Epstein Secrets

tate. The travel must be for the purpose of engaging in the unlawful sexual act. See s2 liftmen HufT, 291 U.S. 559, 562-63 (1934) and Mortensen'. United Stales. 322 U.S. 369, 374 (1944) ("An intention that the women or girls shall engage in the conduct outlawed by Section 2 must be found to exist before th

nduct, with any person, regardless of that person's age. Rather, it criminalizes travel for the purpose of engaging in unlawful sexual activities. United State;'. Hayward 359 F.3d 631, 638 (3d Cir. 2004). See also United States'. Tykarsky 446 F.3d 458, 471 (3d Cir. 2006): EFTA00221344 12/07/07 FRI 15:39

e," United States Cagithli. 49 F.3d 1079, 1083 (56 Cif( 1995), or "at least one of the defendant's motivations for taking trip in the first place," United Statist I EU& 935 F.2d 365, 389 (In Cir. 1991). Swain }Widow', 224 Fed. Appx. 923 (1 I s Cu. 2007) (unpublished). EFTA00221345 12/07/07 FRI 15:40 FAX 1

d to offer my views regarding the case of Jeffrey Epstein ("Mr. Epstein"), who entered into a Deferred Prosecution Agreement ("the Agreement") with the United State's Attorney's Office for the Southern District of Florida ("USAO") to resolve state and federal criminal investigations relating to his actions involvi

as a myriad of other federal crimes, and worked closely with law enforcement officials at the local and state levels. From 1973 through 1987, I was a United States District Judge for the District of New Jersey and presided over many criminal trials and proceedings. In 1979 I was selected by the United States D

germent via the Internet. EFTA00221337 12/07/07 FRI 15:36 FAX I KIRKLAND&ELLIS LLP [ib014 Alan Dershowitz, Esq. December 7, 2007 Page 7 See United Sates 1. Searcy 418 F.3d 1193, 1197 (11th Cir. 2005) (citing H.R. Rep. No. 104.458, at 193 (1996) (Conf.Rep.)). ace ast K. Seto, Note- How S_hould Legislati

s, have essentially involved a standard fact pattern where an undercover agent pretends to be a young teenager on-line, and is directly solicitated. See United States'. Farner 251 F.3d 510 (5th Cir. 2001). See also Cagifitatest Root 296 F.3d 1222, 1227- 28 (11th Cir. 2002); United States I. Sims, 428 F.3d 945, 959

uant to the tenns of the Agreement, please note that the plea and sentencing hearing have been scheduled foe Mowry 4, 2008 at 8:30 am. before Judge Sandra McSorley (please see attached notice of hearing). In addition. as expressed in my voicemail message to you earlier, I would request that tho Office hold off

te. The travel must be for the purpose of engaging in the unlawful sexual act. See so Hansen v. Huff, 291 U.S. 559, 562-63 (1934) and Mortensen v. UnitekStates, 322 U.S. 369, 374 (1944) ("An intention that the women or girls shall engage in the conduct outlawed by Section 2 must be found to exist before the

of his parents. Mr. Epstein surely did not go Some Courts have held that the illicit sexual conduct must be: an "efficient and compelling purpose," United Stake v. Meacham 115 F.3d 1458, 1495 (10° Cir. 1997); a "motivating purpose " United Suites v. clugfc1.1, 49 F.3d 1079, 1083 (5° Cir. 1995). Of "at least

d to offer my views regarding the case of Jeffrey Epstein ("Mr. Epstein"), who entered into a Deferred Prosecution Agreement ("the Agreement") with the United State's Attorney's Office for the Southern District of Florida ("USAO") to resolve state and federal criminal investigations relating to his actions involvi

5). Of "at least one of the defendant's motivations for taking the trip in the first place," united States v. Sail 935 F.2d 385, 389 (I° Cir. 1991). SLAWUnited States v. ffotchouez, 224 Fed. Appx. 923 (11° Cir. 2007) (unpublished). EFTA00214726 12/07/07 FRI 15:40 FAX 1 213 680 8500 K RK LANDLELL LIP fril 022

ant to the tams of the Agreement, please note that the plea and sentencing hearing have been scheduled foe January 4, 2008 at 8:30 am. before Judge Sandra McSorley (please see attached notice of hearing). In addition. as expressed in my voicemail message to you earlier, I would request that the Office hold off

Armed Forces of the United States, and includes a conviction or entry of a pica of guilty or nob contenders rosulting in a sanction in any stato of the United Stator or other jurisdiction. A sanction Includes, but is not limited to, a lino, probation community control, parolo, conditional release, control roloaso

Oregonian Publishing Co.'. United States District Court, 920 F.2d 1462 (9th Cir. 1990) 9 U.S. I Rosen, 471 F. Supp. 2d 651 (E.D. Va. 2007) 23 United States'. Kooistra, 796 F.3d 1390 (11th Cir. 1986) 9 State Cases Anderson I E.T., 862 So. 2d 839 (Fla. 4th DCA 2003) 8 Barron'. Florida Freedom Newspap

the companion case had always been assigned to. On that date, retired Judge Deborah Pucillo was substituting for the assigned Division "VV' judge, Sandra McSorley, because Judge McSorley would not be sitting on that day. 4. Judge Pucillo handled all cases assigned to Division "W' on June 30, 2008 including th