Epstein Secrets

United States Attorney's Office Southern District of Florida 99 NE 4th Street Miami, Florida 33132 Andrew Lourie, Deputy Chief, Northern Region A. Marie Villafaila, Assistant United States Attorney The United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Pa

thew Menchel, Esq. Andrew Lourie, Esq. A. Marie Villafana, Esq. The United States Attorney's Office South

. Matthew Menchel, Esq. Andrew Lourie, Esq. A. Marie Villafana, Esq. The United States Attorney's Office South

gainst strict liability, especially since it applies in cases where there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's decision in United States Murrell, supra, reflects this same understanding of the statute. The Murrell court wrote that, under the "plain language"

um was instituted in 2006. EFTA00190116 LAW Or•ICC, Or GERALD B. LEFCOURT. PC. Jeffrey Sloman, Esq. Matthew Menchel, Esq. Andrew Lourie, Esq. A. Marie Villafafia, Esq. The United States Attorney's Office Southern District of Florida July 6, 2007 Page 2 those who deliberately, knowingly, and intentionally

thew Menchel, Esq. Andrew Lourie, Esq. A. Marie Villafana, Esq. The United States Attorney's Office South

. Matthew Menchel, Esq. Andrew Lourie, Esq. A. Marie Villafana, Esq. The United States Attorney's Office South

gainst strict liability, especially since it applies in cases where there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's decision in United States, Murrell, supra, reflects this same understanding of the statute. The Murrell court wrote that, under the "plain language

thew Menchel, Esq. Andrew Lourie, Esq. A. Marie Villafana, Esq. The United States Attorney's Office South

. Matthew Menchel, Esq. Andrew Lourie, Esq. A. Marie Villafana, Esq. The United States Attorney's Office South

d in 2006. MIA_CEOS_00077 EFTA00191444 LAW °VICES OF GERALD B. LEFCOURT. P.C. Jeffrey Sloman, Esq. Matthew Menchel, Esq. Andrew Lourie, Esq. A. Marie Villafafia, Esq. The United States Attorney's Office Southern District of Florida July 6, 2007 Page 2 those who deliberately, knowingly, and intentionally

gainst strict liability, especially since it applies in cases where there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's' decision in United States Murrell, supra, reflects this same understanding of the statute. The Murrell court wrote that, under the "plain language"

nt and to investigate and prosecute Mr. Epstein and others for federal offenses. Sincerely, Jeffrey H. Sloman Acting United States Attorney By: A. Marie Villafana Assistant United States Attorney cc: Karen Atkinson, Chief, Northern Division Roy Black, Esq. (via electronic mail) Ca< Sta C4.$0736 CV-MARRA P

man Acting United States Attorney By: A. Marie Villafana Assistant United States Attorney cc: Karen Atk

penalty ... if, in fact, someone ... is caught and convicted.") (emphasis added). Accordingly, Masha's Law cannot lawfully be applied in this case. The Eleventh Circuit's decision in United States I, Siegel 153 F.3d 1256 (11th Cir. 1998), is virtually on point. In Siegel, the defendant pleaded guilty to charges under

tors also acknowledged the application of the Petite Policy in drafts of the Deferred Prosecution Agreement. See e.g., September 17, 2007 email from M. Villafana to J. Leflcowitz attaching draft Deferred Prosecution Agreement, Exhibit 32. 17 While federal prosecutors once suggested that Mr. Epstein's retenti

Petite policy will be served by the following procedure [contained in the Deferred Prosecution Agreement)." See e.g., September 17, 2007 email from M. Villafana to J. Lefkowitz attaching draft Deferred Prosecution Agreement, Exhibit 32. The draft agreement further stated: "Epstein understands that it is hi

at (a) force or coercion would be used to cause Owens to engage in a criminal sex act or (b) that Owens was under the age of 18." (emphasis added). The Eleventh Circuit's interpretation of the statute makes perfect sense: were § 1591 not limited in that fashion, it would threaten to criminalize a host of localized be

6 LAW OFFICES OF GERALD B. LEFGOURT, P.G. A.= Villafana, Esq., Assistant United States Attorney Andrew L

gainst strict liability, especially since it applies in eases whcre there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's decision in United States Murrell, supra, reflects this same understanding of the statute. The Murrell court wrote that, under the "plain language"