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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 →nt time period (2004 to late 2005), criminal forfeiture was governed by 18 U.S.C. § 2253(a), which also applies to violations of section 2423. 4. Transportation of an Individual to Engage in Sexual Activity: 18 U.S.C. § 2421 'Count 591 Whoever knowingly transports any individual in interstate or foreign commerce ... with intent that such indi
Page: EFTA02857524_p102 →vant time period (2004 to late 2005), criminal forfeiture was governed by 18 U.S.C. § 2253(a), which also applies to violations of section 2423. 4. Transportation of an Individual to Engage in Sexual Activity: 18 U.S.C. § 2421 ot c lt S9] Whoever knowingly transports any individual in interstate or foreign commerce . . . with intent that such
Page: EFTA02857732_p12 →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 →vant time period (2004 to late 2005), criminal forfeiture was governed by 18 U.S.C. § 2253(a), which also applies to violations of section 2423. 4. Transportation of an Individual to Engage in Sexual Activity: 18 U.S.C. § 2421 [Count 59] Whoever knowingly transports any individual in interstate or foreign commerce . . . with intent that such i
Page: EFTA02857763_p12 →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 →vant time period (2004 to late 2005), criminal forfeiture was governed by 18 U.S.C. § 2253(a), which also applies to violations of section 2423. 4. Transportation of an Individual to Engage in Sexual Activity: 18 U.S.C. § 2421fCounts to Whoever knowingly transports any individual in interstate or foreign commerce . . with intent that such ind
Page: EFTA02857810_p12 →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 →Entities connected to both Transportation of an Individual to Engage in Sexual and Western
Ellis
PERSONDrury
PERSONOffense Instr
ORGANIZATIONthe Ninth Circuit
ORGANIZATIONthe Third Circuit's
ORGANIZATION
Robert Maxwell
PERSONChik-Fil-A.
ORGANIZATION
Lilly
ORGANIZATIONMeacham
PERSONVoiceStream
ORGANIZATION
Marc Rich
PERSONthe Florida Legislature
ORGANIZATION
Virginia Giuffre
PERSONStrevell
ORGANIZATION
United States
LOCATION
Naomi Campbell
PERSONNorthern Region
LOCATIONJanusz Banasiak
PERSON
Ghislaine Maxwell
PERSON
Philadelphia
LOCATION