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

knowingly seeking to persuade or induce someone to engage in activity that would constitute a crime. See Richard A. Posner & Katharine B. Silbaug, A Guide to America's Sex Laws 44 (Univ. of Chi. Press 1998). Accordingly, to violate § 2422(b), an actor must know that he is trying to persuade not only someone under

, 311 I. 3d 557, 161-63 (9" Cir. 2004); U.S.' Meek, 366 3d 705, 720- 22 (9" Cir. 2004); U.S. Panti I, 338 3d 1299, 1300-01 (I I" Cir. 2003); U.S. Bailey, 228 F. 3d 637, 639 (6" Cir. 2000). Case No. 08-80736-C V-MARRA P-011949 EFTA00226737 eattWithentiali th umse Ct. S.An r•&it EIVVY,_ LOHen 1

- communicate or otherwise interact improperly with persons who turn out to be minors. A prosecution of Mr. Epstein would violate the teachings of Bailey and Panfil. As we believe we persuaded you at the June 26th meeting, Mr. Epstein never targeted minors. On the contrary, what he did — at worst — w

gage therein are hugely varied, reflecting different histories, values, politics, and personalities. See Richard A. Posner & Katharine B. Silbaugh, A Guide to America's Sex Laws (1996). The various and shifting societal reasons underlying those laws, and the societal pressures operating in the area, where sexual mo

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

knowingly seeking to persuade or induce someone to engage in activity that would constitute a crime. See Richard A. Posner & Katharine B. Silbaug, A Guide to America's Sex Laws 44 (Univ. of Chi. Press 1998). Accordingly, to violate § 2422(b), an actor must know that he is trying to persuade not only someone under

enge to the statute: "The statute only applies to those who `knowingly' persuade or entice, or attempt to persuade or enticesminors. United States' Bailey, 228 F.3d 637, 639 (6th Cir. 2000). See United States'. Pcmfil, 338 F.3d 1° Indeed, this last problem is best illustrated by any cal may claim to h

gage therein are hugely varied, reflecting different histories, values, politics, and personalities. See Richard A. Posner & Katharine B. Silbaugh, A Guide to America's Sex Laws (1996). The various and shifting societal reasons underlying those laws, and the societal pressures operating in the area, where sexual mo

enge to the statute: "The statute only applies to those who `knowingly' persuade or entice, or attempt to persuade or entice minors. United States' Bailey, 228 F.3d 637, 639 (6th Cir. 2000). See United States' Panfil, 338 F.3d 1° indeed, this last problem is best illustrated by any calls Haley Robson m

gage therein are hugely varied, reflecting different histories, values, politics, and personalities. See Richard A. Posner & Katharine B. Silbaugh, A Guide to America's Sex Laws (1996). The various and shifting societal reasons underlying those laws, and the societal pressures operating in the area, where sexual mo

— communicate or otherwise interact improperly with persons who turn out to be minors. A prosecution of Mr. Epstein would violate the teachings of Bailey and Panfil. As we believe we persuaded you at the June 26th meeting, Mr. Epstein never targeted minors. On the contrary, what he did — at worst — w

gage therein are hugely varied, reflecting different histories, values, politics, and personalities. See Richard A. Posner & Katharine B. Silbaugh, A Guide to America's Sex Laws (1996). The various and shifting societal reasons underlying those laws, and the societal pressures operating in the area, where sexual mo

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

gage therein are hugely varied, reflecting different histories, values, politics, and personalities. See Richard A. Posner & Katharine B. Silbaugh, A Guide to America's Sex Laws (1996). The various and shifting societal reasons underlying thoselaws, and the societal pressures operating in the urea, where sexual mor

e to the statute: "The statute only applies to those who 'knowingly' persuade or entice, or attempt to persuade or entice, minors. United States v. Bailey, 228 F.3d 637, 639 (6th Cir. 2000). See United States v. Panfil, 338 F.3d 1° Indeed, this last problem is best illustrated by any call may claim t

gage therein are hugely varied, reflecting different histories, values, politics, and personalities. See Richard A. Posner & Katharine B. Silbaugh, A Guide to America's Sex Laws (1996). The various and shifting societal reasons underlying those laws, and the societal pressures operating in the area, where sexual mo

e to the statute: "The statute only applies to those who `knowingly' persuade or entice, or attempt to persuade or entice, minors. United States v. Bailey 228 F.3d 637, 639 (6th Cir. 2000). See United States v. Panfil, 338 F.3d 10 Indeed, this last problem is best illustrated by any calls may claim to

gage therein are hugely varied, reflecting different histories, values, politics, and personalities. See Richard A. Posner & Katharine B. Silbaugh, A Guide to America's Sex Laws (19%). The various and shifting societal reasons underlying those laws, and the societal pressures operating in the area, where sexual mor