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Gmail - Re: JE negotiations¶
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Ann Marie Villafana¶
Re: JE negotiations¶
1 message¶
Jay Lefkowitz< JLefkowitz@kirkland.com>¶
To: Ann Marie Villafana¶
Sun, Sep 16, 2007 at 11:44 AM¶
Yes. Will check it out this pm. Sending you various suggested edits shortly as well.¶
----- Original Message -----¶
From: “Ann Marie Villafana”¶
Sent: 09/16/2007 11:41 AM AST¶
To: Jay Lefkowitz¶
Subject: Re: JE negotiations¶
Hi Jay — I looked up some 11th Circuit cases on simple assault and found some good language. I also learned that, every moment that one is aboard an enclosed civil airplane, they are in the “special aircraft jurisdiction of the United States,” so the assault charge is really a violation of 49 USC 46506, which doesn’t change the penalties.¶
I have drafted up a factual proffer that I would use at the change of plea based upon our brief conversation and the agents’ interaction with Ms. Groff at her home. The agents and I would need to speak with Ms. Marcinkova and Ms. Groff briefly to confirm that these facts are true. Feel free to make suggestions.¶
On an “avoid the press” note, I believe that Mr. Epstein’s airplane was in Miami on the day of the Ms. Groff telephone call. If he was in Miami-Dade County at the time, then I can file the charge in the District Court in Miami, which will hopefully cut the press coverage significantly. Do you want to check that out?¶
I will talk to you later. Thanks.¶
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