Epstein Secrets

, 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

ntalities are used only for interstate activities pursuant to the Commerce Clause. Evans. 5) Section 2422(b) is not unconstitutionally vague. U.S. I Bolen, 136 Fed. Appx. 325 (111° Cir. 2005). 6) Section 2422(b) is not unconstitutionally overbroad or vague. U.S.' Thomas, 410'. 3d 1235 (10" Cir. 2005)

of jurisdiction because judge knew that she could depart downward. 19 EFTA00224153 COURT CASES FACILITY FACTS/COMMUNICATION CHARGE U.S. I Bailey, 228 F.3d 637 (6s Cir. 2000) Internet Defendant contacted minors through Internet; used graphic language describing how he wanted to perform o

o meet with another & arrested when he showed up to meet her. Conviction affirmed. 2422(b) Not Consummated Showed up for meeting Sting U.S. I Bolen. 136 Fed. Appx. 325 (11° Cir. 2005) Unpublished 1iternet Internet chat room "sex with younger"; conversations with "25 yr-old mother of 3 yr-ol

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

57 (11" Cir. 2006); Chilled States' Searcy, 418 F.3d 1193 (11* Cir. 2005); United States' Scott, 426 F. 3d 1324 (11th Cir. 2005); and United States. Bolen, 136 Fed. Appx. 325 (I Id' Cir. 2002). 12 Several Courts of Appeal have held that, in a prosecution under §2422(a), the defendant need not know th

t she could depart downward. 17 EFTA01729501 • COURT .. .... r %. • AS' - -.. *AMITY :. OO)$/g.PNOWNICAtI0N, ' ' , COAR.qE..- , U.S. v. Bailey, 228 F.3d 637 (61h Cir. 2000 ) Internet Defendant contacted minors through Internet; used graphic language describing how he wanted to perform

to meet with another & arrested when he showed up to meet her. Conviction affirmed. 2422(b) Not Consummated Showed up for meeting Sting U.S. v. Bolen, 136 Fed. Appx. 325 (11th Cir. 2005) Unpublished Internet Internet chat room "sex with younger"; conversations with "25 yr-old mother of 3 yr-o

at she could depart downward. 17 EFTA00079430 {nv , . ,..y..4 .,,p.th : I r . j"'T ' -77 SS aks24.2-2.(b: 74;11-. 1~.9 iwic.# U.S. v. Bailey, 228 F.3d 637 (6th Cir. 2000) Internet Defendant contacted minors through Internet; used graphic language describing how he wanted to perform

meet with another & arrested when he showed up to meet her. Conviction affirmed. 2422(b) Not Consummated Showed up for meeting Sting U.S. v. Bolen, 136 Fed. Appx. 325 (11'h Cir. 2005) Unpublished Internet Internet chat room "sex with younger"; conversations with "25 yr-old mother of 3 yr-o

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

of a facility of interstate commerce; (2) to knowingly persuade, induce, entice or coerce, as well as the other elements. See also United States v. Bolen, 136 Fed. Appx. 325, 2005 WL 1475845 (11th Cir. 2005). EFTA01660170 LAW OFFICES CW GERALD B. LEPCOURT. PC. Esq. , Esq. , Esq. Esq. e mt ta

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

of a facility of interstate commerce; (2) to knowingly persuade, induce, entice or coerce, as well as the other elements. See also United States v. Bolen, 136 Fed. Appx. 325, 2005 WL 1475845 (11th Cir. 2005). EFTA00284180 LAW orrocts or GERALD B. La?comm. PC. The United States Attorney's Office