Re: repeat massages

I thinkwe should also recite the history of the Mann act trafficking, and the history of these statutes.. , since they have asked about gifts,, they could use that fact as part of the so called inducement chain.. re 2423, the case law specifically says that the sex should not be merely incidental to the trip.. they would argue that I saw the same group of girls, often, therefore, at least more tha an incidental reason.. THANKS

----- Original Message ----
From: Mitch Webber mwebber@law.harvard.edu
To: jeeproject@yahoo.com
Cc: dersh@law.harvard.edu
Sent: Thursday, November 9, 2006 10:24:50 PM
Subject: Re: repeat massages

Dear Mr. Epstein,

I missed something.  Alan also wanted me to send you the two paragraphs 

below, which are the beginning of an argument we have to make coving the
masseuses who returned to you home on several occasions.

Sincerely,
Mitch

The "persuasion, inducement, enticement or coercion" element against 

Epstein is actually weakened by the fact that the masseuses regularly
returned to Epstein's home for more massages. There are no allegations
whatsoever that Epstein pressured or threatened anyone to do anything she
didn't want to do. They wanted to come back. If Epstein did not
persuade, induce, entice or coerce them the first time, it is nonsensical
to believe that he did in subsequent interactions, when the girls returned
knowing precisely what how everyone behaved in Epstein's massage room. As
noted earlier, "[t]he underlying criminal conduct ... is the persuasion,
inducement, enticement or coercion of the minor rather than the sex act
itself." No matter what happened between Epstein and his masseuses, the
fact that they kept coming back militates powerfully against any sort of
pressure on Epstein's part.

Even if there was an original "persuasion," it took place entirely within 

Florida -- indeed, within JE's own home, and not across state lines. That
is not a federal crime. Such initial, intrastate "persuasion" does not
metastasize into an interstate federal crime simply because JE's agent
schedule repeat sessions, since such scheduling does not constitute
inducement by use of the modalities of interstate commerce.