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even when the information would incriminate the client "in the very case in which the Firm was engaged to provide criminal defense representation." Gerald B. Lefcourt, P.C. v. United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who p
aged to provide criminal defense representation." Gerald B. Lefcourt, P.C. v. United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who paid him more than $10,000 cash, and Lefcourt was fined $25,000. Lefcourt sought to avoid
. F2In Bonner v. City of Prichard , 661 F.2d 1206 (11th Cir. 1981) ( en banc), the Eleventh Circuit adopted as precedent all decisions of the prior Fifth Circuit court of Appeals decided prior to October 1, 1981. FIThe Supreme Court called this "a novelty in criminal procedure with which we are wholly unacqu
even when the information would incriminate the client "in the very case in which the Firm was engaged to provide criminal defense representation." Gerald B. Lefcourt, P.C. I United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who pa
gaged to provide criminal defense representation." Gerald B. Lefcourt, P.C. I United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who paid him more than $10,000 cash, and Lefcourt was fined $25,000. Lefcourt sought to avoid
ury. UIn Bonner1 City of Prichard , 661 F.2d 1206 (11th Cir. 1981) ( en banc), the Eleventh Circuit adopted as precedent all decisions of the prior Fifth Circuit court of Appeals decided prior to October 1, 1981. FIThe Supreme Court called this "a novelty in criminal procedure with which we are wholly unacqu
lar phone to persuade or induce . to engage in sexual activity or prostitution 2422(b) EPSTEIN alluring a meeting, Epstein's current attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that attorney Roy Black instructive Epstein to have the CPUs removed although they insisted that those instruction
ng a meeting, Epstein's current attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that attorney Ro
e activity was not "sexual enough" to qualify as "prostitution." Title 18 carries no definition of "prostitution." In United States v. Prince , the Fifth Circuit approved of the generic definition "sexual intercourse for hire" where the West Virginia statues also lacked a definition. Prince , 515 F.2d 564, 5
e in sexual activity or prostitution 2422(b) EPSTEIN caused M. to place one or more traveled via During a meeting, Epstein's current attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that attorney Roy Black instructed Epstein to have the CPUs removed, but they insisted that those instructions were
ng a meeting, Epstein's current attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that attorney Ro
e activity was not "sexual enough" to qualify as "prostitution." Title 18 carries no definition of "prostitution." In United States v. Prince , the Fifth Circuit approved of the generic definition "sexual intercourse for hire" where the West Virginia statues also lacked a definition. Prince , 515 F.2d 564, 5
ng a meeting, Epstein's current attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that attorney Ro
ions, which will be named as co-conspirators and as aiders and abettors in the relevant offenses. 2F During a meeting, Epstein's current attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that attorney Roy Black instructed Epstein to have the CPUs removed, but they insisted that those instructions were
e activity was not "sexual enough" to qualify as "prostitution." Title 18 carries no definition of "prostitution." In United States v. Prince , the Fifth Circuit approved of the generic definition "sexual intercourse for hire" where the West Virginia statues also lacked a definition. Prince , 515 F.2d 564, 5
fkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken
nvestigation) and defense attorneys representing 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 for
ing Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en bane) (11th Circuit adopts as binding precedent all decisions of the former Fifth Circuit handed down prior to the close of business on September 30, 1981)). 12 EFTA00179778 Case 9:08-cv-80736-KAM Document 226 Entered on FLSD Docket 0
et with counsel for Mr. Epstein. Sincerely, R. Alexander Acosta United States Attorney ...••••••• By: Chief, Criminal Division cc: Roy Black Gerald B. Lefcourt R. Alexander Acosta EFTA00179084 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY
aged to provide criminal defense representation." Gerald B. Lefcourt, P.C. v. United States, 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who paid him more than $10,000 cash, and Lefcourt was fined $25,000. Lefcourt sought to avoid
974 'In Bonner v. City of Prichard, 661 F.2d 1206 (11th Cir. 1981) (en bane), the Eleventh Circuit adopted as precedent all decisions of the prior Fifth Circuit court of Appeals decided prior to October 1, 1981. -8- EFTA00179107 F.2d 127 (9th Cir. 1992); United States v. White, 950 F.2d 426, 430 (7th Cir.
e activity was not "sexual enough" to qualify as "prostitution." Title 18 carries no definition of "prostitution." In United States v. Prince , the Fifth Circuit approved of the generic definition "sexual intercourse for hire". Prince , 515 F.2d 564, 566 (5th Cir. 1975). FI2 In 1946, the Supreme Court defin
Page: EFTA02857732_p7 →uring the 18 month period that she was in contact with him. OTHER ISSUES RAISED BY THE DEFENSE EFTA02857759 When you review the cover letter from Gerald Lefcourt (Appendix A), you will see that most of the letter is an attack on the police report and probable cause affidavit drafted by Det. from PBPD. Neith
Page: EFTA02857732_p29 →59 When you review the cover letter from Gerald Lefcourt (Appendix A), you will see that most of the lett
Page: EFTA02857732_p29 →e activity was not "sexual enough" to qualify as "prostitution." Title 18 carries no definition of "prostitution." In United States v. Prince , the Fifth Circuit approved of the generic definition "sexual intercourse for hire". Prince , 515 F.2d 564, 566 (5th Cir. 1975). Fl In 1946, the Supreme Court define
Page: EFTA02857763_p7 →Beach home during the 18 month period that she was in contact with him. V. OTHER ISSUES RAISED BY THE DEFENSE When you review the cover letter from Gerald Lefcourt (Appendix A), you will see that most of the letter is an attack on the police report and probable cause affidavit drafted by Det. Joe Recarey from
Page: EFTA02857763_p45 →NSE When you review the cover letter from Gerald Lefcourt (Appendix A), you will see that most of the lett
Page: EFTA02857763_p45 →e activity was not "sexual enough" to qualify as "prostitution." Title 18 carries no definition of "prostitution." In United States v. Prince , the Fifth Circuit approved of the generic definition "sexual intercourse for hire" where the West Virginia statues also lacked a definition. Prince , 515 F.2d 564, 5
Page: EFTA02857810_p7 →ions, which will be named as co-conspirators and as aiders and abettors in the relevant offenses. 2F During a meeting, Epstein's current attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that attorney Roy Black instructed Epstein to have the CPUs removed, but they insisted that those instructions were
Page: EFTA02857810_p28 →ng a meeting, Epstein's current attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that attorney Ro
Page: EFTA02857810_p28 →Entities connected to both Gerald Lefcourt and Fifth Circuit

Jeffrey Epstein
PERSON
Alexander Acosta
PERSON
United States
LOCATIONLeon Black
PERSON
Alan Dershowitz
PERSONthe Southern District
LOCATIONRoy Black
PERSONAnn Sanchez
PERSONJack Goldberger
PERSON
Department of Justice
ORGANIZATIONFBI
ORGANIZATION
Jay Lefkowitz
PERSON
Ken Starr
PERSON
Palm Beach Police Department
ORGANIZATION
Prince Andrew
PERSON
A. Marie Villafana
PERSON
Kenneth Marra
PERSONJane Doe
PERSON
Bill Clinton
PERSON
George W. Bush
PERSON