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prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen. United States, 322 U.S. 369, 374 (1944); Crespo I. United States, 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of ten
ges Chas been the focus of Epstein's attorneys because she was the youngest girl and the one who brought Epstein's activities to light. Copies of a MySpace page credited to le were provided to the State Attorney's Office and to our office. On that page, llIt states that she is 21 years' old, she drink
ddition, there is the prior consistent statement that made toff/awhile they were in the car driving away from Epstein's home. With respect to the MySpace pagessays that it is inaccurate. When she was confronted with the page before the state grand jury, she denied putting certain items on the page. W
.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
re are two significant problems with that reliance. irst there is no mention of material admissions made UMduring her interview, as well as on her MySpace webpage (discovered by defense investigators and turned over to the State Attorney). A copy of the webpage is annexed at Tab 5. Second, all but omi
was omitted from the Police Report or the Probable Cause Affidavit. • !lies on her Victoria's Secret Job Application. Addition mmtion on Hall's MySpace webpagc casts further doubt on her credibility. For example, she boasts to having engaged in a fraudulent scheme to get hired by Victoria's Secret,
prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen v. United States , 322 U.S. 369, 374 (1944); Crespo v. United States , 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of
oe #2 has been the focus of Epstein's attorneys because she was the youngest girl and the one who brought Epstein's activities to light. Copies of a MySpace page credited to Jane Doe #2 were provided to the State Attorney's Office and to our office. On that page, Jane Doe #2 states that she is 21 years'
.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
are two significant problems w' that reliance. First there is no mention of material admissions made by MI during her interview, as well as on her MySpace webpage (discovered by defense investigators and turned over to the State Attorney). A copy of the webpage is annexed at Tab 5. Second, all but omi
entry [into the United States] cannot be said to be with the purpose `only that she might live in a state of concubinage."' 291 U.S. at 562. And in Mortensen, the Court likewise held that two women who took a trip from their home, returned home, and then resumed their illegal prostitution business did not
uded a s cho-sexual evaluation, lie detector test results showing that Mr. Epstein believed that , one of the two alleged victims, was over 18, and MySpace pages proving that Ms. regularly falsely represented her age to the general public as at least 18. Ms. Belohlavek also found the testimony of one
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
Page: HOUSE_OVERSIGHT_012153 →or talked to Mr. Epstein prior to her arrival at his house; and 3) she lied about her age not only to Mr. Epstein, but, in fact, to the world on her MySpace page when she said that she was 18 years old. Itis, then, also worth noting in this regard that 18 U.S.C. §§2243(c) provides an affirmative defense i
Page: HOUSE_OVERSIGHT_012195 →prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen v. United States, 322 U.S. 369, 374 (1944); Crespo v. United States, 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of t
Page: EFTA02857524_p23 →oe #2 has been the focus of Epstein's attorneys because she was the youngest girl and the one who brought Epstein's activities to light. Copies of a MySpace page credited to Jane Doe #2 were provided to the State Attorney's Office and to our office. On that page, Jane Doe #2 states that she is 21 years'
Page: EFTA02857524_p39 →prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen v. United States , 322 U.S. 369, 374 (1944); Crespo v. United States , 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of
Page: EFTA02857732_p13 →nges has been the focus of Epstein's attorneys because she was the youn est girl and the one who brought Epstein's activities to light. Copies of a MySpace page credited to were provided to the State Attorney's Office and to our office. On that page, states that she is 21 years' old, she drinks and h
Page: EFTA02857732_p20 →prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen v. United States , 322 U.S. 369, 374 (1944); Crespo v. United States , 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of
Page: EFTA02857763_p13 →e #16 has been the focus of Epstein's attorneys because she was the youngest girl and the one who brought Epstein's activities to light. Copies of a MySpace page credited to Jane Doe #16 were provided to the State Attorney's Office and to our office. On that page, Jane Doe #16 states that she is 21 year
Page: EFTA02857763_p22 →prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen v. United States , 322 U.S. 369, 374 (1944); Crespo v. United States , 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of
Page: EFTA02857810_p12 →oe #2 has been the focus of Epstein's attorneys because she was the youngest girl and the one who brought Epstein's activities to light. Copies of a MySpace page credited to Jane Doe #2 were provided to the State Attorney's Office and to our office. On that page, Jane Doe #2 states that she is 21 years'
Page: EFTA02857810_p22 →Entities connected to both Mortensen and MySpace

Jeffrey Epstein
PERSON
Marc Rich
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
George W. Bush
PERSON
Palm Beach
LOCATION
Ghislaine Maxwell
PERSONJack Goldberger
PERSON
Department of Justice
ORGANIZATIONJane Doe
PERSON
Barry Krischer
PERSON
Palm Beach Police Department
ORGANIZATION
Alexander Acosta
PERSONGerald Lefcourt
PERSON
Barry Diller
PERSONRoy Black
PERSON
Prince Andrew
PERSON
New York
LOCATIONJoe Recarey
PERSON