir. 2006); United States v. Searcy, 418 F.3d 1193 (116 Cir. 2005
vision The United States Attorney's Office Southern District of Florida 99 NE 4th Street Miami, Florida 33132 Dear• Mr. Menthe': July 25, 2007 Jeffiry Epstein TELEPHONE la 1E)7370400 m ailman We have previously provided you with a memo as to why we believe no charge under 18 U.S.C. §2422(b) could or sho
ting this statute. We also posited that the language of the statute would have to be stretched beyond recognition to fit the particular facts of Mr. Epstein's ease.' Enclosed is data that strongly supports the arguments we previously made. We have thoroughly analyzed every prosecution brought under the
.S.C. §2422(b) could or should be brought against Jeffrey Epstein, even assuming the specific conduct that
beyond recognition to fit the particular facts of Mr. Epstein's ease.' Enclosed is data that strongly supports
U.S. v. Pisman, 443 F.3d 912 (sr Cir. 2006) (2423(b) conspiracy); U.S. v. Pipkins, et al., 378 F.3d 1281 (11th Cir. 2004) (RICO conspiracy); U.S. v. Hornaday, 392 F.3d 1306 (11`" Cir. 2004) (conspiracy charge was error); EFTA00079414 U.S. v. Jackson. 2007 U.S. Dist. LEXIS 33639 (D. Neb. 2007) (state con
ivision The United States Attorney's Office Southern District of Florida 99 NE 41' Street Miami, Florida 33132 Dear Mr. Menchel: July 25, 2007 Jeffrey Epstein TELEPHONE '212)737-0400 FACSIMILE 12i P) 9/313-SI92 We have previously provided you with a memo as to why we believe no charge under 18 U.S.C.
ting this statute. We also posited that the language of the statute would have to be stretched beyond recognition to fit the particular facts of Mr. Epstein's case.t Enclosed is data that strongly supports the arguments we previously made. We have thoroughly analyzed every prosecution brought under the
Florida 33132 Dear Mr. Menchel: July 25, 2007 Jeffrey Epstein TELEPHONE '212)737-0400 FACSIMILE 12i
beyond recognition to fit the particular facts of Mr. Epstein's case.t Enclosed is data that strongly supports
., U.S. I Pisman, 443 F.3d 912 (7th Cir. 2006) (2423(b) conspiracy); U.S Pipkins, et al., 378 F.3d 1281 (11th Cir. 2004) (RICO conspiracy); U.S. ~ Hornaday, 392 F.3d 1306 (1 1 `11 Cir. 2004) (conspiracy charge was error); U.S. I. Jackson, 2007 U.S. Dist. LEXIS 336 9 (D. Neb. 2007) (state conspiracy char
RENA FAITH BY HAND of of the Criminal Division The United States Attorney's Office Southern Distri of Florida tams, on a 3132 July 25, 2007 Jeffrey Epstein •ELE.T., FACSIMILE Dear Mr. We have previously provided you with a memo as to why we believe no charge under 18 U.S.C. §2422(b) could or should b
ting this statute. We also posited that the language of the statute would have to be stretched beyond recognition to fit the particular facts of Mr. Epstein's case! Enclosed is data that strongly supports the arguments we previously made. We have thoroughly analyzed every prosecution brought under the s
istri of Florida tams, on a 3132 July 25, 2007 Jeffrey Epstein •ELE.T., FACSIMILE Dear Mr. We have pr
beyond recognition to fit the particular facts of Mr. Epstein's case! Enclosed is data that strongly supports
U.S. v. Pisman, 443 F.3d 912 (76 Cir. 2006) (2423(b) Conspiracy); U.S. v. Pipkins, et al., 378 F.3d 1281 (11th Cir. 2004) (RICO conspiracy); U.S. v. Hornaday, 392 F.3d 1306 (11" Cir. 2004) (conspiracy charge was error); EFTA01729485 U.S. v. Jackson, 2007 U.S. Dist. LEXIS 33639 (D. Neb. 2007) (state cons
m: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 26, 2007 8:49 AM To: Menthe', Matthew (USAFLS) Cc: Lourie, Andrew (USAFLS) Subject: Epstein Hi Matt - I had hoped to have a revised indictment for our discussion today but Mr. Black's motion has demanded my immediate attention. However, i
ested him. Sentence 13 months; appealed conviction & sentence. Affirmed. CHARG 2422(b) Not Consummated Showed up for meeting 2 EFTA00226394 JEFFREY EPSTEIN 18 U.S.C. §2422(b) CASE ANALYSIS CHART A nationwide search of all cases listing charges under 18 U.S.C. §2422(b) underscores the undeniable fact th
ummated Showed up for meeting 2 EFTA00226394 JEFFREY EPSTEIN 18 U.S.C. §2422(b) CASE ANALYSIS CHART
r error. 2422(b) Not Consummated Showed up for meeting Sting 55 EFTA00226341 COURT . CASES FACILITY FACTS/COMMUNICATION CHARGE ***U.S. I Hornaday, Internet Internet chat room "Loving Families" 2422(6); 392 F.3d 1306 (11th Cir. 2004) Sting where people communicate about having sex with c
.g., U.S. Pisman, 443 F.3d 912 (7th Cir. 2006) (2423(b) conspiracy); U.S. Pipkins, es al., 378 F.3d 1281 (11th Cir. 2004 (RICO conspiracy); U.S. Hornaday, 392 F.3d 1306 (1 1 th Cir. 2 4) (conspiracy charge was error); U.S. I Jackson, 2007 U.S. Dist. LEXIS 33639 (D. Neb. 2007) (state conspiracy charge
defendant-appellant Miguel Plascencia-Alvarado. Jeffrey E. Ellis, Law Offices of Ellis, Holmes & Witchley,
defendant-appellant Miguel Plascencia-Alvarado. Jeffrey E. Ellis, Law Offices of Ellis, Holmes & Witchley,
at rooms, necessarily involves interstate communications and therefore constitutes the "use of facility of interstate commerce." United States Hornaday, 392 F.3d 1306, 1311 (11th Cir.2004). At trial, Defendant admitted that he communicated with "Conrad" using email and Internet instant messag
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