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wo KIRKLAND & ELLIS LLP “Would you like to come over and give a massage.” See Tab 14 Tr. A, p. 15 o MERE consfirmed that she was informed that she was going to Mr. Epstein’s house to give him a massage and nothing else, and that no one “said anything to [her] on the telephone [or over the Internet] about sexual activity with Mr. Epstein.” See Tab 13, EEE (deposition), p. 24- 25. also confirmed that no one associated with Mr. Epstein ever tried to call her or contact her through the Internet to try to persuade, induce, entice or coerce her to engage in any sexual activity. See Tab 13, BR (deposition), p. 31. ¢ Mr. Epstein did not travel to Palm Beach for the purpose of engaging in sexual activity with a minor (necessary for a conviction under § 2423(b)). o Mr. Epstein spent at least 100 days a year in Palm Beach for family purposes, business purposes, and social purposes, and to maintain a home. o While in Palm Beach, Mr. Epstein routinely visits family members and close friends, has seen his primary care physician for checkups and prescribed tests in the Palm Beach area, and until her death in April of 2004, regularly saw his mother who was hospitalized and then ( convalesced in south Florida. oO From 2003 through 2005 there was no month when Mr. Epstein did not spend at least one weekend in Palm Beach. o The Palm Beach area is the home base for his flight operations, for maintenance of his aircraft, and for periodic FAA inspections. © Additionally, Mr. Epstein’s pilots and engineers all resided in Florida. e Mr. Epstein’s conduct did not involve force, coercion or violence and any sexual activity that took place was consensual. The witness transcripts are replete with statements such as the following: fe) PF stated that she was not persuaded, induced, enticed or coerced by anyone to engage in any sexual activity. See Tab 13 a. Tr. (deposition), p. 31. o TE tates: _ —" never tried to force me to do anything.” See Tab 14, o [ERstated, “1 said, 1 told Jeffrey, 1 heard you like massages topless. And he’s like, yeah, he said, but you don’t have to do anything that you POETS 16 HOUSE_OVERSIGHT_012157