DOJ-OGR-00030483.jpg

682 KB

Extraction Summary

6
People
2
Organizations
5
Locations
1
Events
2
Relationships
3
Quotes

Document Information

Type: Letter
File Size: 682 KB
Summary

This letter, dated June 5, 2006, is from Jeffrey Epstein's attorney, Gerald B. Lefcourt, to prosecutor Lanna Belohlavek of the Florida State Attorney's Office. Following up on a recent meeting, the attorney argues against Epstein pleading to a felony aggravated assault charge, primarily due to the risk of mandatory sex offender registration. The letter proposes a plea to misdemeanor solicitation as a more suitable resolution and addresses legal arguments to support this, including that the victim need not be legally defined as a "prostitute" for the charge to apply.

People (6)

Name Role Context
Gerald B. Lefcourt Attorney
His name is on the letterhead of the law firm sending the letter.
Sheryl E. Reich Attorney
Listed on the letterhead of the law firm.
Renato C. Stabile Attorney
Listed on the letterhead of the law firm.
Faith A. Friedman Attorney
Listed on the letterhead of the law firm.
Lanna Belohlavek State Attorney's Office employee
The recipient of the letter, addressed at the Florida State Attorney's Office.
Jeffrey Epstein Client
The subject of the letter (Re: Jeffrey Epstein) and referred to as "the client".

Organizations (2)

Name Type Context
LAW OFFICES OF GERALD B. LEFCOURT, P.C. Law Firm
The sender of the letter, as indicated by the letterhead.
Florida State Attorney's Office Government Agency
The organization where the recipient, Lanna Belohlavek, works.

Timeline (1 events)

2006-06-01
A meeting held in an attempt to resolve the legal matter concerning Jeffrey Epstein.
Representatives from LAW OFFICES OF GERALD B. LEFCOURT, P.C. Lanna Belohlavek

Locations (5)

Location Context
The address of the law firm Gerald B. Lefcourt, P.C.
The location of the law firm Gerald B. Lefcourt, P.C.
The address of the Florida State Attorney's Office where the letter was sent.
The location of the Florida State Attorney's Office.
Mentioned in relation to the State Attorney's Office and the location of the potential aggravated assault charge.

Relationships (2)

Jeffrey Epstein Attorney-Client Gerald B. Lefcourt
The letter is from the law firm of Gerald B. Lefcourt regarding Jeffrey Epstein, who is referred to as "the client".
Gerald B. Lefcourt Professional (Opposing Counsel) Lanna Belohlavek
Lefcourt's law firm is writing to Belohlavek at the State Attorney's Office to negotiate a plea deal in a criminal case.

Key Quotes (3)

"the client would not be subjected to sex offender registration requirements in any state or foreign jurisdiction."
Source
— Unnamed (described as a "clear and joint understanding" with "prior counsel") (Describing a condition of a prior understanding reached before the June 1, 2006 meeting.)
DOJ-OGR-00030483.jpg
Quote #1
"we strongly believe that a plea to misdemeanor solicitation is the more appropriate resolution."
Source
— LAW OFFICES OF GERALD B. LEFCOURT, P.C. (Proposing an alternative plea deal for their client, Jeffrey Epstein.)
DOJ-OGR-00030483.jpg
Quote #2
"the complaining witness need not be a "prostitute" in order to satisfy the elements of the offense."
Source
— LAW OFFICES OF GERALD B. LEFCOURT, P.C. (Making a legal argument to support the proposed misdemeanor solicitation charge and address the prosecutor's concern about labeling the victims.)
DOJ-OGR-00030483.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (2,228 characters)

LAW OFFICES OF
GERALD B. LEFCOURT, P.C.
A PROFESSIONAL CORPORATION
148 EAST 78TH STREET
NEW YORK, NEW YORK 10021
GERALD B. LEFCOURT
lefcourt@lefcourtlaw.com
SHERYL E. REICH
reich@lefcourtlaw.com
RENATO C. STABILE
stabile@lefcourtlaw.com
FAITH A. FRIEDMAN
ffriedman@lefcourtlaw.com
TELEPHONE
(212) 737-0400
FACSIMILE
(212) 988-6192
June 5, 2006
BY HAND
Lanna Belohlavek
Florida State Attorney's Office
401 North Dixie Highway
West Palm Beach, FL 33401
Re: Jeffrey Epstein
Dear Ms. Belohlavek:
As a follow up to our meeting of June 1, 2006, held in an attempt to resolve this matter, we write to address the following issues which have arisen: (1) the risk, were the client to plead to aggravated assault in Florida, that he might be subject to sex-offender registration statutes in other jurisdictions, now or in the future; (2) the nature of the charge of felony "aggravated assault with intent to commit a felony," and how it does not reflect the allegations herein; and, (3) whether a felony conviction itself is justified based on the available evidence.
At the outset of our June 1, 2006 meeting, we were mindful that an understanding had been reached with prior counsel. It was reached, however, with the clear and joint understanding that the client would not be subjected to sex offender registration requirements in any state or foreign jurisdiction. Moreover, the limited time provided did not allow for an opportunity to conduct an even cursory investigation or research into the ramifications. Were any charge to be brought, having now learned of the serious danger a plea to felony aggravated assault presents with regard to sex offender registration, coupled with the facts presented at our meeting and outlined below, we strongly believe that a plea to misdemeanor solicitation is the more appropriate resolution. As we discussed, this could include an agreed upon allocution, as we are mindful of your concern about labeling the girls "prostitutes." In this regard, as we discussed, the law and relevant statute are clear that the complaining witness need not be a "prostitute" in order to satisfy the elements of the offense.
07/26/17
Page 16 of 131
Public Records Request No.: 17-295
DOJ-OGR-00030483

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