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.
© [BRE stated that Mold her say that she was 18 if asked. See Tab 14, Tr. A, p. 8.
oO FP 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) | also stated “[s]ometimes [Mr. Epstein] just wanted his feet massaged. Sometimes he just wanted a back massage.” See Tab 6, 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) fF 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))
© [ERRRRRRM stated, “I always made sure -- I had a fake ID, anyways, saying that I was 18. And [I (who is HM 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 Intemet to induce proscribed sexual activity (necessary for a conviction under § 2422(b)).
° 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
HE or another assistant] was, ‘Are you willing to come over,’ or,
I
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