Epstein Secrets

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

ourts addressing § 2423(b) have relied on longstanding case law interpreting the Mann Act's use of the statutory phrase. See, e.g., United States v. Garcia-Lopez, 234 F.3d 217, 220 n.3 (5th Cir. 2000); United States v. yang, 128 F.3d 1065, 1069-70 (7th Cir. 1997); United States v. Ellis, 935 F.2d 385, 389-90

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

ourts addressing § 2423(b) have relied on longstanding case law interpreting the Mann Act's use of the statutory phrase. See, e.g., United States v. Garcia-Lopez, 234 F.3d 217, 220 n.3 (5th Cir. 2000); United States v. yang, 128 F.3d 1065, 1069-70 (7th Cir. 1997); United States v. Ellis, 935 F.2d 385, 389-90

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

ourts addressing § 2423(b) have relied on longstanding case law interpreting the Mann Act's use of the statutory phrase. See, e.g., United States v. Garcia-Lopez, 234 F.3d 217, 220 n.3 (5th Cir. 2000); United States v. yang, 128 F.3d 1065, 1069-70 (7th Cir. 1997); United States v. Ellis, 935 F.2d 385, 389-90

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

ourts addressing § 2423(b) have relied on longstanding case law interpreting the Mann Act's use of the statutory phrase. See, e.g., United States v. Garcia-Lopez, 234 F.3d 217, 220 n.3 (5th Cir. 2000); United States v. yang, 128 F.3d 1065, 1069-70 (7th Cir. 1997); United States v. Ellis, 935 F.2d 385, 389-90

fighting at school because the other girl accused Jane Doe #2 of being a prostitute, one of the school principals intervened. The principal searched Jane Doe #2's purse and found $300 cash. The principal asked Jane Doe #2 where the money came from. Jane Doe #2 initially claimed that she earned the money w

activity must have not been merely incidental to the trip. United States v. Hayward, 359 F.3d 631, 637-38 (3d Cir. 2004). See also United States v. Garcia-Lopez , 234 F.3d 217, 220 (5th Cir. 2000) (The district court did not err in instructing the jury that "it was sufficient for the Government to prove tha

the overt acts and substantive allegations related to each Jane Doe because the indictment has been revised to group the overt acts related to each Jane Doe. 'Each of the airplanes is held in a separate "shell corporation," JEGE, Inc., and Hyperion Air, Inc. Epstein is the sole shareholder in both of th

al activity must have not been merely incidental to the trip. United States I. Hayward, 359 F.3d 631, 637-38 (3d Cir. 2004). See also United States Garcia-Lopez, 234 F.3d 217, 220 (5th Cir. 2000) (The district court did not err in instructing the jury that "it was sufficient for the Government to prove that

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

ourts addressing § 2423(b) have relied on longstanding case law interpreting the Mann Act's use of the statutory phrase. See, e.g., United States v. Garcia-Lopez, 234 F.3d 217, 220 n.3 (5th Cir. 2000); United States v. yang, 128 F.3d 1065, 1069-70 (7th Cir. 1997); United States v. Ellis, 935 F.2d 385, 389-90

ctivity must have not been merely incidental to the trip. United States v. Hayward, 359 F.3d 631, 637-38 (3d Cir. 2004). See also United States v. Garcia-Lopez, 234 F.3d 217, 220 (5th Cir. 2000) (The district court did not err in instructing the jury that "it was sufficient for the Government to prove that

m trash pulls, the flight manifests from Epstein's private lanes, and testimony from the girls about how the appointments were made. So, if called Jane Doe ake an appointment on January 1st; Epstein traveled to Florida on January 2nd; and Weaned Jane Doe #12 on 18 EFTA02857620 January 3rd (when they wer

JD#2 was 14 when she was brought to JE's home in 2001. JD#1 told JD#2 that she could make $300 for giving a massage to a man in Palm Beach. JD#1 2 Jane Doc #1 was brought to JE's home by Ghislaine Maxwell after Maxwell met her at Mar a Lago. Jane Doe #1 was 15 at the time of her first contact with JE an