Epstein Secrets

ument 361-62 Entered on FLSD Docket 02/10/2016 Page 2 of 15 CV RE: INVESTIGATION OF JEFFREY EPSTEIN NON-PROSECUTION AGREEMENT IT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conduc

n of the statute as a whole indicates that it is meant to punish those who are the providers or pimps of children, not the purchasers or the johns." Fierro v. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3 (S.D.N.Y. July 2, 2012) (quoting United States v. Bonestroo, No. 11-CR-40016, 2012 WL 13704, at *4 (D.S.D.

alleged sex acts. Mr. Epstein's conduct, however, is akin to consumer or purchaser behavior and should be outside the ambit of 18 U.S.C. § 1591. See Fierro, 2012 WL 13042630, at *4 ("[T]he TVPA is inapplicable to individual purchasers of sex from trafficking victims...").1° I° While Fiero represents th

at *3 (S.D.N.Y. July 2, 2012) (quoting United States v. Bonestroo, No. 11-CR-40016, 2012 WL 13704, at *4 (D.S.D. Jan. 4, 2012)) (emphasis added). In Fierro, the district court found § 1591 inapplicable to consumers or purchasers of sex acts. Here, the principal conduct underlying the indictment is Mr.

ument 361-62 Entered on FLSD Docket 02/10/2016 Page 2 of 15 CV RE: INVESTIGATION OF JEFFREY EPSTEIN NON-PROSECUTION AGREEMENT IT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conduc

n of the statute as a whole indicates that it is meant to punish those who are the providers or pimps of children, not the purchasers or the johns." Fierro v. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3 (S.D.N.Y. July 2, 2012) (quoting United States v. Bonestroo, No. 11-CR-40016, 2012 WL 13704, at *4 (D.S.D.

alleged sex acts. Mr. Epstein's conduct, however, is akin to consumer or purchaser behavior and should be outside the ambit of 18 U.S.C. § 1591. See Fierro, 2012 WL 13042630, at *4 ("[T]he TVPA is inapplicable to individual purchasers of sex from trafficking victims...").1° I° While Fiero represents th

at *3 (S.D.N.Y. July 2, 2012) (quoting United States v. Bonestroo, No. 11-CR-40016, 2012 WL 13704, at *4 (D.S.D. Jan. 4, 2012)) (emphasis added). In Fierro, the district court found § 1591 inapplicable to consumers or purchasers of sex acts. Here, the principal conduct underlying the indictment is Mr.

tigators were still photographing the family. On April EFTA00100406 Case 1:19-cr-00490-RMB Document 11-3 Filed 07/12/19 Page 2 of 2 ite. 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 83 [me: 15:01:37 Incident Report Program: CMS301L Ise NO • 1-05-000368 (Continued) 10, 2006, at approximately 2:30 p.m., I served...bat her

ply to both suppliers and consumers of commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the defendant, Fierro v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied heavily on the statutory interpretation undertaken by two district cou

tigators were still photographing the family. On April EFTA00105504 Case 1:19-cr-00490-RMB Document 11-3 Filed 07/12/19 Page 2 of 2 ite. 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 83 [me: 15:01:37 Incident Report Program: CMS301L Ise NO • 1-05-000368 (Continued) 10, 2006, at approximately 2:30 p.m., I served...bat her

ply to both suppliers and consumers of commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the defendant, Fierro v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied heavily on the statutory interpretation undertaken by two district cou

tigators were still photographing the family. On April EFTA00068076 Case 1:19-cr-00490-RMB Document 11-3 Filed 07/12/19 Page 2 of 2 ate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 83 ime: 15:01:37 Incident Report Program: CMS301L Ise No • 1-05-000368 (Continued) 10, 2006, at approximately 2:30 p.m., I servedflat her res

ply to both suppliers and consumers of commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the defendant, Fierro v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied heavily on the statutory interpretation undertaken by two district cou

tigators were still photographing the family. On April EFTA00076329 Case 1:19-cr-00490-RMB Document 11-3 Filed 07/12/19 Page 2 of 2 ite. 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 83 [me: 15:01:37 Incident Report Program: CMS301L Ise NO • 1-05-000368 (Continued) 10, 2006, at approximately 2:30 p.m., I served...bat her

ply to both suppliers and consumers of commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the defendant, Fierro v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied heavily on the statutory interpretation undertaken by two district cou

tigators were still photographing the family. On April EFTA00071700 Case 1:19-cr-00490-RMB Document 11-3 Filed 07/12/19 Page 2 of 2 ite. 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 83 [me: 15:01:37 Incident Report Program: CMS301L Ise NO • 1-05-000368 (Continued) 10, 2006, at approximately 2:30 p.m., I served...bat her

ply to both suppliers and consumers of commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the defendant, Fierro v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied heavily on the statutory interpretation undertaken by two district cou

tigators were still photographing the family. On April EFTA00076357 Case 1:19-cr-00490-RMB Document 11-3 Filed 07/12/19 Page 2 of 2 ite. 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 83 [me: 15:01:37 Incident Report Program: CMS301L Ise NO • 1-05-000368 (Continued) 10, 2006, at approximately 2:30 p.m., I served...bat her

ply to both suppliers and consumers of commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the defendant, Fierro v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied heavily on the statutory interpretation undertaken by two district cou

tigators were still photographing the family. On April EFTA00078257 Case 1:19-cr-00490-RMB Document 11-3 Filed 07/12/19 Page 2 of 2 ite. 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 83 [me: 15:01:37 Incident Report Program: CMS301L Ise NO • 1-05-000368 (Continued) 10, 2006, at approximately 2:30 p.m., I served...bat her

ply to both suppliers and consumers of commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the defendant, Fierro v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied heavily on the statutory interpretation undertaken by two district cou

tigators were still photographing the family. On April EFTA00080512 Case 1:19-cr-00490-RMB Document 11-3 Filed 07/12/19 Page 2 of 2 ite. 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 83 [me: 15:01:37 Incident Report Program: CMS301L Ise NO • 1-05-000368 (Continued) 10, 2006, at approximately 2:30 p.m., I served...bat her

ply to both suppliers and consumers of commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the defendant, Fierro v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied heavily on the statutory interpretation undertaken by two district cou