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ory five-year period of incarceration. The current ten-year mandatory minimum was instituted in 2006. MIA_CEOS_00077 EFTA00191444 LAW °VICES OF GERALD B. LEFCOURT. P.C. Jeffrey Sloman, Esq. Matthew Menchel, Esq. Andrew Lourie, Esq. A. Marie Villafafia, Esq. The United States Attorney's Office Southern Dis
itional step, even before any sexual activity and regardless of whether one ever takes place. MIA_CE0S_00092 EFTA00191459 LAW OIACCS OF ERALD a LEFCOURT. PC. Jeffrey Sloman, Esq. Matthew Menchel, Esq. Andrew Lourie, Esq. A. Marie Villafaiia, Esq. The United States Attorney's Office Southern Dist
0) (excerpts attached as Exhibit 29) Later, Dershowitz would write to tell the Justice Department that "Epstein never targeted minors." Letter from Gerald Lefcourt & Alan Dershowitz, July 6, 2007 to U.S. Atty.'s Office for the S.D. Fla (attached as Exhibit 30). Now, nearly a decade later, there should be no doubt
gainst strict liability, especially since it applies in cases where there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's' decision in United States Murrell, supra, reflects this same understanding of the statute. The Murrell court wrote that, under the "plain language"
aimen1 and *pm to tomply wkihztote. R. ALEXANDER ACOSTA VinTED STATER ATTOMEY A. MARE VII1APA A ASSISTANT VS. ATTORNEY Dáie.1 ril - Os& Dw.* GERALD LEPCOURT,ESO. COUNSEL TO MPFREY MIEN LILLY ANN SANCHEZ. ESQ. ATTORNEY POR WEM ETSTEN Case No. 08-80736-CV-MARRA P-011814 EFTA00192860 By signing this
MARIE VTLLAFARA ASSISTANT U.S. ATTORNEY OERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANC
with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: Dated: 77P/4" Dated: Dated: A. MARIE VTLLAFARA ASSISTANT U.S. ATTORNEY OERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 Case No. 08-80736-CV-MARRA P-01 1810 EFTA001
penalty ... if, in fact, someone ... is caught and convicted.") (emphasis added). Accordingly, Masha's Law cannot lawfully be applied in this case. The Eleventh Circuit's decision in United States I, Siegel 153 F.3d 1256 (11th Cir. 1998), is virtually on point. In Siegel, the defendant pleaded guilty to charges under
D Docket 02/10/2016 Page 2 of 2 (USAFLS) From: Lilly Ann Sanchez ([email protected] Sent: Friday .lanuary M 7007 4:05 PM To: (USAFLS) Cc: Gerald Letcourl Subject: Jeffrey Epstein Illt hope you had a great holiday season. Gerald Lefcourt and I would like to speak with you early next week on the Epst
Illt hope you had a great holiday season. Gerald Lefcourt and I would like to speak with you early next wee
y=en... 6/28/2007. MIA_CEOS_00081 EFTA00184639 9:08-cv-80736-KAM Document 361-46 Entered on FLSD Docket 02/10/2016 Page 7 of 24 LAW OIPICto or ERALD B. LEFCOURT, P.C. Jeffrey Mi sq. Matthew Esq. Andrew Lourie, Esq. A. Villafafia, Esq. The United States Attorney's Office Southern District of Florida J
gainst strict liability, especially since it applies in eases whcre there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's decision in United States Murrell, supra, reflects this same understanding of the statute. The Murrell court wrote that, under the "plain language"
tant prosecutor Dahlia Weiss and thereby influence the outcome of the State prosecution, that assertion is frivolous. Mr. Goldberger was retained by Gerald Lefcourt after Mr. Epstein already had been indicted by the Grand Jury. Mr. Lefcourt had never heard the name Dahlia Weiss when he hired Mr. Goldberger, and
tion, that assertion is frivolous. Mr. Goldberger was retained by Gerald Lefcourt after Mr. Epstein already had been indicted by the Grand Jury. Mr. Lefcourt had never heard the name Dahlia Weiss when he hired Mr. Goldberger, and had no idea that Mr. Goldberger's law partner was married to a sex-crimes p
at (a) force or coercion would be used to cause Owens to engage in a criminal sex act or (b) that Owens was under the age of 18." (emphasis added). The Eleventh Circuit's interpretation of the statute makes perfect sense: were § 1591 not limited in that fashion, it would threaten to criminalize a host of localized be
See Tab 23, August 16, 2007 Letter from I. to G. Lefcourt ("In other words, if the sex offense case is res
to engage in a criminal sex act or (b) that Owens was under the age of 18.) (emphasis added). Again, none of these factors is present in this case. The Eleventh Circuit's interpretation of the statute makes perfect sense: were § 1591 not limited in this fashion, it would threaten to criminalize a host of localized be
48 EAST 78Th NEW YORE, NEW YORK 10021 GERALD B. LEFCOURT [email protected] SHERYL E. REICH NIcle
gainst strict liability, especially since it applies in cases where there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's decision in United States Murrell, supra, reflects this same understanding of the statute. The Murrell court wrote that, under the "plain language"
T 78" STREET NEW YORK, NEW YORK 10021 GERALD B. LEFCOURT lefccitul@letcourtlaw corn SHERYL E. REICH Nid
gainst strict liability, especially since it applies in cases where there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's decision in United States, Murrell, supra, reflects this same understanding of the statute. The Murrell court wrote that, under the "plain language
18" STREET NEW YORK, NEW YORK 10021 GERALD B. LEFCOURT SHERYL C. REICH RENATO C. STABILE FAITH A. FRI
gainst strict liability, especially since it applies in cases where there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's decision in United States v. Muriel!, supra, reflects this same understanding of the statute. The Mum!! court wrote that, under the "plain language
nt purposes. And §2422(a), unlike subsection (b), carries no mandatory minimum sentence, let alone ten years. EFTA00284189 ♦— ornocs or GERALD a LEFCOURT, PC United States Attorney's Office Southern District of Florida July 6, 2007 Page 16 first prove that Murrell, using the internet, acted with a
gainst strict liability, especially since it applies in cases where there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's decision in United States v. Murrell, supra, reflects this same understanding of the statute. The Mini! court wrote that, under the "plain language
cribed. EFTA00226757 LAW OrrICCO or GERALD B. LEFCOURT. PC. The bulk importation of complex bodies of s
gainst strict liability, especially since it applies in cases where there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's decision in United States Murrell, supra, reflects this same understanding of the statute. The Murrell court wrote that, under the "plain language"
Entities connected to both Gerald Lefcourt and The Eleventh Circuit's

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