Epstein Secrets

nder state law. Confining the statute's reach to such situations is precisely what eliminates what would otherwise be First Amendment problems. See Bailey 228 F.3d at 639 ("Defendant simply does not EFTA00221341 12/07/07 FRI 15:38 FAX 1 K I RKLAND&ELLI S LLP o1s Alan Dershowitz, Esq. December 7,

ny sex act himself, he would nevertheless violate §2422(b)." United States'. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004). See also United States Bailey, 228 F.3d 637, 639 (02' Cu. 2000) ("Congress has made a clear choice to criminalize persuasion and the attempt to persuade, not the performance of

in another state. The travel must be for the purpose of engaging in the unlawful sexual act. See s2 liftmen HufT, 291 U.S. 559, 562-63 (1934) and Mortensen'. United Stales. 322 U.S. 369, 374 (1944) ("An intention that the women or girls shall engage in the conduct outlawed by Section 2 must be found to

sex act himself, he would nevertheless violate §2422(b)." United States v. Murrell 368 F.3d 1283, 1286 (111b Cir. 2004). See also United States v. Bailey, 228 F.3d 637, 639 (6th Cir. 2000) ("Congress has made a clear choice to criminalize persuasion and the attempt to persuade, not the performance of

another state. The travel must be for the purpose of engaging in the unlawful sexual act. See also Hansen v. Huff, 291 U.S. 559, 562-63 (1934) and Mortensen v. Unikd Stales, 322 U.S. 369, 374 (1944) ("An intention that the women or girls shall engage in the conduct outlawed by Section 2 must be found to

the communication itself—not the resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point: The defendant in Bailey contended that attempt under § 2422(6) 'requires the specific intent to commit illegal sexual acts rather than just the intent to persuade or solic

for the purpose of " requi ment fly in the face of the two Suprems Court decisions addressing that element. See Hansen'. Huff, 291 U.S. 559 (1934); Mortensen. United States, 322 U.S. 369 (1944). Santos and Cuellar speak loudly and clearly against prosecutors seeing such elasticity in federal criminal stat

sex act himself, he would nevertheless violate §2422(b)." United States v. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004). See also United States v. Bailey 228 F.3d 637, 639 (02' Cu. 2000) ("Congress has made a clear choice to criminalize persuasion and the attempt to persuade, not the performance of t

n another state. The travel must be for the purpose of engaging in the unlawful sexual act. See so Hansen v. Huff, 291 U.S. 559, 562-63 (1934) and Mortensen v. UnitekStates, 322 U.S. 369, 374 (1944) ("An intention that the women or girls shall engage in the conduct outlawed by Section 2 must be found to

said to act purposefully if 'he consciously desires that result, whatever the likelihood of that result happening from his conduct.' United States !Bailey, 444 U.S. 394, 404 (1980), quoting United Slates u United Slates Gypsum Co., 438 U.S. 22, 445 (1978).7 The Supreme Court has repeatedly interpreted

.7 The Supreme Court has repeatedly interpreted this language to require that the illegal activity be the dominant motive for the travel. See, e.g., Mortensen 'United States, 322 U.S. 369, 373 (1944) (". . .an intention that the women or girls shall engage in the conduct outlawed by Section 2 must be foun

sly met with and , Epstein s assistants in New York and in Florida. Estes stated they travel with Epstein everywhere he goes. I interviewed of Bailey stated she ust arrived from Scotland and has worked with Zeff for only one month. She stated she has never met Epstein and has not seen him. The in

.7 The Supreme Court has repeatedly interpreted this language to require that the illegal activity be the dominant motive for the travel. See, e.g., Mortensen' United States, 322 U.S. 369, 373 (1944) (". ..an intention that the women or girls shall engage in the conduct outlawed by Section 2 must be found

s the communication itself—not the resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point: The defendant in Bailey contended that attempt under § 2422(b) ‘requires the specific intent to commit illegal sexual acts rather than just the intent to persuade or solicit

for the purpose of “ requirement fly in the face of the two Supreme Court decisions addressing that element. See Hansen v. Huff, 291 U.S. 559 (1934); Mortensen v. United States, 322 U.S. 369 (1944). Santos and Cuellar speak loudly and clearly against prosecutors seeing such elasticity in federal criminal sta

the communication itself—not the resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point: The defendant in Bailey contended that attempt under § 2422(b) `requires the specific intent to commit illegal sexual acts rather than just the intent to persuade or solic

r the purpose of " requirement fly in the face of the two Supreme Court decisions addressing that element. See Hansen v. Huff, 291 U.S. 559 (1934); Mortensen v. United States, 322 U.S. 369 (1944). Santos and Cuellar speak loudly and clearly against prosecutors seeing such elasticity in federal criminal st