Epstein Secrets

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

"[T]he government must show that the criminal sexual act was a dominant purpose of the trip, not a merely incidental one.") (citing United States v. Hayward, 359 F.3d 631, 638 (3d Cir. 2004)) (emphasis added). That interpretation of the law is obviously correct. While § 2423(b) is relatively new—it firs

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

"[T]he government must show that the criminal sexual act was a dominant purpose of the trip, not a merely incidental one.") (citing United States v. Hayward, 359 F.3d 631, 638 (3d Cir. 2004)) (emphasis added). That interpretation of the law is obviously correct. While § 2423(b) is relatively new—it firs

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

"[T]he government must show that the criminal sexual act was a dominant purpose of the trip, not a merely incidental one.") (citing United States v. Hayward, 359 F.3d 631, 638 (3d Cir. 2004)) (emphasis added). That interpretation of the law is obviously correct. While § 2423(b) is relatively new—it firs

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

"[T]he government must show that the criminal sexual act was a dominant purpose of the trip, not a merely incidental one.") (citing United States v. Hayward, 359 F.3d 631, 638 (3d Cir. 2004)) (emphasis added). That interpretation of the law is obviously correct. While § 2423(b) is relatively new—it firs

fighting at school because the other girl accused Jane Doe #2 of being a prostitute, one of the school principals intervened. The principal searched Jane Doe #2's purse and found $300 cash. The principal asked Jane Doe #2 where the money came from. Jane Doe #2 initially claimed that she earned the money w

d engage in illegal sexual activity. In other words, the illegal sexual activity must have not been merely incidental to the trip. United States v. Hayward, 359 F.3d 631, 637-38 (3d Cir. 2004). See also United States v. Garcia-Lopez , 234 F.3d 217, 220 (5th Cir. 2000) (The district court did not err in

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

"[T]he government must show that the criminal sexual act was a dominant purpose of the trip, not a merely incidental one.") (citing United States v. Hayward, 359 F.3d 631, 638 (3d Cir. 2004)) (emphasis added). That interpretation of the law is obviously correct. While § 2423(b) is relatively new—it firs

a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to (6) In or around 2002, Defendant JEFFREY EPSTEIN paid $400 to Jane Doe #2, who was then fifteen years' old, to (7) In or around 2002, Defendant JEFFREY EPSTEIN asked Jane Doe #2 if she had any younger friends who woul

person, regardless of that person's age. Rather, it criminalizes travel for the purpose of engaging in unlawful sexual activities. Unkd State4 v. Hayward, 359 F.3d 631, 638 (3d Cir. 2004). Sec also United States v. Tykarslcy, 446 F.3d 458, 471 (3d Cir. 2006): EFTA01718552 12/07/07 FRI 15:39 FAX 1

engage in illegal sexual activity. In other words, the illegal sexual activity must have not been merely incidental to the trip. United States v. Hayward, 359 F.3d 631, 637-38 (3d Cir. 2004). See also United States v. Garcia-Lopez, 234 F.3d 217, 220 (5th Cir. 2000) (The district court did not err in i

m trash pulls, the flight manifests from Epstein's private lanes, and testimony from the girls about how the appointments were made. So, if called Jane Doe ake an appointment on January 1st; Epstein traveled to Florida on January 2nd; and Weaned Jane Doe #12 on 18 EFTA02857620 January 3rd (when they wer

JD#2 was 14 when she was brought to JE's home in 2001. JD#1 told JD#2 that she could make $300 for giving a massage to a man in Palm Beach. JD#1 2 Jane Doc #1 was brought to JE's home by Ghislaine Maxwell after Maxwell met her at Mar a Lago. Jane Doe #1 was 15 at the time of her first contact with JE an