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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
2423 are more recent additions, which focus on children. All three sections are sometimes jointly referred to as the Mann Act. UNote that there is an Eleventh Circuit Pattern Jury Instruction for attempted enticement of a minor. In that instruction, the Eleventh Circuit included a willfulness requirement — including a requirem
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
423 are more recent additions, which focus on children. All three sections are sometimes jointly referred to as the Mann Act. a lNote that there is an Eleventh Circuit Pattern Jury Instruction for attempted enticement of a minor. In that instruction, the Eleventh Circuit included a willfulness requirement — including a requirem
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
was a facility of interstate commerce." United States'. Roberts, 2006 WL 827293 n.1 (11th Cir. Mar. 30, 2006). See also United "Note that there is an Eleventh Circuit Pattern Jury Instruction for attempted enticement of a minor. In that instruction, the Eleventh Circuit included a willfulness requirement — including a require
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 →is used in the commission of [the] offense, regardless of whether the use is interstate in nature (Le., the telephone call was '°Note that there is an Eleventh Circuit Pattern Jury Instruction for attempted enticement of a minor. In that instruction, the Eleventh Circuit included a willfulness requirement — including a require
Page: EFTA02857524_p10 →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 →23 are more recent additions, which focus on children. All three sections are sometimes jointly referred to as the Mann Act. F! Note that there is an Eleventh Circuit Pattern Jury Instruction for attempted enticement of a minor. In that instruction, the Eleventh Circuit included a willfulness requirement — including a requirem
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 →d 2423 are more recent additions, which focus on children. All three sections are sometimes jointly referred to as the Mann Act. Note that there is an Eleventh Circuit Pattern Jury Instruction for attempted enticement of a minor. In that instruction, the Eleventh Circuit included a willfulness requirement — including a requirem
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 →423 are more recent additions, which focus on children. All three sections are sometimes jointly referred to as the Mann Act. 3F Note that there is an Eleventh Circuit Pattern Jury Instruction for attempted enticement of a minor. In that instruction, the Eleventh Circuit included a willfulness requirement — including a requirem
Page: EFTA02857810_p29 →Entities connected to both Gerald Lefcourt and an Eleventh Circuit Pattern Jury

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