Epstein Secrets

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

(15 years) under the Sentencing Guidelines. I have reviewed the submissions made on behalf of Mr. Epstein to the United States Attorney's office in the Southern District of Florida, which concluded that the cited federal statutes are inapplicable to the allegations made against Mr. Epstein and therefore, as a matter

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

false. understand that was recently reprimanded at a special hearing convened by a United States District Judge in the West Palm Beach Division of the Southern District of Florida, for making misrepresentations during a prior sentencing proceeding. In fact, Stephanie Thacker, a former deputy to CEOS Chief Drew Oost

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

Jeffrey Epstein ("Mr. Epstein"), who entered into a Deferred Prosecution Agreement ("the Agreement") with the United State's Attorney's Office for the Southern District of Florida ("USAO") to resolve state and federal criminal investigations relating to his actions involving numerous young women. I am writing becau

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

Jeffrey Epstein ("Mr. Epstein"), who entered into a Deferred Prosecution Agreement ("the Agreement") with the United State's Attorney's Office for the Southern District of Florida ("USAO") to resolve state and federal criminal investigations relating to his actions involving numerous young women. I am writing becau

cts, they travel for that purpose, is to emphasize that which is incidental and ignore what is of primary significance." Id. at 562-63. Likewise, in Mortensen'. United States 322 U.S. 369 (1944), defendants were convicted after two women they employed as prostitutes at their Nebraska brothel traveled to U

ified in the federal investigation file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest thc jurisdiction of the U.S. District Court for the Southern District of Florida over his person and the subject matter. Epstein will not contest that identified victims are persons who, while minors, were victims of

.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

using the intemet, acted with a specific intent to persuade a means to engage in unlawful sex). In fact, we have reviewed every indictment filed in the Southern District of Florida in which there is at least one allegation of a violation of §2422(b). To the extent the facts could be discerned from the indictment, we

going determination, it is not necessary to examine the further contention of appellant that the judgment should be versed under authority of of Mortensen United States, 322 U.S. 369, 64 S.Ct. 1 . The judgment is reversed and the caw remanded with directions to enter judg- ment of acquittal. SANBOR

gent with the Federal Bureau of Investigation, and charges as follows: COUNT ONE 1. From in or about December 2004 to in or about March 2008, in the Southern District of New York and elsewhere, MARK BRENER, a/k/a "Michael," CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," and TAN

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

form, among other things, recruiting services. 4. Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way, Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as '358 El Brillo Way"). 5. DefendaRFFREY EPSTEIN owned a property located at 9 East 71st Street, New York, N

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

form, among other things, recruiting services. 4. Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way, Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El Brillo Way"). 5. Defendant JEFFREY EPSTEIN owned a property located at 9 East 71st Street, New Yor