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personal matters and contacts to which he attends in Florida. For example, beginning in 2002, Mr. Epstein visited his mother nearly every weekend in Palm Beach until she passed away in April, 2004. 5 As previously set forth herein, and as more fully explained in other submissions related to this case, the r
ill understand, of what the law intends to do if a certain line is passed.'" Arthur Andersen LLP v. United States, 544 U.S. 696, 703 (2005) (quoting McBoyle v. United States, 283 U.S. 25, 27 (1931)) (citation omitted). Two recent Supreme Court decisions dramatically underscore these principles and help
uld pay the procurer of each girl's "appointment" hundreds of dollars. 13. Defendant designed this scheme to secure a private place in Defendant's Palm Beach mansion where only persons employed and invited by Defendant would be present, so as to reduce the chance of detection of Defendant's sexual abuse a
o be interpreted in favor of the defendants subjected to them. See United States I . Gradwell, 243 U.S. 476, 485, 37 5.O. 407, 61 L.Ed. 857 (1917); McBoyle . United States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931); United States'. Bass, 404 U.S. 336, 347-349, 92 S.Ct. 515, 30 L.Ed.2d 488 (197
uld pay the procurer of each girl's "appointment" hundreds of dollars. 13. Defendant designed this scheme to secure a private place in Defendant's Palm Beach mansion where only persons employed and invited by Defendant would be present, so as to reduce the chance of detection of Defendant's sexual abuse a
o be interpreted in I favor of the defendants subjected to them. See United States Gradwell, 243 U.S. 476, 485, 37 S.Ct. 407, 61 L.Ed. 857 (1917); McBoyle . United States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931); United States'. Bass, 404 U.S. 336, 347-349, 92 S.Ct. 515, 30 L.Ed.2d 488 (197
Entities connected to both Palm Beach and McBoyle

Jeffrey Epstein
PERSON
George W. Bush
PERSONLeon Black
PERSON
United States
LOCATION
Alan Dershowitz
PERSONJack Goldberger
PERSON
Marc Rich
PERSON
Lesley Groff
PERSONJane Doe
PERSONFBI
ORGANIZATION
Bradley Edwards
PERSON
Bill Clinton
PERSONthe Southern District
LOCATION
Kenneth Marra
PERSON
Department of Justice
ORGANIZATION
Barry Diller
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSON
Alexander Acosta
PERSONRoy Black
PERSON