Epstein Secrets

EFTA00157660 LAW OFFICES ALLEN GUTHRIN: MCHUGH & THOMAS, PLLC GEORGE 43.GUIRRE ROSERT e. PALEN RFJXCCA A. SETTS R. IERRAKE ROCOERS CANSO IS THOMAS ONES S. ARNO° DAVOS HARDY Mt SCOTT WCKLINE PANELS I. CANINO PAMELA C. CON PINUP .S STEPKOIETTHACKER DREAMT J. ANN TERESA K. INOWSON DEBRA

tion to the New York Times 44. Perhaps most troubling of all, the USAO has repeatedly leaked information about this case to the media—including to Landon Thomas, the senior business correspondent for the New York Times. We have personally reviewed Mr. Thomas's own notes, and they are remarkably detailed abo

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

tion to the New York Times 44. Perhaps most troubling of all, the USAO has repeatedly leaked information about this case to the media—including to Landon Thomas, the senior business correspondent for the New York Thnes. We have personally reviewed Mr. Thomas's own notes, and they are remarkably detailed abo

about this case to the media—including to Landon Thomas, the senior business correspondent for the New York Thnes. We have personally reviewed Mr. Thomas's own notes, and they are remarkably detailed about highly confidential aspects of the prosecution's theory of the case and the plea negotiations.

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(6) 'requires the specific intent to commit illegal sexual acts

., E . . 7; Police Report at Tr. at 7, Exhibit 25); who never in unlawful sexual activity or any sexual activity 78, Exhibit 17; Tr., Exhibit 24, Thomas Tr., Exhibit 26 and Tr., Exhibit 2); or, and counse e other ta l' about their ages (see t 38-39, Exhibit 10; Tr. at 16, Exhibit 4; Tr. at 6, 8, 22,

in order to persuade, induce, entice, or coerce a finor to engage in a proscribed sexual act—rather than the sexual act itself. See United States Murrell, 368 F.3d 1283, 1285 (11th Cir. 2004) ("The underlying criminal conduct Congress expressly proscribed in passing § 2422(b) is the persuasion, induc

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

rmation about this case to the media—including to Landon Thomas, the senior business correspondent for the New Yor