Epstein Secrets

). B. Personal Jurisdiction 5] The Plaintiff has the burden of establishing personal jurisdiction by a pre- ponderance of the evidence. Combs v. Bakker, 886 F2d 673 (4th Cir.1989). A two-prong test governs an analysis of in personam jurisdiction. The first prong re- quires that the activiti,te defe

arie C. (USAFLS) From: Vi°Mena. Ann Mane C. (USAFLS) Sent: Tuesday. July 31, 2007 1:37 PM To: Sloman, Jeff (USAFLS); Menchel, Matthew (USAFLS); Lourie. Andrew (USAFLS) Subject: Emailing: Conf Plea Negotiations.wpd Attachments: Conf Plea Negotiations.wpd Hi all -- I fixed some typos. Here is the

ro tune to produce to attorney Jonathan Biran of Baker Donelson grand jury material relevant to his repr

ffrey Sloman and Andrei Londe arguing against federal prosecution. 34 7/13/2007 Letter from Roy Black to Marie Villa' la with handwritten attorney Lourie notes 35 7/25/2007 latter from Gerald l.efrourt and Alan Dershowia to Matthew Menchel arguing that no charge can or should be made under 18 U.S.C

l division. Please advise if further information is needed. Sincerely, dal Marta rilliskrages. A. Marie Villafaila Page 58 of 58 EFTA00225540 BAKER,DONELSON 100 116111 STREET • BALTIMORE, MARYLAND 21202 • 410.685.1120. bakerdonelson.com JONATHAN BRAN Direct Dial: 410.862.1073 E-Mail Addresall

so the plea agreement would have had to be a binding plea pursuant to Fed. R. Crim. P. 11(c)(1)(C), which is what I drafted. I was informed by Mr. Lourie that USA Acosta did not want to do a (c)(1)(C) plea, so I had to find charges that would result in a two-year statutory maximum. This resulted in m