Epstein Secrets

arte2urfeneleta off Ficarvaatkat Pag6/2Ct1131.5Page 2 of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JU

n of the statute as a whole indicates that it is meant to punish those who are the providers or pimps of children, not the purchasers or the johns." Fierro v. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3 (S.D.N.Y. July 2, 2012) (quoting United States v. Bonestroo, No. 11-CR-40016, 2012 WL 13704, at *4 (D.S.D.

alleged sex acts. Mr. Epstein's conduct, however, is akin to consumer or purchaser behavior and should be outside the ambit of 18 U.S.C. § 1591. See Fierro, 2012 WL 13042630, at *4 ("[T]he TVPA is inapplicable to individual purchasers of sex from trafficking victims...").1° I° While Fiero represents th

at *3 (S.D.N.Y. July 2, 2012) (quoting United States v. Bonestroo, No. 11-CR-40016, 2012 WL 13704, at *4 (D.S.D. Jan. 4, 2012)) (emphasis added). In Fierro, the district court found § 1591 inapplicable to consumers or purchasers of sex acts. Here, the principal conduct underlying the indictment is Mr.

arte2urfeneleta off Ficarvaatkat Pag6/2Ct1131.5Page 2 of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JU

n of the statute as a whole indicates that it is meant to punish those who are the providers or pimps of children, not the purchasers or the johns." Fierro v. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3 (S.D.N.Y. July 2, 2012) (quoting United States v. Bonestroo, No. 11-CR-40016, 2012 WL 13704, at *4 (D.S.D.

alleged sex acts. Mr. Epstein's conduct, however, is akin to consumer or purchaser behavior and should be outside the ambit of 18 U.S.C. § 1591. See Fierro, 2012 WL 13042630, at *4 ("[T]he TVPA is inapplicable to individual purchasers of sex from trafficking victims...").1° I° While Fiero represents th

at *3 (S.D.N.Y. July 2, 2012) (quoting United States v. Bonestroo, No. 11-CR-40016, 2012 WL 13704, at *4 (D.S.D. Jan. 4, 2012)) (emphasis added). In Fierro, the district court found § 1591 inapplicable to consumers or purchasers of sex acts. Here, the principal conduct underlying the indictment is Mr.

Courthouse 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe STEPTOE I JOHNSON UP We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of conditions that will effectively gua

n of the statute as a whole indicates that it is meant to punish those who are the providers or pimps of children, not the purchasers or the johns." Fierro v. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3 (S.D.N.Y. July 2, 2012) (quoting United States v. Bonestroo, No. 11-CR-40016, 2012 WL 13704, at *4 (D.S.D.

alleged sex acts. Mr. Epstein's conduct, however, is akin to consumer or purchaser behavior and should be outside the ambit of 18 U.S.C. § 1591. See Fierro, 2012 WL 13042630, at *4 ("[T]he TVPA is inapplicable to individual purchasers of sex from trafficking victims...").1° I° While Fiero represents th

at *3 (S.D.N.Y. July 2, 2012) (quoting United States v. Bonestroo, No. 11-CR-40016, 2012 WL 13704, at *4 (D.S.D. Jan. 4, 2012)) (emphasis added). In Fierro, the district court found § 1591 inapplicable to consumers or purchasers of sex acts. Here, the principal conduct underlying the indictment is Mr.