Epstein Secrets

have a history of working diligently on behalf of victims of crime. While at the United States Attorney's Office for the Southern District of West Virginia, I was a part of the prosecution team that prosecuted the first case in the country under the federal Violence Against Women Act. United States v. B

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

959. Decided Nov. 20, 1959. Prosecutions for violations of White Slave Traffic Act. The United States District Court for the Eastern District of Virginia, at Norfolk, Walter E. Hoff- man, J., entered judgment of conviction as to one defendant on three counts and judgment of conviction as to the other

nder § 2422(b) requires a finding only of an intent to entice, not an intent to perform the sexual act following the persuasion); United States v. Murrell. 368 F.3d 1283, 1286 (11th Cir2004) (stat- ing that the underlying conduct that 2422(b) criminalizes is the persuasion of the minor, rather than t

d sexual conversations, tried to entice the victim by representa- tions about his car, house, and money, and went to a prearranged meeting place); Murrell, 368 F.3d at 1288 (holding that the evidence was sufficient where the defen- dant traveled two hours to meet a minor for sex in exchange for money,

have a history of working diligently on behalf of victims of crime. While at the United States Attorney's Office for the Southern District of West Virginia, I was a part of the prosecution team that prosecuted the first case in the country under the federal Violence Against Women Act. United States v. B

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

ere it would have been possible to have sex with Jane Doe #3."). In media statements, Dershowitz has repeatedl

a phone) as the vehicle of the inducement. See, e.g., United States ' Murrel, 368 F.3d 1283, 1286 (11th Cir. 2004) (government must ... prove that Murrell, 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 i

while a minor," was a victim of an offense. 3. Jane Doe #3 I. Epstein, 08-CV-80232-KAM: This suit was filed

facility (the mail, phone, or intemet)—not thereafter—and the scienter element must be present while the facility is being used. See United States'. 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

d from to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, INC. (88) In or around the end of 2004, Defendant led Jane Doe #19, who was then a sixteen-year-old girl, from the kitchen upstairs to Defendant JEFFREY EPSTEIN's bedroom at (89) In or around the end of 2004, Defe

e.g. with himself or a third party), without then actually committing any sex act himself, he would nevertheless violate §2422(b)." United States v. Murrell, 368 F.3d 1283, 1286 (11th Cu. 2004). See also United States v. Bailey 228 F.3d 637, 639 (61° Cir. 2000) ("Congress has made a clear choice to crimi

can remember. 3 A. As many as I can remember. 4 Q. I know it's been a while. 5 A. It was Jody. It was Donna. And it was -- 6 it was Virginia. It was -- how many? Virginia, Lana. 7 It was also a young girl, but she was not a 8 massage therapist. She came to the house as a friend, I 9

gain by 9 his investigator again for any more questions or anything 10 or any packages that he may deliver to you 11 A. They have to go to Mr. Murrell. 12 Q. I was going to say, have him contact your 13 attorney. 14 MR. MURRELL: Packages? Are we expecting a 15 delivery of something? 1

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

394 ‘ORGE G. RI r Gepraoe ST ERE CHARLESTON, WEST VIRGINIA 25333-3304 REBECCA A. BETTS oehiae 500 LEE STREET

at was important for us. 19 don't want to be involved with this thing. I'm out of 20 the job three years ago, and that's why we hired 21 Mr. Murrell. He suggested that. 22 Q. Did he ask you if anybody else has been 23 contacted? 24 A. No. 25 Q. Did he tell you that to call him ba

can remember. 3 A. As many as I can remember. 4 Q. I know it's been a while. 5 A. It was Jody. It was Donna. And it was -- 6 it was Virginia. It was -- how many? Virginia, Lana. 7 It was also a young girl, but she was not a 8 massage therapist. She came to the house as a friend, 9

y as I can remember. 4 Q. I know it's been a while. 5 A. It was Jody. It was Donna. And it was -- 6 it was Virginia. It was -- how many? Virginia, Lana. 7 It was also a young girl, but she was not a 8 massage therapist. She came to the house as a friend, 9 think. I don't think she was a

have a history of working diligently on behalf of victims of crime. While at the United States Attorney's Office for the Southern District of West Virginia, I was a part of the prosecution team that prosecuted the first case in the country under the federal Violence Against Women Act. United States v. B

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