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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
ty; and Third : that the Defendant 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). EFTA00229860
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
ty; and Third : that the Defendant 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). a l Tobon-Builes was decided prior to the enactment of 31 U.S.C. § 5324(a), which created a crimin
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
ty; and Third: that the Defendant 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). 30 EFTA00234546 The term "unlawful activity" is not defined in Section 1960. Another one of the
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 →y; and Third: that the Defendant 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 th
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 →: that the Defendant engaged in the financial transaction with the intent to promote the carrying on of specified unlawful activity. EFTA02857761 Eleventh Cir. Pattern Jury Instr., Offense Instr. 70.4 (2003). F Tobon-Bitiles was decided prior to the enactment of 31 U.S.C. § 5324(a), which created a crimina
Page: EFTA02857732_p31 →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 →ty; and Third : that the Defendant 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). F Tobon-Builes was decided prior to the enactment of 31 U.S.C. § 5324(a), which created a criminal
Page: EFTA02857763_p47 →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 →ty; and Third : that the Defendant 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). a lTobon-Builes was decided prior to the enactment of 31 U.S.C. § 5324(a), which created a crimina
Page: EFTA02857810_p29 →Entities connected to both Gerald Lefcourt and Eleventh Cir

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