Epstein Secrets

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

. at 2895.2 Count Five of the Indictment also charged the Defendant under 18 U.S.C. § 371, but for conspiring to violate 18 U.S.C. §§ 1591(a) & (b) (the Trafficking Victims Protection Act), by trafficking individuals under the age of eighteen for commercial sex acts that affect interstate commerce. S2 Indictment 9¶ 22-24. Count Five'

dition of the NPA and his state sentence, was required to register as a sex offender in the locations of his residences. He is currently registered New York's age of consent was 17 at the time of the alleged conduct and remains so today. See N.Y. Penal Law § 130.05. 2 EFTA00058430 Case 1:19-cr-00490-RM

of seeking bail. We will amplify it later, along with various other arguments, in full-blown dismissal motions. Section 1591 was passed as part of the Trafficking Victims Protection Act of 2000 ("TVPA"), Pub. L. No. 106-386, 114 Stat. 1464 (October 28, 2000). In enacting the TVPA, Congress recognized that human trafficking, particu

tion of the NPA and his state sentence, was required to register as a sex offender in the locations of his residences. He is currently registered ' New York's age of consent was 17 at the time of the alleged conduct and remains so today. See N.Y. Penal Law § 130.05. 2 EFTA00076069 Case 1:19-cr-00490-RM

of seeking bail. We will amplify it later, along with various other arguments, in full-blown dismissal motions. Section 1591 was passed as part of the Trafficking Victims Protection Act of 2000 ("TVPA"), Pub. L. No. 106-386, 114 Stat. 1464 (October 28, 2000). In enacting the TVPA, Congress recognized that human trafficking, particu

tion of the NPA and his state sentence, was required to register as a sex offender in the locations of his residences. He is currently registered ' New York's age of consent was 17 at the time of the alleged conduct and remains so today. See N.Y. Penal Law § 130.05. 2 EFTA00095872 Case 1:19-cr-00490-RM

of seeking bail. We will amplify it later, along with various other arguments, in full-blown dismissal motions. Section 1591 was passed as part of the Trafficking Victims Protection Act of 2000 ("TVPA"), Pub. L. No. 106-386, 114 Stat. 1464 (October 28, 2000). In enacting the TVPA, Congress recognized that human trafficking, particu

dition of the NPA and his state sentence, was required to register as a sex offender in the locations of his residences. He is currently registered New York's age of consent was 17 at the time of the alleged conduct and remains so today. See N.Y. Penal Law § 130.05. 2 EFTA00097461 Case 1:19-cr-00490-RM

of seeking bail. We will amplify it later, along with various other arguments, in full-blown dismissal motions. Section 1591 was passed as part of the Trafficking Victims Protection Act of 2000 ("TVPA"), Pub. L. No. 106-386, 114 Stat. 1464 (October 28, 2000). In enacting the TVPA, Congress recognized that human trafficking, particu

Mr. Epstein spent at his home in Florida, and the extensive list of Florida-based activities clearly undermines the contention that Mr. Epstein is a New York_ resident and defeats the notion that his purpose in traveling to Florida was to engage in illicit sexual conduct. On the contrary, Mr. Epstein ret

d Does Not Fall Within the Ambit of the Statute 18 § 1591 - "Sex Trafficking of Children or by Force, Fraud, or Coercion" — was passed as part of the Trafficking Victims Protection Act ("TVPA") to address a problem far removed from the present set of circumstances: human trafficking, in general, and human sex trafficking, in parti