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behalf of such person) during the very• communication that constitutes the required basis for federal jurisdiction. EFTA00079412 LAW OF/PICCO OP GERALD B. LEFCOURT. P.C. FCre₹ o Criminal Division The United States Attorney's Office Southern District of Florida July 25, 2007 Page 5 To our knowledge, the c
T TB" STREET NEW YORE, NEW YORK 10021 GERALD B LEFCOURT SHERYL E. REICH riBlialloROWEWN:orn RENATO C.
ding of this statutory language would raise constitutional problems of fair warning, vagueness and lenity. EFTA00079411 LAW o•ICCS or GERALD 13. LEVCOURT. PC Chiefo the Criminal Division The United States Attorney's Office Southern District of Florida July 25, 2007 Page 4 We are, of course, mindf
. 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 statute for which
as counsel to the above noted entities to respond to the subpoenas dated April 24, 2007, served, respectively, on those entities. I understand from Gerald B. Lefcourt and Lilly Ann Sanchez, both counsel to Jeffrey Epstein, that as a result of a telephone conversation had amongst you, Mr. Lefcourt and Ms. Sanchez,
d from Gerald B. Lefcourt and Lilly Ann Sanchez, both counsel to Jeffrey Epstein, that as a result of a telephone conversation had amongst you, Mr. Lefcourt and Ms. Sanchez, you are now seeking documents reflecting: 1. Ownership of JEGE and Hyperion; 2. Assets of JEGE and Hyperion; and 3. Employees of
and 3. Employees of JEGE and Hyperion. As I believe Mr. Lefcourt and Ms. Sanchez told you, JEGE and Hyperion are each wholly owned by Mr. Epstein. Enclosed is an IRS Form 2553 ("Election by a Small Business Corporation") filed by JEGE, showing that Mr. Epstein is the sole shareholder of that entity. A
as counsel to the above noted entities to respond to the subpoenas dated April 24, 2007, served, respectively, on those entities. I understand from Gerald B. Lefcourt and Lilly Ann Sanchez, both counsel to Jeffrey Epstein, that as a result of a telephone conversation had amongst you, Mr. Lefcourt and Ms. Sanchez,
d from Gerald B. Lefcourt and Lilly Ann Sanchez, both counsel to Jeffrey Epstein, that as a result of a telephone conversation had amongst you, Mr. Lefcourt and Ms. Sanchez, you are now seeking documents reflecting: 1. Ownership of JEGE and Hyperion; 2. Assets of JEGE and Hyperion; and 3. Employees of
and 3. Employees of JEGE and Hyperion. As I believe Mr. Lefcourt and Ms. Sanchez told you, JEGE and Hyperion are each wholly owned by Mr. Epstein. Enclosed is an IRS Form 2553 ("Election by a Small Business Corporation") filed by JEGE, showing that Mr. Epstein is the sole shareholder of that entity. A
as counsel to the above noted entities to respond to the subpoenas dated April 24, 2007, served, respectively, on those entities. I understand from Gerald B. Lefcourt and Lilly Ann Sanchez, both counsel to Jeffrey Epstein, that as a result of a telephone conversation had amongst you, Mr. Lefcourt and Ms. Sanchez,
d from Gerald B. Lefcourt and Lilly Ann Sanchez, both counsel to Jeffrey Epstein, that as a result of a telephone conversation had amongst you, Mr. Lefcourt and Ms. Sanchez, you are now seeking documents reflecting: 1. Ownership of JEGE and Hyperion; 2. Assets of JEGE and Hyperion; and 3. Employees of
and 3. Employees of JEGE and Hyperion. As I believe Mr. Lefcourt and Ms. Sanchez told you, JEGE and Hyperion are each wholly owned by Mr. Epstein. Enclosed is an IRS Form 2553 ("Election by a Small Business Corporation") filed by JEGE, showing that Mr. Epstein is the sole shareholder of that entity. A
as counsel to the above noted entities to respond to the subpoenas dated April 24, 2007, served, respectively, on those entities. I understand from Gerald B. Lefcourt and Lilly Ann Sanchez, both counsel to Jeffrey Epstein, that as a result of a telephone conversation had amongst you, Mr. Lefcourt and Ms. Sanchez,
d from Gerald B. Lefcourt and Lilly Ann Sanchez, both counsel to Jeffrey Epstein, that as a result of a telephone conversation had amongst you, Mr. Lefcourt and Ms. Sanchez, you are now seeking documents reflecting: I. Ownership of JEGE and Hyperion; 2. Assets of JEGE and Hyperion; and 3. Employees of
and 3. Employees of JEGE and Hyperion. As I believe Mr. Lefcourt and Ms. Sanchez told you, JEGE and Hyperion are each wholly owned by Mr. Epstein. Enclosed is an IRS Form 2553 ("Election by a Small Business Corporation") filed by JEGE, showing that Mr. Epstein is the sole shareholder of that entity. A
ld" neighbor; arrested in hotel where supposed to meet. • Not Consummated Showed up for meeting Sting Conviction affirmed. 87 EFTA01729571 I LEFCOURT'S LIST EFTA01729572
e. 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 statute for which
Entities connected to both Gerald Lefcourt and Enclosed

Jeffrey Epstein
PERSON
Alexander Acosta
PERSON
United States
LOCATIONLeon Black
PERSON
Alan Dershowitz
PERSONthe Southern District
LOCATIONAnn Sanchez
PERSONJack Goldberger
PERSONFBI
ORGANIZATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
A. Marie Villafana
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Ghislaine Maxwell
PERSON
Palm Beach County
LOCATION
the United States District Court
ORGANIZATION
Bradley Edwards
PERSONSanchez
PERSON
Barry Diller
PERSON