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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 →d traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulestream 75 EFTA02857594 aircraft owned by Defendant, HYPERION, AIR, INC. 76. On January 1, 2005, Defendants EPSTEIN, and traveled from Anguilla, British West Indies.to Palm Beach County, Florida aboard the Gulfstream
Page: EFTA02857524_p72 →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 →efendants EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. 11. On June 3, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #6. 12. On June 4, 2004, Defendants
Page: EFTA02857763_p27 →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 →fendants 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, 2005, Defenda
Page: EFTA02857810_p24 →Entities connected to both Western and AIR, INC.
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