EXHIBIT 54¶
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"Ann Viliatana¶
09/16/2007 11:41¶
AM¶
:4iWf:'-'01,IMPS09P.1baSgh MIR Er a ft00.4 OlaYrat'¶
To "Jay Lefkowitz" <JLefkowitzOkirkland.com> cc bcc¶
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. at her home. The agents and I would need to speak with Ms. I 'f 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 '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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