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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 →s' old. She was recruited indirectly by Jane Doe #4. Jane Doe #5 re, that she entered the home through the kitchen and was introduced to brought JD#5 upstairs to the dressing area, where she met Epstein. JD#5 performed multiple sexual massages for Epstein. During the first massage, Epstein asked
Page: EFTA02857524_p47 →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 →n, Jane Doe #5 was approached by two individuals, and Tony, while at a beach club on Singer Island. was a classmate of JD#5 at High School. asked JD#5 if she wanted to make some money giving a massage to a wealthy man on Palm Beach Island. JD#5 was told that she would be paid $200, she would have
Page: EFTA02857763_p18 →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 →old. She was recruited indirectly by Jane Doe #4. Jane Doe #5 reported that she entered the home through the kitchen and was introduced to brought JD#5 upstairs to the dressing area, where she met Epstein. JD#5 performed approximately 10 sexual massages for Epstein. The first two massages she perfo
Page: EFTA02857810_p27 →Entities connected to both JD#5 and Western
Garcia-Lopez
PERSONHayward
PERSONthe Third Circuit's
ORGANIZATIONNorthern Region
LOCATION
U.S. Virgin Islands
LOCATION
Virginia Giuffre
PERSONNorthern Florida
LOCATIONCommerce Bank and Western Union
ORGANIZATIONGerald Lefcourt
PERSON
Alexander Acosta
PERSONRoy Black
PERSONLeon Black
PERSONTobon
ORGANIZATIONTobon-Builes'
ORGANIZATION
United States
LOCATION
Naomi Campbell
PERSON
Ghislaine Maxwell
PERSONJanusz Banasiak
PERSONCommerce Bank
ORGANIZATION
Philadelphia
LOCATION