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s alleged to have had improper sexual contact, solely in Florida, with women who were under the age of 18. Mr. Epstein maintained residences both in New York and Florida and would repeatedly fly from New York to Florida where his primary residence was located. It is alleged that before he would travel to
ign country for sexual purposes, or for that matter, that he traveled to a foreign country to engage in illicit sexual activities. 1 Instructive is the Eleventh Circuit Pattern Jury Instruction 70.4 which states that the defendant can be found guilty of § I956(aX3)(A) only If (1) he knowingly conducted a financial transacti
s alleged to have had improper sexual contact, solely in Florida, with womcn who were under the age of 18. Mr. Epstein maintained residences both in New York and Florida and would repeatedly fly from New York to Florida where his primary residence was located He would travel to Florida for purposes of re
ay show that Mr. Epstein paid for sexual services, he most certainly did so with untainted, legitimately earned funds. • • • • s Instructive is the Eleventh Circuit Pattern Jury Instrucuun 70.4 which states that the defendant can be found guilty of § 1956(aX3XA) only if (I) he knowingly conducted a financial transaction
s alleged to have had improper sexual contact, solely in Florida, with womcn who were under the age of 18. Mr. Epstein maintained residences both in New York and Florida and would repeatedly fly from New York to Florida where his primary residence was located He would travel to Florida for purposes of re
ay show that Mr. Epstein paid for sexual services, he most certainly did so with untainted, legitimately earned funds. • • • • s Instructive is the Eleventh Circuit Pattern Jury Instrucuun 70.4 which states that the defendant can be found guilty of § 1956(aX3XA) only if (I) he knowingly conducted a financial transaction
ndant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 5. On May 1, 2004, Defendants EPSTEIN, and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. 6. On May 3, 2004, Defendant caused one or mo
use of that facility to entice a minor to engage in "any sexual activity for which any person can be charged with a criminal offense." According to the Eleventh Circuit Pattern Jury Instruction, the determination of what sexual activity is criminal is governed by Florida law. Florida law bars a person from procuring anyone
s alleged to have had improper sexual contact, solely in Florida, with women who were under the age of 18. Mr. Epstein maintained residences both in New York and Florida and would repeatedly fly from New York to Florida where his primary residence was located. He would travel to Florida for purposes of r
vidence may show that Mr. Epstein paid for sexual services, he most certainly did so with untainted, legitimately earned funds. • 5 Instructive is the Eleventh Circuit Pattern Jury Instruction 70.4 which states that the defendant can be found guilty of § 1956(a)(3XA) only if (I) he knowingly conducted a financial transacti
use of that facility to entice a minor to engage in "any sexual activity for which any person can be charged with a criminal offense." According to the Eleventh Circuit Pattern Jury Instruction, the determination of what sexual activity is criminal is governed by Florida law. Florida law bars a person from procuring anyone
Page: EFTA02857763_p7 →ndant caused one or more telephone calls to be made to a telephone used by Jane Doe #6. 5. On May 1, 2004, Defendants EPSTEIN, and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. EFTA02857788 6. On May 3, 2004, Defendant c
Page: EFTA02857763_p26 →Entities connected to both New York and the Eleventh Circuit Pattern

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Virginia Giuffre
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSON
New York City
LOCATION
U.S. Virgin Islands
LOCATION
Joe Biden
PERSON
Barry Diller
PERSONEmmy Taylor
PERSON
Alexander Acosta
PERSON
Colorado
LOCATION
Philadelphia
LOCATIONCourtney Wild
PERSONJack Goldberger
PERSON