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24 F.3d 65, 76-77 (1" Cir. 2005); United States' Brown, 43 F.3d 618, 625 (11`h Cir. 1995). The governmen
rom former CEOS attorney Stephanie Thacker that responds to CEOS's assessment of its limited review of Mils case; and a point-by- point rebuttal to First Assistant United States Attorney Jeffrey recent letter which we believe contains factual inaccuracies typical of our correspondence from the United States A
n r -C) 2' 1"" tea rn PI 0 - n r O - -c BROWN MAY 162001 0 3 —c Ce? cn cn EFTA00229662
ion, please feel free to contact me. By: cc: R. Alexander Acosta United States Attorney Sincerely, R. Alexander Acosta United States Attorney First Assistant United States Attorney 3 Case No. 08-80736-CV-MARRA P-013242 EFTA00229661 HERMAN SLOMAN bE MERMELSTEIN, P.A. ATTORNEYS AT LAW BANK Or AMERICA
of an opportunity to engage in prohibited conduct. See, e.g,. United States v. Sanchez-Berrios, 424 F.3d 65, 76-77 (1" Cir. 2005); United States v. Brown, 43 F.3d 618, 625 (I1th Cu. 1995). The government cannot fairly, or consistent with the rule of lenity, advocate a broader definition of the same te
er CEOS attorney Stephanie Thacker that responds to CEOS's assessment of its limited review of Mr. E stein's case; and a point-by- point rebuttal to First Assistant United States Attorney recent letter which we believe contains factual inaccuracies typical of our correspondence from the United States Attorney'
atute covers interstate transportation of woman without pecuniary motive where intent is to have illicit relations with her by force or otherwise); Brown 'United States, 237 F.2d 281 (8th Cir. 1956) (the defendant violated the Act when he tricked woman into his car and drove her across state lines wh
EOURMW.ccen RENATO C. STABILE 11104110WONSEinvcom FAITH A. FRIEDMAN filedmeneldwurlaw.wco BY HAND DELIVERY June 25, 2007 Jeffrey Sloman, Esq., First Assistant United States Attorney Matthew Menchel, Esq., Chief, Criminal Division The United States Attorney's Office Southern District of Florida 99 NE 4th
09 minor to engage in sex activity. 04- James Brown I [None] Use of intemet to entice 14032 mino
LE slabIle&elcourIlawcorn FAITH A. FRIEDMAN [email protected] BY FEDERAL EXPRESS TELEPHONE FACSIMILE July 6, 2007 Jeffrey Sloman, Esq., First Assistant United States Attorney Matthew Menchel, Esq., Chief, Criminal Division The United States Attorney's Office Southern District of Florida 99 NE 4th
atute covers interstate transportation of woman without pecuniary motive where intent is to have illicit relations with her by force or otherwise); Brown v United States, 237 F.2d 281 (8th Cir. 1956) (the defendant violated the Act when he tricked woman into his car and drove her across state lines w
ccs OF Gzaaw B. Ii5xto-crat, P.G. A PROFESSIONAL CORPORATION NEW YOR3X, NSW' YORE 10021 GERALD 8. LEP-COURT June 25, 2007 ' BY HAND DELIVERY , First Assistant United States Attorney Chief, Criminal Division ey's Office Southern District of Florida IMO Miami, Florida 33132 Deputy Chief, Northern Region
licit relations with her by force or otherwise); Brown United States, 237 .2d 281 (8th Cir. 1956) ver
GERALD 0. LEFCOURT leloarypekouituroccom SHERYL E RE1CR Nv C. STABILE ow FRIEDM•N -Oln June 25, 2007 BY HAND DELIVERY Jeffrey Sloman, Esq., First Assistant United States Attorney Matthew Menchel, Esq., Chief, Criminal Division The United States Attorney's Office Southern District of Florida 99 NE 4th
atute covers interstate transportation of woman without pecuniary motive where intent is to have illicit relations with her by force or otherwise); Brown v United States, 237 F.2d 281 (8th Cir. 1956) (the defendant violated the Act when he tricked woman into his car and drove her across state lines w
RATION IPS EAST 70' STREET NEW YORE, NEW YORIELOOEI GERALD B. LEFCOURT SHERYL E. REICH FAITH A. FRIEDMAN June 25, 2007 BY HAND DELIVERY Esq., First Assistant United States Attorney Esq., Chief, Criminal Division The United States Attorney's Office Southern District of Florida 99 NE 4th Street Miami, F
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