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entry [into the United States] cannot be said to be with the purpose `only that she might live in a state of concubinage."' 291 U.S. at 562. And in Mortensen, the Court likewise held that two women who took a trip from their home, returned home, and then resumed their illegal prostitution business did not
ida aboard the Boeing 727 aircraft owned by JEGE, INC. (200) On or about August 25, 2004, Defendants JEFFREY EPSTEIN, and traveled from Ecuador to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (201) On or about October 2, 2004,1fendants JEFFREY EPS MIN, SARAH KELLEN, and NADIA MA
State's prosecution of Mr. Epstein was in any manner tainted by corruption, incompetence, or undue influence. Barry Krischer, the deeply respected Palm Beach County State Attorney, has served in that office, elected, reelected, and reelected yet again, for 12 years. Lana Belohlavek, the lead State prosecutor in this m
for the purpose of " requi ment fly in the face of the two Suprems Court decisions addressing that element. See Hansen'. Huff, 291 U.S. 559 (1934); Mortensen. United States, 322 U.S. 369 (1944). Santos and Cuellar speak loudly and clearly against prosecutors seeing such elasticity in federal criminal stat
evidentiary hurdles that have been identified, the existence of a State felony plea and sentence that have been advocated by the State Attorney for Palm Reach County, and the many issues of prosecutorial misconduct and overzealousness that have permeated the investigation. I also request that you provide us with
n another state. The travel must be for the purpose of engaging in the unlawful sexual act. See so Hansen v. Huff, 291 U.S. 559, 562-63 (1934) and Mortensen v. UnitekStates, 322 U.S. 369, 374 (1944) ("An intention that the women or girls shall engage in the conduct outlawed by Section 2 must be found to
I T-011 P.004/004 F-076 STATE OF FLORIDA vs. JEFFREY EPSTEIN, Defendant. IN THE CIRCUIT COURT OF THE FIFTEEN111 JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 2006CF009454AIOC NOTICE OF HEARING PLEASE TAKE NOTICE that the undersigned hu called up for hewing the following: JUDGE: San
in another state. The travel must be for the purpose of engaging in the unlawful sexual act. See s2 liftmen HufT, 291 U.S. 559, 562-63 (1934) and Mortensen'. United Stales. 322 U.S. 369, 374 (1944) ("An intention that the women or girls shall engage in the conduct outlawed by Section 2 must be found to
nett T-011 P.004/004 F-076 STATE OF FLORIDA vs. JEFFREY EPSTEIN, Defendant IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, N AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 2006CF009454A3DC NOTICE OF HEARING PLEASE TAKE NOTICE that the undersigned hes called up for hewing the following: JUDGE: Sa
prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen v. United States , 322 U.S. 369, 374 (1944); Crespo v. United States , 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of
aused one or more calls to be made to a telephone used by Jane Doe #1. # . On or about March 31, 2005, EPSTEIN traveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned b Defendant JEGE, INC. . On or about March 31, 2005, EPSTEIN and caused Jane Doe #1 to make a cal
prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen. United States, 322 U.S. 369, 374 (1944); Crespo I. United States, 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of ten
ometimes brought his assistant/girlfriend, into the sexual activity. On October 18, 2005, PBPD obtained a search warrant with the assistance of the Palm Beach County State Attorney's Office ("PBSAO"). By this time, PBSAO had already been contacted by Epstein's cadre of lawyers. When PBPD arrived at Epstein's home
ometimes brought his assistant/girlfriend, into the sexual activity. On October 18, 2005, PBPD obtained a search warrant with the assistance of the Palm Beach County State Attorney's Office ("PBSAO"). By this time, PBSAO had already been contacted by Epstein's cadre of lawyers. When PBPD arrived at Epstein's home
Page: EFTA02857524_p2 →prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen v. United States, 322 U.S. 369, 374 (1944); Crespo v. United States, 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of t
Page: EFTA02857524_p23 →prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen v. United States , 322 U.S. 369, 374 (1944); Crespo v. United States , 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of
Page: EFTA02857763_p13 →lls to be made to a telephone used by Jane Doe #11. EFTA02857805 80. On January 6, 2005, Defendant EPSTEIN traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft ownec,,endant, HYPERION, AIR, INC. 105. On February 24, 2005, Defendants EPSTEIN, , and traveled from Tete
Page: EFTA02857763_p44 →prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen v. United States , 322 U.S. 369, 374 (1944); Crespo v. United States , 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of
Page: EFTA02857810_p12 →more calls to 917-855-3363. # . On or about March 30, 2005, #1. #1. # . On or about March 31, 2005, EPSTEIN traveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned b Defendant i JEGE, INC. . On or about March 31, 2005, EPSTEIN and caused Jane Doe #1 to place a
Page: EFTA02857810_p21 →Entities connected to both Mortensen and Palm Beach County

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Alexander Acosta
PERSONLeon Black
PERSONthe Southern District
LOCATION
United States
LOCATIONJane Doe
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Department of Justice
ORGANIZATION
Palm Beach
LOCATION
Ghislaine Maxwell
PERSONRoy Black
PERSONFBI
ORGANIZATION
West Palm Beach
LOCATION
Donald Trump
PERSONGerald Lefcourt
PERSON
Barry Diller
PERSON