HOUSE OVERSIGHT 012156 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. o also 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, Ir., p. 22. o stated that old her say that she was 18 if asked. See Tab 14, Tr. A, p. 8. stated that she "told him I was 19." See Tab 5, Tr., p. 16. • 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. o 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. o also stated "[s]ometimes [Mr. Epstein] just wanted his feet massaged. Sometimes he just wanted a back massage." See Tab 6, Tr., p. 19. • Mr. Epstein did not use an interstate facility to communicate an illegal objective to the alleged victims (necessary for a conviction under § 2422(b)). o confirmed that Mr. Epstein never emailed, texted, or chatted in an Internet chat room with her. See Tab 13, (deposition), p. 30. • Mr. Epstein did not target minors (necessary for a conviction under § 2422(b)) o stated, "I always made sure -- I had a fake ID, anyways, saying that I was 18. And I (who is 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, Fr., p. 8. • Mr. Epstein did not use the phone or the Internet to induce proscribed sexual activity (necessary for a conviction under § 2422(b)). o stated that there was never any discussion over the phone about her coming over to Mr.