EFTA00081319.pdf
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Case 9:08-cv-80736-KAM Document 361-55 Entered on FLSD Docket 02/10/2016 Page 1 of 2
EXHIBIT
55
EFTA00081319
Crthaii 91148:C3€86170ditaKs Document 361-55 Entered on FLSD Docket 02/10/2016 INg ? 81.3
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Re: JE negotiations
1 message
Jay Lefkowitz< JLefkowitz@kirkland.com>
Sun, Sep 16, 2007 at 11:44 AM
To:
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 S
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 .—t 1 at her home. The agents and I would
need to speak with
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.
it**
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EFTA00081320
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| Filename | EFTA00081319.pdf |
| File Size | 193.4 KB |
| OCR Confidence | 85.0% |
| Has Readable Text | Yes |
| Text Length | 2,230 characters |
| Indexed | 2026-02-11T10:28:06.464112 |