Epstein Secrets

of an opportunity to engage in prohibited conduct. See, e.g,. United States v. Sanchez-Berrios, 424 F.3d 65, 76-77 (1" Cir. 2005); United States v. Brown, 43 F.3d 618, 625 (I1th Cu. 1995). The government cannot fairly, or consistent with the rule of lenity, advocate a broader definition of the same te

to engage in a criminal sex act or (b) that Owens was under the age of 18.) (emphasis added). Again, none of these factors is present in this case. The Eleventh Circuit's interpretation of the statute makes perfect sense: were § 1591 not limited in this fashion, it would threaten to criminalize a host of localized be

09 minor to engage in sex activity. 04- James Brown I [None] Use of intemet to entice 14032 mino

gainst strict liability, especially since it applies in cases where there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's decision in United States Murrell, supra, reflects this same understanding of the statute. The Murrell court wrote that, under the "plain language"

or to engage in sex activity. 04- 14032 James Brown I [None] Use of intemet to entice minor to en

gainst strict liability, especially since it applies in cases where there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's decision in United States v. Murrell, supra, reflects this same understanding of the statute. The Mini! court wrote that, under the "plain language

e pressure or manipulation.. . ." United States Brown, 43 F.3d 618, 625 (11th Cir.), cert. denied, 516

nduce criminal sexual activity at some point after such use, or if the defendant does not actually induce during the use, § 2422(b) does not apply. The Eleventh Circuit's Pattern Jury Instructions recognize as much. According to those Instructions, the Government must prove beyond a reasonable doubt: First: That the

09 minor to engage in sex activity. 04- James Brown 1 [None] Use of intemet to entice 14032 mino

gainst strict liability, especially since it applies in cases where there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's decision in United States Murrell, supra, reflects this same understanding of the statute. The Murrell court wrote that, under the "plain language"