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to choose the harsher only when Congress has spoken in clear and definite language.") (chine (Inked States r. McNally. 483 U.S. 350. 359-360 (1987): United States v. Universal CIT. Credit Corp.. 344 U.S. 218. 221-222 (1 952)) Furthermore, the note of lenity also applies to Florida state criminal law. See &Tine
n language that is clear and EFTA00104561 lid 41Yuf „v KIRKLAND & ELLIS LLP I lonorable K. Alexander Acosta December 17.2007 Page definite". See United States v. Floss. 404 U.S. 336. 34748 (1971) (citations and footnote omitted). It is fundamentally unlItir to apply to conduct criminal statues that cannot
ehm, the defendant bought and distributed crack cocaine and cocaine to underage girls; admitted to knowing that the girls were underage; ananged for Underage girls to have sex with usher mentbers orate conspiracy in exchange for the drugs: and he was in patsession of illegal firearms at the time of the al
ting the offense alleged in Count Two of this Indictment, JEFFREY EPSTEIN, the defendant, shall forfeit to the United States, pursuant to'Title 18, United States Code, Section 1594(c) (1), any property, real and personal, that was used or intended to be used to commit or to facilitate the commission of the o
ash. Victims typically were paid hundreds of dollars for each encounter. 17. JEFFREY EPSTEIN, the defendant, knew that certain of hiS victims were Underage, including because certain victims told him their age.' In addition, as With New York-based victims, Many. Florida victims, once recruited, were ab
ting the offense alleged in Count Two of this Indictment, JEFFREY EPSTEIN, the defendant, shall forfeit to the United States, pursuant to'Title 18, United States Code, Section 1594(c) (1), any property, real and personal, that was used or intended to be used to commit or to facilitate the commission of the o
ash. Victims typically were paid hundreds of dollars for each encounter. 17. JEFFREY EPSTEIN, the defendant, knew that certain of hiS victims were Underage, including because certain victims told him their age.' In addition, as With New York-based victims, Many. Florida victims, once recruited, were ab
ting the offense alleged in Count Two of this Indictment, JEFFREY EPSTEIN, the defendant, shall forfeit to the United States, pursuant to'Title 18, United States Code, Section 1594(c) (1), any property, real and personal, that was used or intended to be used to commit or to facilitate the commission of the o
ash. Victims typically were paid hundreds of dollars for each encounter. 17. JEFFREY EPSTEIN, the defendant, knew that certain of hiS victims were Underage, including because certain victims told him their age.' In addition, as With New York-based victims, Many. Florida victims, once recruited, were ab
Entities connected to both United States and Underage

Jeffrey Epstein
PERSON
George W. Bush
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
New York City
LOCATION
U.S. Virgin Islands
LOCATION
the United States District Court
ORGANIZATION
Palm Beach
LOCATION
Joi Ito
PERSON
Geoffrey S. Berman
PERSON
Apple
ORGANIZATIONthe "New York Residence
ORGANIZATION
Zorro
LOCATION
New Yorker
ORGANIZATIONI. Premises
ORGANIZATIONBarbara Moses
PERSON
Saint James
LOCATIONFruits
ORGANIZATIONShoebox
ORGANIZATIONthe Subject Devices
ORGANIZATION