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is used in the commission of [the] offense, regardless of whether the use is interstate in nature (Le., the telephone call was '°Note that there is an Eleventh Circuit Pattern Jury Instruction for attempted enticement of a minor. In that instruction, the Eleventh Circuit included a willfulness requirement — including a require
Page: EFTA02857524_p10 →and there were 28 calls between and JD#3. Although was aboard the plane during several trips, there is no evidence that she ever had contact with JD#3 or arranged for JD#3 to engage in sexual activity with Epstein; thus, I have not charged her in connection with any of this activity. Rather than tr
Page: EFTA02857524_p42 →EPSTEIN L. JANE DOE #7 Jane Doe # 7 attended High School. She was recruited by Jane Doe #3 to go to Epstein's house when she was 16 years' old. JD#3 also went to Epstein's house and performed sexual services starting when she was 15. JD#3 refused to speak to police and the FBI, telling them that
Page: EFTA02857763_p41 →d 2423 are more recent additions, which focus on children. All three sections are sometimes jointly referred to as the Mann Act. Note that there is an Eleventh Circuit Pattern Jury Instruction for attempted enticement of a minor. In that instruction, the Eleventh Circuit included a willfulness requirement — including a requirem
Page: EFTA02857763_p46 →C. Jane Doe #3 Jane Doe #3 also attended High School with Jane Doe #1 and JD#1 recruited her to go to Epstein's home to perform a sexual massage. JD#3 was in her sophomore year of high school. JD#1 told JD#3 that she could make $200 for massaging Epstein. JD#1 drove JD#3 to Epstein's house and tol
Page: EFTA02857810_p22 →423 are more recent additions, which focus on children. All three sections are sometimes jointly referred to as the Mann Act. 3F Note that there is an Eleventh Circuit Pattern Jury Instruction for attempted enticement of a minor. In that instruction, the Eleventh Circuit included a willfulness requirement — including a requirem
Page: EFTA02857810_p29 →Entities connected to both an Eleventh Circuit Pattern Jury and JD#3
the Ninth Circuit
ORGANIZATIONCriminal Division
ORGANIZATIONEleventh Cir
ORGANIZATION
Cleveland
LOCATIONAttempt(s
ORGANIZATION
Nelson
PERSON
Jencks
PERSONthe Sentencing Commission
ORGANIZATIONEllis
PERSONTransportation of an Individual to Engage in Sexual
ORGANIZATION
Alexander Acosta
PERSON
Lilly
ORGANIZATION
Virginia Giuffre
PERSON
Jeffrey Epstein
PERSONthe Florida Legislature
ORGANIZATIONEmmy Taylor
PERSONAnn Sanchez
PERSONMeacham
PERSONGerald Lefcourt
PERSONthe Third Circuit's
ORGANIZATION