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levant to Count Three because it tended to establish the existence of a conspiracy and of the Defendant and Epstein's intent to abuse the victims in New York. In sum, the same locations—particularly Florida—were part of the Government's case for both counts. And over time, a conspiracy's "shifting emphasi
rk law. This response ensured that the jury focused on the correct instruction and, in turn, reminded the jury that the only state law at issue was New York's, even if sexual abuse in New Mexico was relevant evidence of intent. See United States v. Rommy, 506 F.3d 108, 126 (2d Cir. 2007) ("[A] trial court
e lines with the intent to engage in sexual activity criminalized by state law. S2 Indictment ¶¶ 16-18. In this case, the relevant state offense was New York Penal Law Section 130.55, which criminalizes sexual contact with an individual known to be under the age of seventeen. Trial Tr. 3034-35. The Count Three
ated the laws against sex trafficking. This action is also timely because the conspiracy continued until recently. This action is also timely under New York's Adult Survivor's Act, N.Y. CPLR § 214-j. II. PARTIES 7. Jane Doe 1 is a U.S. citizen and was at all relevant times a resident of and domiciled in
as 2012, a JP Morgan subsidiary company assisted with transporting certain Epstein sex-trafficking victims by private jet from Florida to Epstein in New York. 177. Ultimately, JP Morgan financially benefited by earning millions of dollars for its participation in the Epstein sex-trafficking venture. 178
f 130 75. In addition to coercing commercial sex acts from his victims, Epstein also committed coercive sexual offenses against them as defined in New York Penal Law § 130, as described in greater detail below. 76. Throughout around 1998 through about July 2019, the Epstein's sex- trafficking venture recrui
d with friends and hired staff to maintain and keep secret this network of sexual abuse for years, which sprawled throughout Epstein's residences in New York, Florida, New Mexico, the United States Virgin Islands, and Paris. Epstein's preference was to have three different girls a day for his sexual pleas
touched Plaintiff in an offensive and sexual manner without her consent. 81. Epstein and Maxwell's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to forcible touching as defined in Article 130.52, inasmuch as Epstein and Maxwell intentionally and for
d with friends and hired staff to maintain and keep secret this network of sexual abuse for years, which sprawled throughout Epstein's residences in New York, Florida, New Mexico, the United States Virgin Islands, and Paris. Epstein's preference was to have three different girls a day for his sexual pleas
touched Plaintiff in an offensive and sexual manner without her consent. 81. Epstein and Maxwell's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to forcible touching as defined in Article 130.52, inasmuch as Epstein and Maxwell intentionally and for
d with friends and hired staff to maintain and keep secret this network of sexual abuse for years, which sprawled throughout Epstein's residences in New York, Florida, New Mexico, the United States Virgin Islands, and Paris. Epstein's preference was to have three different girls a day for his sexual pleas
touched Plaintiff in an offensive and sexual manner without her consent. 81. Epstein and Maxwell's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to forcible touching as defined in Article 130.52, inasmuch as Epstein and Maxwell intentionally and for
Entities connected to both New York and New York Penal

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONDarren Indyke
PERSON
U.S. Virgin Islands
LOCATION
Palm Beach
LOCATION
Les Wexner
PERSON
Richard Kahn
PERSON
Kenneth Marra
PERSON
Metropolitan Correctional Center
ORGANIZATION
United Kingdom
LOCATION
Martha Stewart
PERSON
Southern District of New York
ORGANIZATION
Jes Staley
PERSON
David Boies
PERSON
Alaska
LOCATION
Jay Lefkowitz
PERSONSigrid McCawley
PERSON
New Mexico
LOCATION
New York Post
ORGANIZATION