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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 →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 →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 →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 →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 →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 →Entities connected to both JD#3 and Western
Gebardi
PERSONChik-Fil-A.
ORGANIZATIONOffense Instr
ORGANIZATIONDrury
PERSON
U.S. Virgin Islands
LOCATION
Virginia Giuffre
PERSONDrury
LOCATION
Palm Beach Police Department
LOCATIONGerald Lefcourt
PERSON
Alexander Acosta
PERSONRoy Black
PERSONLeon Black
PERSON
Palm Beach International Airport
ORGANIZATIONthe Eleventh Circuit's
ORGANIZATION
United States
LOCATION
Naomi Campbell
PERSON
Jeffrey Epstein
PERSONJanusz Banasiak
PERSONSection 2423(a
ORGANIZATION
Philadelphia
LOCATION