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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
court decisions watering down the "for the purpose of " requirement fly in the face of the two Supreme Court decisions addressing that element. See Hansen v. Huff, 291 U.S. 559 (1934); Mortensen v. United States, 322 U.S. 369 (1944). Santos and Cuellar speak loudly and clearly against prosecutors seei
ds. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and
Page 28 of 36 the same act are intended to have the same meaning.") (quotation and citation omitted). Two Mann Act cases are particularly apt. In Hansen', Half, 291 U.S. 559 (1934), the Government charged the defendant with violating the Mann Act after she returned to the country with a man with who
nded Wellington High School in Palm Beach County. 20. During the period of their involvement with the Defendants, Jane Does # 6, 8 and 12 attended Palm, Beach Central High School in Palm Beach County. 21. During- the period of her involvement with the Defendants, Jane Doe #7 attended William T. Dwyer Hig
e of § 2423 Cases, ixhibit 30, and make this case more like Hansen Half, 291 U.S. 559 (1934), and Mortensen United States, 322 U.S. 369 (1944). In Hansen, the Supreme Court rejected charges against a woman traveling back to her home in the United States to "continue her irregular and improper conduct
Entities connected to both Palm Beach and Hansen

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
United States
LOCATIONLeon Black
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSON
New York
LOCATION
Marc Rich
PERSON
New York City
LOCATION
Lesley Groff
PERSONJane Doe
PERSON
Donald Trump
PERSON
Palm Beach County
LOCATIONthe Southern District
LOCATIONFBI
ORGANIZATION
Bill Clinton
PERSON
U.S. Virgin Islands
LOCATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSON