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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 →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 →23 are more recent additions, which focus on children. All three sections are sometimes jointly referred to as the Mann Act. F! 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: 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 →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 →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 →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 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