Epstein Secrets

acility (the mail, phone, or intemet)—not thereafter—and the scienter element must be present while the facility is being used. See United States v. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004) ("[T]he government must first prove that [Defendant], using the Internet, acted with a specific intent to per

tute the offence." Russell v. United States, 369 U.S. 749, 764-65 (1962) (quoting United States v. Hess, 124 U.S. 483, 487 (1888); United States v. Carll, 105 U.S. 611, 612 (1881)). The FAC does not come close to discharging that burden. A. The applicable version of § 2255 only permits "minors" to sue

acility (the mail, phone, or intemet)—not thereafter—and the scienter element must be present while the facility is being used. See United States v. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004) ("[T]he government must first prove that [Defendant], using the Internet, acted with a specific intent to per

tute the offence." Russell v. United States, 369 U.S. 749, 764-65 (1962) (quoting United States v. Hess, 124 U.S. 483, 487 (1888); United States v. Carll, 105 U.S. 611, 612 (1881)). The FAC does not come close to discharging that burden. A. The applicable version of § 2255 only permits "minors" to sue

acility (the mail, phone, or intemet)—not thereafter—and the scienter element must be present while the facility is being used. See United States v. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004) ("[T]he government must first prove that [Defendant], using the Internet, acted with a specific intent to per

tute the offence." Russell v. United States, 369 U.S. 749, 764-65 (1962) (quoting United States v. Hess, 124 U.S. 483, 487 (1888); United States v. Carll, 105 U.S. 611, 612 (1881)). The FAC does not come close to discharging that burden. A. The applicable version of § 2255 only permits "minors" to sue

acility (the mail, phone, or intemet)—not thereafter—and the scienter element must be present while the facility is being used. See United States v. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004) ("[T]he government must first prove that [Defendant], using the Internet, acted with a specific intent to per

tute the offence." Russell v. United States, 369 U.S. 749, 764-65 (1962) (quoting United States v. Hess, 124 U.S. 483, 487 (1888); United States v. Carll, 105 U.S. 611, 612 (1881)). The FAC does not come close to discharging that burden. A. The applicable version of § 2255 only permits "minors" to sue

acility (the mail, phone, or intemet)—not thereafter—and the scienter element must be present while the facility is being used. See United States v. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004) ("[T]he government must first prove that [Defendant], using the Internet, acted with a specific intent to per

tute the offence." Russell v. United States, 369 U.S. 749, 764-65 (1962) (quoting United States v. Hess, 124 U.S. 483, 487 (1888); United States v. Carll, 105 U.S. 611, 612 (1881)). The FAC does not come close to discharging that burden. A. The applicable version of § 2255 only permits "minors" to sue