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re they all!! me that they believe their fourteen year old daughter may have had some type of sexual relationship with an older male who resided in Palm Beach. Neither knew the suspect s name or address. Both stated that their daughter did not talk to them about the incident, nor would she admit to it. i
in's house by her associate, stated this occurred late May 2004 or early June 2004. S e was told she could model lingerie for money for a wealthy Palm Beacher. She remembered they traveled by yellow cab from their residence in West Palm Beach to Epstein's house. She remembered encountering Epstein at the
.7 The Supreme Court has repeatedly interpreted this language to require that the illegal activity be the dominant motive for the travel. See, e.g., Mortensen' United States, 322 U.S. 369, 373 (1944) (". ..an intention that the women or girls shall engage in the conduct outlawed by Section 2 must be found
Epstein's assistants to make an appointment to "work." Up to three appointments each day would be made. The girls would travel to Epstein's home in Palm Beach where they would meet Epstein's chef and Epstein's assistant—usually an the kitchen. The assistant normally would escort the girls upstairs to the
prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen. United States, 322 U.S. 369, 374 (1944); Crespo I. United States, 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of ten
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
cts, they travel for that purpose, is to emphasize that which is incidental and ignore what is of primary significance." Id. at 562-63. Likewise, in Mortensen'. United States 322 U.S. 369 (1944), defendants were convicted after two women they employed as prostitutes at their Nebraska brothel traveled to U
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
entry [into the United States] cannot be said to be with the purpose `only that she might live in a state of concubinage."' 291 U.S. at 562. And in Mortensen, the Court likewise held that two women who took a trip from their home, returned home, and then resumed their illegal prostitution business did not
f Epstein's assistants to make an appointment to "work." Up to three appointments each day would be made. The girls would travel to Epstein's barsip Palm Beach where they would meet Epstein's chef and Epsteiti's assistant—usually an the kitchen. The assistant normally would escort the girls upstairs to the
Page: EFTA02857524_p3 →prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen v. United States, 322 U.S. 369, 374 (1944); Crespo v. United States, 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of t
Page: EFTA02857524_p23 →prove that the defendant's sole purpose for traveling and transporting the individual was to have the individual engage in illegal sexual activity. Mortensen v. United States , 322 U.S. 369, 374 (1944); Crespo v. United States , 151 F.2d 44, 46 (1st Cir. 1945). This offense carries a statutory maximum of
Page: EFTA02857763_p13 →they refused to speculate on the ages of the "masseuses." And, as mentioned above, Jane Doe #3 estimates that she brought thirty girls to Epstein's Palm Beach home during the 18 month period that she was in contact with him. V. OTHER ISSUES RAISED BY THE DEFENSE When you review the cover letter from Geral
Page: EFTA02857763_p45 →Entities connected to both Palm Beach and Mortensen

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSONLeon Black
PERSON
United States
LOCATIONJack Goldberger
PERSON
Alan Dershowitz
PERSON
New York
LOCATION
West Palm Beach
LOCATION
Marc Rich
PERSON
New York City
LOCATION
Lesley Groff
PERSONJane Doe
PERSON
Palm Beach County
LOCATION
Donald Trump
PERSON
U.S. Virgin Islands
LOCATIONFBI
ORGANIZATIONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON