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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
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
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
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
, 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
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"
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
penalty ... if, in fact, someone ... is caught and convicted.") (emphasis added). Accordingly, Masha's Law cannot lawfully be applied in this case. The Eleventh Circuit's decision in United States I, Siegel 153 F.3d 1256 (11th Cir. 1998), is virtually on point. In Siegel, the defendant pleaded guilty to charges under
nded Wellington High School in Palm Beach County. 20. During the period of their involvement with the Defendants, Jane Does # 6, 8 and 12 attended Palm, Beach Central High School in Palm Beach County. 21. During- the period of her involvement with the Defendants, Jane Doe #7 attended William T. Dwyer Hig
at (a) force or coercion would be used to cause Owens to engage in a criminal sex act or (b) that Owens was under the age of 18." (emphasis added). The Eleventh Circuit's interpretation of the statute makes perfect sense: were § 1591 not limited in that fashion, it would threaten to criminalize a host of localized be
Entities connected to both Palm Beach and The Eleventh Circuit's

Jeffrey Epstein
PERSON
George W. Bush
PERSONLeon Black
PERSON
United States
LOCATION
Alan Dershowitz
PERSONJack Goldberger
PERSON
New York
LOCATION
Marc Rich
PERSON
New York City
LOCATIONJane Doe
PERSON
Lesley Groff
PERSON
Donald Trump
PERSON
Palm Beach County
LOCATION
U.S. Virgin Islands
LOCATION
Bradley Edwards
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
Bill Clinton
PERSON
Prince Andrew
PERSON
Kenneth Marra
PERSON