Epstein Secrets

review of the sufficiency of evidence. Walter M. Campbell, Lillie & Bryant, Los Angeles, Cal., Robert B. M

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,

1 [None] Use of intemet to entice 14011 minor to engage in sex activity. 05- Timothy 4 2 counts of 2422(b) Use of intemet to entice 14024 Campbell 18 U.S.C.S. 2252(aX2); minor to engage in sex activity. 18 U.S.C.S. 2252(AX4XB) Received and possessed child pornography that had been trans

a phone) as the vehicle of the inducement. See, e.g., United States v. Mune!, 368 17.3d 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

11° Cir. 1999); United States v. Rojas, 145 Fed. Appx. 647 (11° Cir. 2005); United States it Root, 296 F.3d 1222 (11th Cir. 2002). United States it Murrell, 368 F3d 1283 (11th Cir. 2004), is in the same mold, except that, in that sting operation, the defendant communicated, not with the purported 13 yea

t be: an "efficient and compelling purpose," United States v. Meacham, 115 F.3d 1488, 1495 (10' Cir. 1997); a "motivating purpose," United States v Campbell, 49 F.3d 1079, 1083 (56 Cir. 1995), or "at least one of the defendant's motivations for taking the trip in the first place," United States v Ellis,

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 (111b Cir. 2004). See also United States v. Bailey, 228 F.3d 637, 639 (6th Cir. 2000) ("Congress has made a clear choice to crim

OLD DAVID J. HARDY WM SCOTT WICKLINE PAMELA L. CAMPBELL PAMELA C DEEM PHILIP J. CO/ABS STEPHANE D. THI

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

al conduct must be: an "efficient end compelliog purpos United States' Meacham 115 F.3d 1488, 1495 (10°' Cir. 1991); a "motivating purpose," Unitt. Campbell 49 F.3d 1079, 1083 (5° 1995), or "at least one of the defendant's motivations for taking the trip in the first place," United States I. Ellis 935 F

(e.g. with himself or a third party), without then actually committing any sex act himself, he would nevertheless violate §2422(b)." United States'. Murrell, 368 F.3d 1283, 1286 (1 I th Cir. 2004). See also United States'. Bailey 228 F.3d 637, 639 (61° Cir. 2000) ("Congress has made a clear choice to cri

[None] Use of internet to entice 14011 minor to engage in sex activity. 05- Timothy 4 2 counts of 2422(b) Use of internet to entice 14024 Campbell 18 U.S.C.S. 2252(a)(2); minor to engage in sex activity. 18 U.S.C.S. 2252(A)(4)(B) Received and possessed child pornography that had been tr

th the purported 13 year old girl, but with an undercover agent holding himself out to be the imaginary girl's father. The initial contacts between Murrell and the agent occurred in internet chatrooms named "family love" and "Rent F Vry Yng." Over time, Murrell sought to make arrangements with the girl'

[None] Use of intemet to entice 14011 minor to engage in sex activity. 05- "I imothy 4 2 counts of 2422(6) Use of intemet to entice 14024 Campbell 18 U.S.C.S. 2252(aX2); minor to engage in sex activity. 18 U.S.C.S. 2252(AX4)(B) Received and possessed child pornography that had been tran

r"o4-eit • „ , • _ w02, 01.4,1 \I! , , is ;fig 1/4 Case No. 08-80736-CV-MARRA P-011951 EFTA00226739 Definitions of Inducument I) U.S. I Murrell, 3681. 3d 1283, 1287 (II" Cir. 2004). In a charge of violation §2422(b), the term "induce means to stimulate the occurrence of "or to" cause the min

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

DAVID J. HARDY : WM. SCOTT WICKLINE oa PAMELA L, ‘CAMPBELL PAMELA C. DEEM FACSIMILE! PHILIP J. COMBS STEPH