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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 →ual conduct 2423(b) EPSTEIN JEGE 40 2/24/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 42 3/18/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 43 3/31/05 Travel in interst
Page: EFTA02857524_p41 →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 →Beach County, Florida, aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. caused one ore more telephone calls to EFTA02857786 conduct HYPERION 35 1/6/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 36 1/14/05 Travel in inte
Page: EFTA02857763_p25 →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 →, 2005, Defendants EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. #. On or about May 6, 2005, Defendants EPSTEIN and caused Jane Doe #3 to make a telephone call to 917-855-3363. #. On or about May 6,
Page: EFTA02857810_p24 →Entities connected to both Western and HYPERION

U.S. Virgin Islands
LOCATION
Ghislaine Maxwell
PERSONLeon Black
PERSONMySpace
ORGANIZATIONCourtney Wild
PERSON
United States
LOCATION
Palm Beach Police Department
LOCATION
Jeffrey Epstein
PERSON
Marc Rich
PERSONPalm Beach Island
LOCATION
Robert Maxwell
PERSON
Virginia Giuffre
PERSONGerald Lefcourt
PERSON
Alexander Acosta
PERSONRoy Black
PERSON
Naomi Campbell
PERSON
Mortensen
PERSON
Jacksonville
LOCATION
Griffith
PERSON
Costa Rica
LOCATION