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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
(citing United States v. Griffith , 284 F.3d 338, 351 (2d Cir. 2002); United States v. Taylor , 239 F.3d 994, 997 (9th Cir. 2001); United States v. Scisum , 32 F.3d 1479, 1485-86 (10th Cir. 1994); United States v. Hamilton , 456 F.2d 171, 173 (3d Cir. 1982)). Instead, the court concluded that the Gove
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
(citing United States v. Griffith , 284 F.3d 338, 351 (2d Cir. 2002); United States v. Taylor , 239 F.3d 994, 997 (9th Cir. 2001); United States v. Scisum , 32 F.3d 1479, 1485-86 (10th Cir. 1994); United States v. Hamilton , 456 F.2d 171, 173 (3d Cir. 1982)). Instead, the court concluded that the Gove
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
8-39 (citing United States I. Griffith, 284 F.3d 338, 351 (2d Cir. 2002); United States, Taylor, 239 F.3d 994, 997 (9th Cir. 2001); United States I Scisum, 32 F.3d 1479, 1485-86 (10th Cir. 1994); United States Hamilton, 456 F.2d 171, 173 (3d Cir. 1982)). Instead, the court concluded that the Governmen
cribed. EFTA00226757 LAW OrrICCO or GERALD B. LEFCOURT. PC. The bulk importation of complex bodies of s
travel." Evidence related to the "grooming process" was relevant to whether the defendants had the illicit intent necessary under 2423(b). 5) U.S.' Scisum, 32' 3d 1479 (10th Cir. 1994). For a violation of 2423(a), the government must prove that the defendant had formed the intent to have the victim eng
(citing United States v. Griffith , 284 F.3d 338, 351 (2d Cir. 2002); United States v. Taylor , 239 F.3d 994, 997 (9th Cir. 2001); United States v. Scisum , 32 F.3d 1479, 1485-86 (10th Cir. 1994); United States v. Hamilton , 456 F.2d 171, 173 (3d Cir. 1982)). Instead, the court concluded that the Gove
Page: EFTA02857732_p3 →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 →(citing United States v. Griffith , 284 F.3d 338, 351 (2d Cir. 2002); United States v. Taylor , 239 F.3d 994, 997 (9th Cir. 2001); United States v. Scisum , 32 F.3d 1479, 1485-86 (10th Cir. 1994); United States v. Hamilton , 456 F.2d 171, 173 (3d Cir. 1982)). Instead, the court concluded that the Gove
Page: EFTA02857763_p3 →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 →(citing United States v. Griffith , 284 F.3d 338, 351 (2d Cir. 2002); United States v. Taylor , 239 F.3d 994, 997 (9th Cir. 2001); United States v. Scisum , 32 F.3d 1479, 1485-86 (10th Cir. 1994); United States v. Hamilton , 456 F.2d 171, 173 (3d Cir. 1982)). Instead, the court concluded that the Gove
Page: EFTA02857810_p3 →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 Scisum

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
Palm Beach
LOCATION
Jeffrey Sloman
PERSON
Marc Rich
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONJoe Recarey
PERSON
Lilly
ORGANIZATION