| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Visits to Epstein's home for massage | Epstein's residence | View |
This document is a legal memorandum addressed to Mark Filip arguing against the federal prosecution of Jeffrey Epstein. The author cites deposition testimony from alleged victims (Miller, Beale, Gonzalez, Laduke) to claim there was no interstate coercion, that the women lied about their ages (claiming to be 18), and that the encounters were often non-sexual or consensual without force. The document also criticizes the conduct of federal prosecutors and notes a connection between a prosecutor and civil attorney Jeffrey Herman.
Stated Epstein never touched her physically.
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