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th suppliers and consumers of commercial sex acts. It would be helpful for us to get as many cases addressing that issue as possible, especially in the Second Circuit but honestly nationwide, for cases charged during the time period from when the statute was passed initially in 2000 through when it was amended. T
rsion of USC 1591. As we discussed in your office, the key case actually analyzing the statute is U.S. v. Jungers, while the other cases either cite Jungers directly or simply assume that 1591 applies to purchasers without analyzing the law. Additionally, there is one case, Fierro v. Taylor, from SDNY i
umers were prosecuted under the pre-2015 version of USC 1591. As we discussed in your office, the key case actually analyzing the statute is U.S. v. Jungers, while the other cases either cite Jungers directly or simply assume that 1591 applies to purchasers without analyzing the law. Additionally, there
t 1591 does not apply to consumers. However, the judge relied on and directly cited the statutory interpretation completed by the district courts in Jungers and Bonestroo, both of which were overturned by the 8th Circuit United States v. Jungers. Thus, it is doubtful that Fierro would be seen as persuas
ed provides the motive for him do so and is another significant factor in assessing the risk of flight. See United States v. Jackson, 823 F.2d 4, 7 (2d Cir. 1987). So too is the strength of the evidence, detailed above and in the Government's Detention Memo. Indeed, that evidence, already robust less th
Page: EFTA00015536 →ict courts in the District of South Dakota, United States v. Bonestroo, No. 11 Cr. 40016, 2012 WL 13704 (D.S.D. Jan. 4, 2012), and United States v. Jungers, 11 Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 10
Page: EFTA00015545 →n to dozens of victims who were abused in Florida. 2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the Second Circuit that absent an express provision to the contrary in the agreement, one District is not bound by the terms of an agreement entered into between a def
Page: EFTA00015549 →elaborately replicate a detention facility without the confidence of security such a facility instills."' United States v. Orena, 986 F.2d 628, 632 (2d Cir. 1993) (quoting United States v. Gotti, 776 F. Supp. 666, 672 (E.D.N.Y. 1991) (rejecting private jail proposal)); see also Valerio, 9 F. Supp. 3d at
Page: EFTA00028792 →ict courts in the District of South Dakota, United States v. Bonestroo, No. 11 Cr. 40016, 2012 WL 13704 (D.S.D. Jan. 4, 2012), and United States v. Jungers, 11 Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 10
Page: EFTA00028798 →Entities connected to both Second Circuit and Jungers

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Julie K. Brown
PERSON
Michael Cohen
PERSON
Southern District of New York
ORGANIZATIONMartin Weinberg
PERSON
Michael Jackson
PERSON
New York
LOCATIONFBI
ORGANIZATION
Harry Reid
PERSON
Reid Weingarten
PERSON
New York State
LOCATION
Anderson
PERSONDistrict Court for the Southern District of New York
ORGANIZATION
Geoffrey S. Berman
PERSONEmmy Taylor
PERSON