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f New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter in response to the defendant's Motion for Pretrial Release (the "Release Motion"), dated July 11,
Page: EFTA00015532 →y . . . .")—is equally irrelevant because the offense with which the defendant has been charged requires no such proof. See, e.g., United States v. Afrare, 632 F. App'x 272, 278 (6th Cir. 2016) ("We hold that § 1591(a) criminalizes the sex trafficking of children (less than 18 years old) with or withou
Page: EFTA00015534 →f New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter in response to the defendant's Motion for Pretrial Release (the "Release Motion"), dated July 11,
Page: EFTA00028785 →y . . . .")—is equally irrelevant because the offense with which the defendant has been charged requires no such proof. See, e.g., United States v. Afrare, 632 F. App'x 272, 278 (6th Cir. 2016) ("We hold that § 1591(a) criminalizes the sex trafficking of children (less than 18 years old) with or withou
Page: EFTA00028787 →t Court Southern District of New York United States Courthouse July 12, 2019 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter in response to the defendant's Motion for Pretrial Release (the "Release Motion"), dated July 11,
Page: EFTA00030247 →or, where victims are underage, the Government principally must prove that a minor is caused to engage in a commercial sex act. See United States v. Afrare, 632 F. App'x 272, 278 (6th Cir. 2016) ("We hold that § 1591(a) criminalizes the sex trafficking of children (less than 18 years old) with or witho
Page: EFTA00030249 →Entities connected to both Geoffrey S. Berman and Afrare

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
United States
LOCATIONFBI
ORGANIZATIONMartin Weinberg
PERSON
Harry Reid
PERSON
Julie K. Brown
PERSON
Richard M. Berman
PERSON
Reid Weingarten
PERSON
Michael Cohen
PERSON
George Mitchell
PERSONEmmy Taylor
PERSON
Michael Jackson
PERSON
U.S. Virgin Islands
LOCATIONDistrict Court for the Southern District of New York
ORGANIZATION
Alexander Acosta
PERSONPitman
PERSON
Anderson
PERSON
New York State
LOCATION