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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
o, its silence is controlling." Delgado,. United States Att'y Gen. 487 F.3d 855, 862 (11th Cir. 2007) (quoting CBS, 245 F.3d at 1226 (itself quoting Griffith, 206 F.3d at 1394 with citation and quotations omitted))) (alteration omitted). Because the statute provides a single cause of action with a single
er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were
tation does not necessarily require enticement, and likewise enticement to travel does not necessarily require transportation. See United States v. Griffith, No. 99 Cr. 786 (HB), 2000 WL 1253265, at *4 (S.D.N.Y. Sept. 5, 2000) (denying post-trial motion to dismiss as multiplicitous 18 U.S.C. § 2422 tran
er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were
tation does not necessarily require enticement, and likewise enticement to travel does not necessarily require transportation. See United States v. Griffith, No. 99 Cr. 786 (HB), 2000 WL 1253265, at *4 (S.D.N.Y. Sept. 5, 2000) (denying post-trial motion to dismiss as multiplicitous 18 U.S.C. § 2422 tran
er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were
tation does not necessarily require enticement, and likewise enticement to travel does not necessarily require transportation. See United States v. Griffith, No. 99 Cr. 786 (HB), 2000 WL 1253265, at *4 (S.D.N.Y. Sept. 5, 2000) (denying post-trial motion to dismiss as multiplicitous 18 U.S.C. § 2422 tran
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 →h Circuit soundly rejected the argument, citing the other circuits reaching the same conclusion. Jones, 471 F.3d at 538-39 (citing United States v. Griffith, 284 F.3d 338, 351 (2d Cir. 2002); United States v. Taylor, 239 F.3d 994, 997 (9th Cir. 2001); United States v. Scisum, 32 F.3d 1479, 1485-86 (10th
Page: EFTA02857524_p6 →h Circuit soundly rejected the argument, citing the other circuits reaching the same conclusion. Jones , 471 F.3d at 538-39 (citing United States v. Griffith , 284 F.3d 338, 351 (2d Cir. 2002); United States v. Taylor , 239 F.3d 994, 997 (9th Cir. 2001); United States v. Scisum , 32 F.3d 1479, 1485-86 (1
Page: EFTA02857763_p3 →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 Griffith

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSONLeon Black
PERSON
United States
LOCATION
Alan Dershowitz
PERSONJack Goldberger
PERSON
New York
LOCATION
Marc Rich
PERSON
West Palm Beach
LOCATION
Eric Holder
PERSON
Donald Trump
PERSON
New York City
LOCATION
Lesley Groff
PERSONJane Doe
PERSON
Palm Beach County
LOCATION
U.S. Virgin Islands
LOCATION
Prince Andrew
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION