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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
United States I. Yang, 128 F.3d 1065, 1069-70 (7th Cir. 1997); United Statosi. Ellis 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States'. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion); cf. Gustafson'. Alloyd Co.. Inc., 513 U.S. 561, 570 (1995) ("[W]e adhere[] to t
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
e travel. In other words, the Government must show that the Defendant's criminal purpose was not merely incidental to the travel. United States v. Hoschouer , F.3d 2007 WL 979931, *1 (11th Cir. Apr. 3, 2007). The decision of the Eleventh Circuit was consistent with every other circuit that has addresse
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
e travel. In other words, the Government must show that the Defendant's criminal purpose was not merely incidental to the travel. United States v. Hoschouer , F.3d 2007 WL 979931, *1 (11th Cir. Apr. 3, 2007). The decision of the Eleventh Circuit was consistent with every other circuit that has addresse
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
Hersh specifically mentions "sexual activity with a minor," knowledge of age is not required, as discussed above. 17 EFTA00234533 United States Hoschouer, F.3d 2007 WL 979931, *1 (11th Cir. Apr. 3, 2007). The decision of the Eleventh Circuit was consistent with every other circuit that has addresse
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 →e travel. In other words, the Government must show that the Defendant's criminal purpose was not merely incidental to the travel. United States v. Hoschouer, F.3d,_, 2007 WL 979931, *1 (11th Cir. Apr. 3, 2007). The decision of the Eleventh Circuit was consistent with every other circuit that has addres
Page: EFTA02857524_p17 →e travel. In other words, the Government must show that the Defendant's criminal purpose was not merely incidental to the travel. United States v. Hoschouer , F.3d 2007 WL 979931, *1 (11th Cir. Apr. 3, 2007). The decision of the Eleventh Circuit was consistent with every other circuit that has addresse
Page: EFTA02857732_p9 →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 →e travel. In other words, the Government must show that the Defendant's criminal purpose was not merely incidental to the travel. United States v. Hoschouer , F.3d 2007 WL 979931, *1 (11th Cir. Apr. 3, 2007). The decision of the Eleventh Circuit was consistent with every other circuit that has addresse
Page: EFTA02857763_p9 →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 →e travel. In other words, the Government must show that the Defendant's criminal purpose was not merely incidental to the travel. United States v. Hoschouer , F.3d 2007 WL 979931, *1 (11th Cir. Apr. 3, 2007). The decision of the Eleventh Circuit was consistent with every other circuit that has addresse
Page: EFTA02857810_p9 →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 Hoschouer

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONLeon Black
PERSON
United States
LOCATIONthe Southern District
LOCATIONAnn Sanchez
PERSONRoy Black
PERSON
Department of Justice
ORGANIZATION
Palm Beach Police Department
ORGANIZATION
Kenneth Marra
PERSONJane 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
LOCATION