Epstein Secrets

r 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. It is, then, also worth noting in this regard that 18 U.S.C. §§2243(c) provides an affirmative defense

nt can be found guilty of that offense only if...the defendant believed that such individual was less than (18) years of age..."); United States v. Murrell, 368 F.3d 1283, 1286 (I I1° Cir. 2004) (§ 2422(b) requires that the defendant knowingly target a minor). Importantly, then, all the elements must be

der to sustain a conviction. In particular, § 2422(b) requires that the defendant specifically intended to target a minor. ke,ligh, United States v. Murrell, 368 F.3d 1286 (11th Cir. 2004) ("[T]o prove an attempt the government must first prove that [defendant], using the Internet, acted with a specific

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,

61 (11th Cir. 1949); United States Rojas, 145 Fed. Appx. 647 (11th Cir. 05); United States I Root, 296 F.3d 1222 (11'h Cir. 200 ). United States I Murrell, 368 F.3d 1283 (11th Cir. 2004), is in the same mold, except that, in that tiling operation, the defendant communicated, not with the purported 13 y

r 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. It is, then, also worth noting in this regard that 18 U.S.C. §§2243(c) provides an affirmative defense

rder to sustain a conviction. In particular, § 2422(b) requires that the defendant specifically intended to target a minor. age, a, United States v. Murrell, 368 F.3d 1286 (11th Cir. 2004) ("[T]o prove an attempt the government must first prove that [defendant], using the intemet, acted with a specific

ce, a conviction under the statute only requires a finding that the defendant had an intent to persuade or to attempt to persuade.’ United States v. Murrell 368 F.3d 1283, 1287 (11th Cir. 2004) (citing United States v. Bailey, 228 F.3d 637, 638-39 (6th Cir.2000)). Thus, the targeted criminal conduct must

e statute makes clear, the essence of this crime is 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 r

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

with Epstein's girlfriend as a birthday "gift" to Epstein. Neither is attention paid in the Probable Cause Affidavits of the fact that maintained a MySpace webpage in which she admitted to various criminal and dishonest acts, including creating false references for her work and her extensive drug use.'

dence he did not want to encounter the Alessis during his stay in Palm Beach. I then spoke with Mr. Alessi in the presence of his attorney, Donnie Murrell. Mr. Alessi stated that he was employed for eleven years with Mr. Epstein. He originally was hired as a part time employee and then moved up into a

rder to sustain a conviction. In particular, § 2422(b) requires that the defendant specifically intended to target a minor. age, a, United States v. Murrell, 368 F.3d 1286 (11th Cir. 2004) ("[T]o prove an attempt the government must first prove that [defendant], using the intemet, acted with a specific

r 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. It is, then, also worth noting in this regard that 18 U.S.C. §§2243(c) provides an affirmative defense