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ate or otherwise interact improperly with persons who turn out to be minors. A prosecution of Mr. Epstein would violate the teachings of Bailey and Panfil. As we believe we persuaded you at the June 26th meeting, Mr. Epstein never targeted minors. On the contrary, what he did — at worst — was akin to
57 (11" Cir. 2006); Chilled States' Searcy, 418 F.3d 1193 (11* Cir. 2005); United States' Scott, 426 F. 3d 1324 (11th Cir. 2005); and United States. Bolen, 136 Fed. Appx. 325 (I Id' Cir. 2002). 12 Several Courts of Appeal have held that, in a prosecution under §2422(a), the defendant need not know th
meeting place. Court vacated & remanded because downward departure not warranted.. 2422(b) Not Consummated Showed up at meeting Sting U.S. v. Panfil, 338 F.3d 1299 (11th Cir. 2003) Internet Internet chat room communications with "13 yr-old"; sexually explicit; told her he would give her powe
to meet with another & arrested when he showed up to meet her. Conviction affirmed. 2422(b) Not Consummated Showed up for meeting Sting U.S. v. Bolen, 136 Fed. Appx. 325 (11th Cir. 2005) Unpublished Internet Internet chat room "sex with younger"; conversations with "25 yr-old mother of 3 yr-o
d at meeting place. Court vacated & remanded because downward departure not warranted.. 2422(6) Not Consummated Showed up at meeting to U.S. v. Panfil, 338 F.3d 1299 (11'h Cir. 2003) Interne( Internet chat room communications with "13 yr-old"; sexually explicit; told her he would give her powe
meet with another & arrested when he showed up to meet her. Conviction affirmed. 2422(b) Not Consummated Showed up for meeting Sting U.S. v. Bolen, 136 Fed. Appx. 325 (11'h Cir. 2005) Unpublished Internet Internet chat room "sex with younger"; conversations with "25 yr-old mother of 3 yr-o
ngly' persuade or entice, or attempt to persuade or entice, minors. United States v. Bailey, 228 F.3d 637, 639 (6th Cir. 2000). See United States v. Panfil, 338 F.3d 1° Indeed, this last problem is best illustrated by any call may claim to have made to solicit persons to massage Mr. Epstein. Though M
of a facility of interstate commerce; (2) to knowingly persuade, induce, entice or coerce, as well as the other elements. See also United States v. Bolen, 136 Fed. Appx. 325, 2005 WL 1475845 (11th Cir. 2005). EFTA01660170 LAW OFFICES CW GERALD B. LEPCOURT. PC. Esq. , Esq. , Esq. Esq. e mt ta
ingly' persuade or entice, or attempt to persuade or entice, minors. United States v. Bailey 228 F.3d 637, 639 (6th Cir. 2000). See United States v. Panfil, 338 F.3d 10 Indeed, this last problem is best illustrated by any calls may claim to have made to solicit persons to massage Mr. Epstein. Though
of a facility of interstate commerce; (2) to knowingly persuade, induce, entice or coerce, as well as the other elements. See also United States v. Bolen, 136 Fed. Appx. 325, 2005 WL 1475845 (11th Cir. 2005). EFTA00284180 LAW orrocts or GERALD B. La?comm. PC. The United States Attorney's Office
at meeting place. Court vacated & remanded because downward departure not warranted. 2422(b) Not Consummated Showed up at meeting Sting U.S. I Panfil, 338 F.3d 1299 (11th Cir. 2003) Internet Internet chat room communications with "13 yr-old"; sexually explicit; told her he would give her powe
ith another & arrested when he showed up to meet her. Conviction affirmed. — 2422(b) Not Consummated Showed up for meeting _ Sting - U.S. I Bolen. 136 Fed. Appx. 325 (11'" Cir. 2005) Unpublished Internet Internet chat room "sex with younger"; conversations with "25 yr-old mother of 3 yr-
gly' persuade or entice, or attempt If to persuade or entice, minors. United States Bailey, 228 F.3d 637, 639 (611' Cir. 2000). See United States' Panfil, 338 I3d 1D Indeed, this last problem is best illustrated by any calls may claim to have made to solicit persons to massage Mr. Epstein. Though Ms
ntalities are used only for interstate activities pursuant to the Commerce Clause. Evans. 5) Section 2422(b) is not unconstitutionally vague. U.S. I Bolen, 136 Fed. Appx. 325 (111° Cir. 2005). 6) Section 2422(b) is not unconstitutionally overbroad or vague. U.S.' Thomas, 410'. 3d 1235 (10" Cir. 2005)
Entities connected to both Panfil and Bolen

Jeffrey Epstein
PERSONDarren Indyke
PERSON
New York
LOCATION
George W. Bush
PERSON
U.S. Virgin Islands
LOCATIONHelder
PERSONBooker
PERSON
Alan Dershowitz
PERSON
Searcy
PERSONRojas
PERSON
Bailey
PERSONAnn Sanchez
PERSONEvans
PERSONMurrell
PERSON
Houston
LOCATION
United States
LOCATIONGerald Lefcourt
PERSONGarrett
PERSONBurgess
ORGANIZATION
New York City
LOCATION