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his own.(-2951 According to attorney Gerald B. Lefcourt, Epstein was "part of the original group that co
e of felony solicitation of prostitution,P61 to which Epstein pleaded not guilty in August 2006.L1971 Epstein's defense lawyers included Roy Black, Gerald Lefcra Harvard Law School professor Alan Dershowitz, and former U.S. Solicitor General Ken Starri-92Cal linguist Steven Pinker also assisted. 10 Epstein'
nce" after The New York Times revealed its author, Drew Hendricks, had been paid $600 to submit it falsely as his own.(-2951 According to attorney Gerald B. Lefcourt, Epstein was "part of the original group that conceived of the Clinton Global Initiative".(27§-1 Epstein co-organized a science event with illusio
w to react to it". He alleged the meeting had taken place in London.= In a court filing, Andrew's lawyers had previously referred to a statement by Figueroa's sister, Crystal Figueroa, who alleged that in her bid to find victims for Epstein, Giuffre had asked her, "Do you know any girls who are kind of s
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
simply subjects the defendant to a more severe penalty in light of Congress' concern about the sexual exploitation of minors. Cf. United States v. Figueroa , 165 F.3d 111, 115 (2d Cir. 1998) (noting that, if a criminal statute's language is unclear, its scienter requirement is presumed to be met once an
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
simply subjects the defendant to a more severe penalty in light of Congress' concern about the sexual exploitation of minors. Cf. United States v. Figueroa , 165 F.3d 111, 115 (2d Cir. 1998) (noting that, if a criminal statute's language is unclear, its scienter requirement is presumed to be met once an
to 3501.15600 2006 0816 nt history 3501.1560)7 2006.0626 PaM Beach Poke Department eAdenceftracting report 3501.1560)8 2007.01.01 letter from Gerald Lefrourt to 3501.156009 2007.01.12 Letter from lames Eisenberg to 3501.156010 20(17.03.13 interneve notes 3501.156011 200703.13 intennew 302 3501.15
ripts 3501064065 2007.02.01 letter from Gerald Lefcourt 1 3501064066 2007.02.27 Testi 3501064067 200
ch regarding Tony Figueroa 3501476014 2007.01.06 Research regarding Tony Figueroa 3501476015 2007.01.06 National comprehensive mpan resin:m.7am Figueroa 3501.076016 2007.01.10 Fns memorandum regarding intavieerof Tony Figueroa 3501.076017 2007.01.10 Tony Figueroa Miamian notes 1501.0760113 200
ictment. One of those cases was argued by Gerald Lefcourt — one of Epstein's attorneys. For those reasons,
rge number of uncharged overt acts, those uncharged acts can serve as a variance from/amendment to the Indictment. One of those cases was argued by Gerald Lefcourt — one of Epstein's attorneys. For those reasons, I have kept most of the overt acts from the original indictment (excluding those related to the Ja
. D. M A. (Jane Doe #18) and H. (Jane Doe #19) Jane Doe #18 was recruited by her brother's friend, Tony (referred to in indictment as "A.F."). Figueroa also was the former boyfriend (Jane Doe #1). Figueroa recruited several girls to Epstein's home includin R. Jane Doe #18 attended R2 al Palm Beac
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 →simply subjects the defendant to a more severe penalty in light of Congress' concern about the sexual exploitation of minors. Cf. United States v. Figueroa, 165 F.3d 111, 115 (2d Cir. 1998) (noting that, if a criminal statute's language is unclear, its scienter requirement is presumed to be met once an
Page: EFTA02857524_p7 →simply subjects the defendant to a more severe penalty in light of Congress' concern about the sexual exploitation of minors. Cf. United States v. Figueroa , 165 F.3d 111, 115 (2d Cir. 1998) (noting that, if a criminal statute's language is unclear, its scienter requirement is presumed to be met once an
Page: EFTA02857732_p4 →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 →simply subjects the defendant to a more severe penalty in light of Congress' concern about the sexual exploitation of minors. Cf. United States v. Figueroa , 165 F.3d 111, 115 (2d Cir. 1998) (noting that, if a criminal statute's language is unclear, its scienter requirement is presumed to be met once an
Page: EFTA02857763_p4 →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 →simply subjects the defendant to a more severe penalty in light of Congress' concern about the sexual exploitation of minors. Cf. United States v. Figueroa , 165 F.3d 111, 115 (2d Cir. 1998) (noting that, if a criminal statute's language is unclear, its scienter requirement is presumed to be met once an
Page: EFTA02857810_p4 →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 Figueroa

Jeffrey Epstein
PERSON
Alexander Acosta
PERSON
United States
LOCATIONLeon Black
PERSON
Alan Dershowitz
PERSONthe Southern District
LOCATIONAnn Sanchez
PERSONRoy Black
PERSONJack Goldberger
PERSON
Department of Justice
ORGANIZATIONFBI
ORGANIZATION
Jay Lefkowitz
PERSON
Prince Andrew
PERSON
Ken Starr
PERSON
Palm Beach Police Department
ORGANIZATION
A. Marie Villafana
PERSON
Kenneth Marra
PERSONJane Doe
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON