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Extracted Text (OCR)
KIRKLAND & ELLIS LLP
also had conversations with other women in which these women hoped
that “Jeffrey didn’t find out [their] age[s].” See Tab 6, Miller Tr., p. 45.
° Ps. stated that she: “would tell my girlfriends just like
approached me. Make sure you tell him you’re 18. Well, these girls that I
brought, I know that they were 18 or 19 or 20. And the girls that I didn’t
Know and I don’t know if they were lying or not, I would say make sure
that you tell him you’re 18.” See Tab 6, Tr., p. 22.
© TBR stated that Mold her say that she was 18 if asked. See
Tab 14, NE Tr. A, p. 8.
oO fF stated that she “told him I was 19.” See Tab ia
Tr., p. 16.
e Mr. Epstein did not know these women would be caused to engage in a sex act
(necessary for a conviction under § 1591) and any sexual activity that took place was
unplanned.
fe) fF | stated “sometimes [Mr. Epstein] likes topless massages, but
you don’t have to do anything you don’t want to do. He just likes
massages.” See Tab 6, Tr., p. 7.
fe) fe also stated “[s]ometimes [Mr. Epstein] just wanted his feet
massaged. Sometimes he just wanted a back massage.” See Tab 6, J
Tr, p. 19.
e Mr. Epstein did not use an interstate facility to communicate an illegal objective to
the alleged victims (necessary for a conviction under § 2422(b)).
fo) PF confirmed that Mr. Epstein never emailed, texted, or chatted
in an Internet chat room with her. See Tab 13, BE deposition),
p. 30.
e Mr. Epstein did not target minors (necessary for a conviction under § 2422(b))
© [ERRRRRNM stated, “I always made sure -- I had a fake ID, anyways, saying
that I was 18. And [J (who is friend who brought her to
Mr. Epstein’s home)] just said make sure_you’re 18 because Jeffrey
doesn’t want any underage girls.” See Tab 6, r., p. 8.
e Mr. Epstein did not use the phone or the Internet to induce proscribed sexual activity
(necessary for a conviction under § 2422(b)).
fe) f stated that there was never any discussion over the phone about
her coming over to Mr. Epstein’s home to engage in sexual activity: “The
only thing that ever occurred on any of these phone calls [with J
ME or another assistant] was, ‘Are you willing to come over,’ or,
I
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