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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
red to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for 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
red to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for 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
red to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for 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. 11 at 248:17-20 (naming those properties)); and "interact" is an expansive word aimed at captu
red to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for 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
red to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for i
Entities connected to both New Mexico and Nitsche

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONthe Southern District
LOCATION
George W. Bush
PERSON
Palm Beach
LOCATION
Bradley Edwards
PERSON
Prince Andrew
PERSONJane Doe
PERSONFBI
ORGANIZATION
Colorado
LOCATION
Virginia Giuffre
PERSON
Scarlett Johansson
PERSONMaria Farmer
PERSON
Julie K. Brown
PERSON
Stephen Hawking
PERSON
George Mitchell
PERSON
Michael Jackson
PERSON
David Boies
PERSON
Bill Richardson
PERSON