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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
alone, but which is knowingly committed by a conspirator in an effort to accomplish some object of the conspiracy." 11th Cir. Pattern Jury Instr., Offense Instr. 13.1 (2003). L9Part G contains the guidelines for calculating the offense levels for "Offenses Involving Commercial Sex Acts, Sexual Exploitation
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
alone, but which is knowingly committed by a conspirator in an effort to accomplish some object of the conspiracy." 11th Cir. Pattern Jury Instr., Offense Instr. 13.1 (2003). F IAlthough Hersh specifically mentions "sexual activity with a minor," knowledge of age is not required, as discussed above. Part G
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
alone, but which is knowingly committed by a conspirator in an effort to accomplish some object of the conspiracy." 11th Cir. Pattern Jury Instr., Offense Instr. 13.1 (2003). Although Hersh specifically mentions "sexual activity with a minor," knowledge of age is not required, as discussed above. Part G co
Epstein would pay the girl—usually $200—and if it was a "new" girl, would ask for the girl's phone '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
d alone, but which is knowingly committed by a conspirator in an effort to accomplish some object of the conspiracy." 11th Cir. Pattern Jury Instr., Offense Instr. 13.1 (2003). 16 EFTA00234532 in any illicit sexual conduct with another person shall be fined under this title or imprisoned not more than 30 y
connected and the videotapes were gone. Nonetheless, the search did recover some evidence of value, '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: EFTA02857524_p2 →ng a meeting, Epstein's current attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that attorney Ro
Page: EFTA02857524_p2 →engaged in the financial transaction with the intent to promote the carrying on of specified unlawful activity. Eleventh Cir. Pattern Jury Instr., Offense Instr. 70.4 (2003). 29 EFTA02857552 money laundering statutes, Section 1956 cross-references Section 1961(1) for the definition of "specified unlawful
Page: EFTA02857524_p29 →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 →alone, but which is knowingly committed by a conspirator in an effort to accomplish some object of the conspiracy." 11th Cir. Pattern Jury Instr., Offense Instr. 13.1 (2003). MAlthough Hersh specifically mentions "sexual activity with a minor," knowledge of age is not required, as discussed above. Based on
Page: EFTA02857732_p30 →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 →alone, but which is knowingly committed by a conspirator in an effort to accomplish some object of the conspiracy." 11th Cir. Pattern Jury Instr., Offense Instr. 13.1 (2003). Although Hersh specifically mentions "sexual activity with a minor," knowledge of age is not required, as discussed above. MBased on
Page: EFTA02857763_p46 →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 →alone, but which is knowingly committed by a conspirator in an effort to accomplish some object of the conspiracy." 11th Cir. Pattern Jury Instr., Offense Instr. 13.1 (2003). Although Hersh specifically mentions "sexual activity with a minor," knowledge of age is not required, as discussed above. F Part G
Page: EFTA02857810_p29 →Entities connected to both Gerald Lefcourt and Offense Instr

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONLeon Black
PERSON
United States
LOCATIONAnn Sanchez
PERSONRoy Black
PERSON
Department of Justice
ORGANIZATION
Palm Beach Police Department
ORGANIZATIONJane Doe
PERSON
Palm Beach County
LOCATION
Ghislaine Maxwell
PERSON
Barry Krischer
PERSON
Barry Diller
PERSON
Jeffrey Sloman
PERSON
Palm Beach
LOCATION
Marc Rich
PERSON
Virginia Giuffre
PERSON
New York
LOCATION
Lesley Groff
PERSONJoe Recarey
PERSON