Fw: Fwd: Vicky Eiger memo

 Some ramblings   ....A couple of missed points...  for 2422,,, there is case law on what it means to induce or coerce,, the judge said they have common sense meanings, I disagree with the mens rea of inducing being dispositive, as it would be clear that a person on the internet who simply sent a text message , that said I know you are thirteen years old , let's meet for  some sex act, would still be charged with enticement. , the risk is they say that HAley or others recruitng for money could be the inducement.. , it would make litle sense  however, for an interstate  call from a state where the age of consent is 16 to a state where the age of consent is16, and still be liable for a federal crime. WE need ot know if they've ever brought a case with 16 and 17 yearolds. ,as the mann  act and 2423 reference 109a. , there it is clear that the federal age is 16//..I agree that the legislative history and legislatvie intent needs reciting.. , the 2422 response should deal with Lily's portrayal.   .. Recall that the police report, has allegations of four illegal acts,(this might qualify as commercial sex act with a minor). in addition to the one time 14 year old.. who though she is the youngest, , as she was not known before she showed up at the house,, and didn't return,  unless they stretched it to find me a fourteen year old, on the phone, and haley went recruiting, and found one, , but that flies in the face of the girls own stateements that she said she was 18... , and for the federal crime mistake of age ,, is a defense... SO vicky is clear ,, the ages on the police report are the detectives guess as to their ages when he believes they were at the house.. . I agree with Mitch that  lily's and guys comments that they know of no similar case ever being brought , needs to be up front.  I realize that plea cases , would be more difficult to find,, but putting out a request on the the defense counsel blog might  be appropriate. . I would also stresss that plam beach is my home,, , from the phone records, Sarah would call many people and tell them we were coming,, rarely setting up an actual appointment until we were actually there, .. not only not knowing who would come to the house, but in addtion who the recipient of the massage would be.. keep in mind that nadia was only 20. , making even sex with her legal under florida law.. ,  Vicky can speak to me for more of the facts.., We should addresss the Alex Hall fabrications, as that is what the feds are looking at... She says she came to the house multiple times , and had both oral ad vaginal sex, with me, and I knew her age.. Seperate and apart from her total lack of credibility, I think we should craft our argument as if the fbi believes her.. .. No position of authority, no drugs, no legislative intent,, Sarah would have had to known about the sex, , I would have had to know that Sarah was going to use the telephone,, WE both would have had to be aware of her age. ., she brought her boyfrend to the house,, to accompany her.. , before we get into those arguments however, I think it is important that we stress that this was looked at by the state.. , and the federal interest in limited. .