Epstein Secrets

personal matters and contacts to which he attends in Florida. For example, beginning in 2002, Mr. Epstein visited his mother nearly every weekend in Palm Beach until she passed away in April, 2004. 5 As previously set forth herein, and as more fully explained in other submissions related to this case, the r

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

EPSTEIN employed defendant to perform, among other things, services as personal assistants. 2. Defendant JEFFREY EPSTEIN owned a property located al Palm Beach, Florida, in the Southern District of Florida. EFTA01718577 3. Defendant JEFFREY EPSTEIN was the principal owner of JEGE, INC., a Delaware corpo

o rely on telephone or personal notification. EFTA01718531 U.S. Department of Justice United States Attorney Southern District of Florida West Paint Beach, FL 33401 Facsimile: December 6, 2007 DELIVERY BY UNITED STATES MAIL Miss Re: Crime Victims' Rights — Notification of Resolution of Epstein Inv

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

personal matters and contacts to which he attends in Florida. For example, beginning in 2002, Mr. Epstein visited his mother nearly every weekend in Palm Beach until she passed away in April, 2004. 5 As previously set forth herein, and as more fully explained in other submissions related to this case, the r

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

, more important, fails to say. The Court will notice that Dershowitz devotes only a single sentence in his affidavit to his activities at Epstein's Palm Beach and New York mansions. See DE 282-I at 3 ("As to Mr. Epstein's homes in New York City and Palm Beach, I categorically state that I never had any sex

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

ds. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and

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

ed to escalate and occurred during two years. The routine became familiar t . Epstein's assistant Sara would telephone her every time Epstein was in the Town of Palm Beach and would place appointments for her to visit and work for Epstein tated Epstein would photograph them naked and having sex and proudly display the

dence he did not want to encounter the Alessis during his stay in Palm Beach. I then spoke with Mr. Alessi in the presence of his attorney, Donnie Murrell. Mr. Alessi stated that he was employed for eleven years with Mr. Epstein. He originally was hired as a part time employee and then moved up into a