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d charging Epstein with promotion money laundering, in violation of 18 U.S.C. § 1956(a)(3)(A). After conferring with the Money Laundering Section at the Department of Justice, it was recommended that I forego the Section 1956 charge and, instead, I should charge Epstein with aiding and abetting the unlicensed money transm
ty; and Third : that the Defendant engaged in the financial transaction with the intent to promote the carrying on of specified unlawful activity. Eleventh Cir. Pattern Jury Instr., Offense Instr. 70.4 (2003). a l Tobon-Builes was decided prior to the enactment of 31 U.S.C. § 5324(a), which created a crimin
d charging Epstein with promotion money laundering, in violation of 18 U.S.C. § 1956(a)(3)(A). After conferring with the Money Laundering Section at the Department of Justice, it was recommended that I forego the Section 1956 charge and, instead, charge Epstein with aiding and abetting the unlicensed money transmitting by
Page: EFTA02857732_p16 →: that the Defendant engaged in the financial transaction with the intent to promote the carrying on of specified unlawful activity. EFTA02857761 Eleventh Cir. Pattern Jury Instr., Offense Instr. 70.4 (2003). F Tobon-Bitiles was decided prior to the enactment of 31 U.S.C. § 5324(a), which created a crimina
Page: EFTA02857732_p31 →d charging Epstein with promotion money laundering, in violation of 18 U.S.C. § 1956(a)(3)(A). After conferring with the Money Laundering Section at the Department of Justice, it was recommended that I forego the Section 1956 charge and, instead, charge Epstein with aiding and abetting the unlicensed money transmitting by
Page: EFTA02857763_p16 →ty; and Third : that the Defendant engaged in the financial transaction with the intent to promote the carrying on of specified unlawful activity. Eleventh Cir. Pattern Jury Instr., Offense Instr. 70.4 (2003). F Tobon-Builes was decided prior to the enactment of 31 U.S.C. § 5324(a), which created a criminal
Page: EFTA02857763_p47 →d charging Epstein with promotion money laundering, in violation of 18 U.S.C. § 1956(a)(3)(A). After conferring with the Money Laundering Section at the Department of Justice, it was recommended that I forego the Section 1956 charge and, instead, I should charge Epstein with aiding and abetting the unlicensed money transm
Page: EFTA02857810_p16 →ty; and Third : that the Defendant engaged in the financial transaction with the intent to promote the carrying on of specified unlawful activity. Eleventh Cir. Pattern Jury Instr., Offense Instr. 70.4 (2003). a lTobon-Builes was decided prior to the enactment of 31 U.S.C. § 5324(a), which created a crimina
Page: EFTA02857810_p29 →Entities connected to both Department of Justice and Eleventh Cir

Jeffrey Epstein
PERSON
United States
LOCATION
Alexander Acosta
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONJane Doe
PERSON
Joe Biden
PERSONRoy Black
PERSON
Marc Rich
PERSONEmmy Taylor
PERSON
Barry Diller
PERSON
Colorado
LOCATION
Supreme Court
ORGANIZATIONGerald Lefcourt
PERSON
Palm Beach County
LOCATION
Philadelphia
LOCATIONCourtney Wild
PERSON
U.S. Virgin Islands
LOCATION