Epstein Secrets

t amounted to, at most, the solicitation of prostitution, is unprecedented. Since prostitution is fundamentally a mute concern, (see United Stares' Evans, 476 F.3d 1176, n.1 (1Ith Cir. 2007) (federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulation)

letter now accuses me of "manufacturing" charges of obstruction of justice, making obscene phone calls, and violating child privacy laws. When Mr. Lourie told you that those charges would "embarrass the Office," he meant that the Office was unwilling to bend the facts to satisfy Mr. Epstein's desired

egulation). Rather, its reach is limited to sex trafficking that Involves children or is accomplished by force, fraud, or coercion". United States. Evans, 476 F.3d 1176, 1179 n. 1 (II* Cir. 2007). Nor, has the Department of Justice deemed it appropriate. See, e.g. United States Department of Justice C

District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. Sloman, Menchcl and Lourie and Ms. Villafatia: TELEPHONE 12121737.0400 FACSIMILE As you are aware, we represent Jeffrey E. Epstein in connection with your ongoing investig

travel agencies advertising overseas underage sex tou and involved explicit talk of sexual activity with known minors. A fourth is United States' Evans, 476 F.3d 1176 (11ih Cir. 2007) (11th Cir, 2007). But there, in facts far different from those presented here, the defendant "admitted using both a

uthern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Jeffrey Epstein Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafafia: We write as counsel to Jeffrey Epstein to follow-up on our meeting on June 26, 2007. We thought the meeting was extremely produ

to travel agencies advertising overseas underage sex to d involved explicit talk of sexual T activity with known minors. A fourth is United States Evans, 476 F.3d 1176 (11th Cir. 2007) (11th Cir, 2007). But there, in facts far different from ose presented here, the defendant "admitted using both a c

uthern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Jeffrey Epstein Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafafia: TELEPHONE (alai 737-0400 FACSIMILE 1212)124384192 We write as counsel to Jeffrey Epstein to follow-up on our meeting on June

travel agencies advertising overseas underage sex touriand involved explicit talk of sexual activity with known minors. A fourth is United States I Evans, 476 F.3d 1176 (11th Cir. 2007) (11th Cir, 2007). But there, in facts far different from those presented here, the defendant "admitted using both a

uthern District of Florida 500 South Australian Avenue, Suite-400 West Palm Beach, Florida 33401 Jeffrey Epstein Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafafia: We write as counsel to Jeffrey Epstein to follow-up on our meeting on June 26, 2007. We thought the meeting was extremely produ

travel agencies advertising overseas underage sex tour and involved explicit talk of sexual activity with known minors. A fourth is United States'. Evans, 476 F.3d 1176 (11th Cir. 2007) (11th Cir, 2007). But there, in facts far different from those presented here, the defendant "admitted using both a

26 EXHIBIT 43 EFTA00184603 Case 9:08-cv-80736-KAM Document 361-43 Entered on FLSD Docket 02/10/2016 Page 2 of 26 Dear Ms. Villafafia and Mr. Lourie: LAW OFFICES Of GERALD B. LuttatiRT, P.C. A PROFESSIONAL CORPORATION 148 EAST 70'" STREET NEW YORK, NEW YORK 10021 GERALD B. LERCOURT Www1Glef

se motive is often the critical issue, "summary judgment disposition re- mains appropriate if the (non-movantl can- not prevail as a matter of law." Evans v. Technologies Applications & Serv. Co., 80 F2d 954, 958-59 (4th Cir.1996); Ennis v. Nat Asa of Bus. and Edna Redick Inc., 53 F.3d, 55, 62 (4th

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

waiver of right to appeal. 2422(b) Not Consummated Sting 51 EFTA00226345 COURT :CASES. FACILITY FACTS/COMMUNICATION ;41a03[ARGE9e, U.S I Evans. 476 F.3d 1176 (11th Cir. 2007) Telephone/ Prostitution Ring 14 yr-old worked for defendant (& 2 co- defendants) as prostitute; he was pimp &

llafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, July 26, 2007 8:49 AM To: Menthe', Matthew (USAFLS) Cc: Lourie, Andrew (USAFLS) Subject: Epstein Hi Matt - I had hoped to have a revised indictment for our discussion today but Mr. Black's motion has demanded

-MARRA P-011934 EFTA00226722 .O.cet at Gramm B. Liwcount, P.C. Sims, 161 Fed. Appx. 849, 2006 WL 14581 (I I° Cir. 2006) (unpublished). See also Evans, supra, 47613d 1176. The second involves sex tourism sting operations where the defendants signed up for a "Taboo Vacation," usually to go to Costa

District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafana: LLLLL .R3Nt .2o2I 7370400 FACSIMILE 221/066102 As you are aware, we represent Jeffrey E. Epstein in connection with your ongo

tember 24, 2007 Email from J. Lefkowitz to M. Villafana. 22. Ms. Villafana replied that she had “forwarded your message only to Alex [Acosta], Andy [Lourie], and Rolando [Garcia]. I don’t anticipate it going any further than that.” Jd. 23. Ms. Villafana stated that the agreement would be “placed in the

or intimidation. These are the elements required by the statute, and they are not met here. Although CEOS could, perhaps, point to United States v. Evans, 476 F.3d 1176 (11" Cir. 2007) as a case that, standing alone, involved wholly intrastate conduct, the facts of that case are far different in key re

s co-conspirators. None of this type of activity comes close to the facts regarding Mr. Epstein. Finally, but significantly, the prostitution ring in Evans was not, in fact, entirely intrastate as the companion case of one of the Evans co-defendants makes clear. See, United States v. Madison, 477 F.3d 13