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ution ring in Evans was not, in fact, entirely intrastate as the companion case of one of the Evans co-defendants makes clear. See, United States v. Madison, 477 F.3d 1312, 1313-1314 (11th Cir. 2007) (Jane Doe #2 stated that she traveled to Atlanta, Georgia with Madison to work as a prostitute). Thus, c
coercive components that Congress, and administration policy statements intended in 18 U.S.C. § 1591 prosecutions. Evans, and his co-conspirators (Madison and Yearby) were not "Johns." They operated a for profit prostitution ring marked by control of, and extreme violence toward, the victims, who they
of Justice Child Exploitation and Obscenity Section ("CEOS") regarding the federal investigation of Jeffrey Epstein by the United States Attorney's Office for the Southern District of Florida ("USAO"),I I will refrain from recounting Mr. Epstein's arguments in detail here, but, rather, will highlight salient points responsive
coercive components that Congress, and administration policy statements intended in 18 U.S.C. § 1591 prosecutions. Evans, and his co-conspirators (Madison and Yeasty) were not "Johns." They operated a for profit prostitution ring marked by control of, and extreme violence toward, the victims, who they
makes clear. See, United States v. Madison, 477 F.3d 1312, 1313-1314 (11th Cir. 2007) (Jane Doe 42 stated that she traveled to Atlanta, Georgia with Madison to work as a prostitute). Thus, courts, including the Eleventh Circuit in Evans, have underscored the point that § 1591 simply is not intended to
of Justice Child Exploitation and Obscenity Section ("CEOS") regarding the federal investigation of Jeffrey Epstein by the United States Attorney's Office for the Southern District of Florida ("USAO").' I will refrain from recounting Mr. Epstein's arguments in detail here, but, rather, will highlight salient points responsive
90, 99 S.Ct. 1946. And "it is a general and indisputable rule[ ] that where there is a legal right, there is also a legal remedy." I I Marbuty v. Madison, 5 U.S. (I Cranch) 137, 163, 2 L.Ed. 60 (1803) (quoting 3 William Blackstone, Commentaries *23). I agree with the Majority, however, that the prese
dispute that it never conferred with the victims and kept the Agreement secret. See Gov't En Banc Brief at 5. 10 In July 2019, the U.S. Attorney's Office for the Southern District of New York (`SDNY") had unsealed an indictment charging Epstein with a sex-trafficking conspiracy and substantive sex trafficking involving conduct that occur
L WA 55117 BOOK STORES 01/03/17 DEAN & DELUCA /13003 003013003 NEW YORK NY $13059 8002217714 Description GROCERY STORE 01/04/17 diptygue Madison New York NY $302.67 212-879-3330 01/04/17 BAR ITALIA SAN FRANCISCO CA $57.28 8778877815 01/04/17 LADUREE 117000023519038 NEWYORK NY $4
ional purposes. For specific details, please visit your online statement. AMEX002472 SONY_GM_02745771 EFTA_00233027 EFTA01674430 AM E X002473 SD NY _GM_02745772 EFTA_00233028 EFTA01674431 DUPLICATE txpTressCOPY JEFFREY E EPSTEIN Closing Date 06/14/17 New Balance Minimum Payment Due Payme
Entities connected to both Madison and Southern District of New York

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
United States
LOCATION
Prince Andrew
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSONLeon Black
PERSON
Marc Rich
PERSONFBI
ORGANIZATION
Woody Allen
PERSON
Alexander Acosta
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Julie K. Brown
PERSON
John F. Kennedy
PERSONJack Goldberger
PERSONJane Doe
PERSON