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nstruct the jury on law governing the age of consent in New Mexico, the United Kingdom, and Florida. First, the Defendant's proposal oversimplified New Mexico's age of consent law. The Court could not accurately instruct the jury on New Mexico's law without potentially introducing a theory of guilt that the
a single conspiracy can contain multiple objectives, particularly if the objectives share important similarities, as they do here. United States v. Salameh, 152 F.3d 88, 148 (2d Cir. 1998) (citing United States v. 4/Irani, 968 F.2d 1512, 1518 (2d Cir. 1992)). Overlap of participants. The participants i
d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 10 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu
in the indictment was committed by one or more of the members of the conspiracy in furtherance of the objectives of the conspiracy." United Staten. Salameh, 152 F.3d 88, 14546 (2d Cir. 1998). Because a conspiracy does not require the completion of a substantive crime, it does not matter whether Minor V
d conclude that "Jeffrey" is Jeffrey Epstein; "Jeffrey's properties" are Jeffrey Epstein's properties, including his houses in Palm Beach, New York, New Mexico, and the United States Virgin Islands (see, e.g., Ex. 11 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu
the indictment was committed by one or more of the members of the conspiracy in furtherance of the objectives of the conspiracy." United States v. Salameh, 152 F.3d 88, 145-46 (2d Cir. 1998). Because a conspiracy does not require the completion of a substantive crime, it does not matter whether Minor
Entities connected to both New Mexico and Salameh

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONthe Southern District
LOCATIONFBI
ORGANIZATION
New York
LOCATION
Santa Fe
LOCATION
Prince Andrew
PERSON
George W. Bush
PERSON
Julie K. Brown
PERSON
Marc Rich
PERSON
Department of Justice
ORGANIZATION
U.S. Virgin Islands
LOCATION
Southern District of New York
ORGANIZATION
Supreme Court
ORGANIZATION
Scarlett Johansson
PERSON
George Mitchell
PERSON
Palm Beach
LOCATION
Michael Jackson
PERSONEmmy Taylor
PERSON