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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). 29 EFTA02857552 money laundering statutes, Section 1956 cross-references Section 1961(1) for the definition of "specified unlawful
Page: EFTA02857524_p29 →d to use or promote the same unlawful activity. Accordingly, one could charge Epstein alone with individual counts ofviolating Section 1960 for each Western Union transfer and for each ATM withdrawal that occurred immediately prior to one of Banasiak's documented payments to one of the girls. I decided not to
Page: EFTA02857524_p31 →hat I forego the Section 1956 charge and, instead, charge Epstein with aiding and abetting the unlicensed money transmitting by causing his bank and Western Union unwittingly to transmit funds intended to be used to promote and support sex trafficking and white slave traffic. The Money Laundering Section refe
Page: EFTA02857732_p16 →alone, but which is knowingly committed by a conspirator in an effort to accomplish some object of the conspiracy." 11th Cir. Pattern Jury Instr., Offense Instr. 13.1 (2003). MAlthough Hersh specifically mentions "sexual activity with a minor," knowledge of age is not required, as discussed above. Based on
Page: EFTA02857732_p30 →hat I forego the Section 1956 charge and, instead, charge Epstein with aiding and abetting the unlicensed money transmitting by causing his bank and Western Union unwittingly to transmit funds intended to be used to promote and support sex trafficking and white slave traffic. The Money Laundering Section refe
Page: EFTA02857763_p16 →alone, but which is knowingly committed by a conspirator in an effort to accomplish some object of the conspiracy." 11th Cir. Pattern Jury Instr., Offense Instr. 13.1 (2003). Although Hersh specifically mentions "sexual activity with a minor," knowledge of age is not required, as discussed above. MBased on
Page: EFTA02857763_p46 →stern Union were the innocent intermediaries who operated the money transmitting business. Nonetheless, Epstein's directions to pay the girls caused Western Union to transmit funds that were intended to be used to promote or support unlawful activity — the prostitution of minors. Epstein's directions to Banasi
Page: EFTA02857810_p17 →alone, but which is knowingly committed by a conspirator in an effort to accomplish some object of the conspiracy." 11th Cir. Pattern Jury Instr., Offense Instr. 13.1 (2003). Although Hersh specifically mentions "sexual activity with a minor," knowledge of age is not required, as discussed above. F Part G
Page: EFTA02857810_p29 →Entities connected to both Offense Instr and Western

Virginia Giuffre
PERSON
Jennifer Lopez
PERSONStrevell
ORGANIZATION
Mortensen
PERSON
Robert Maxwell
PERSONVoiceStream
ORGANIZATION
Jencks
PERSON
Cleveland
LOCATIONEllis
PERSON
Alexander Acosta
PERSONthe Sentencing Commission
ORGANIZATIONLeon Black
PERSONNorthern Region
LOCATIONCriminal Division
ORGANIZATION
United States
LOCATION
Naomi Campbell
PERSONGarcia-Lopez
PERSONJanusz Banasiak
PERSON
Jacksonville
LOCATION
Philadelphia
LOCATION