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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
ty; and Third: that the Defendant engaged in the financial transaction with the intent to promote the carrying on of specified unlawful activity. Eleventh Cir. Pattern Jury Instr., Offense Instr. 70.4 (2003). 30 EFTA00234546 The term "unlawful activity" is not defined in Section 1960. Another one of the
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 →y; and Third: that the Defendant engaged in the financial transaction with the intent to promote the carrying on of specified unlawful activity. Eleventh Cir. Pattern Jury Instr., Offense Instr. 70.4 (2003). 29 EFTA02857552 money laundering statutes, Section 1956 cross-references Section 1961(1) for th
Page: EFTA02857524_p29 →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 →ty; and Third : that the Defendant engaged in the financial transaction with the intent to promote the carrying on of specified unlawful activity. Eleventh Cir. Pattern Jury Instr., Offense Instr. 70.4 (2003). F Tobon-Builes was decided prior to the enactment of 31 U.S.C. § 5324(a), which created a criminal
Page: EFTA02857763_p47 →Entities connected to both Palm Beach and Eleventh Cir

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
United States
LOCATION
New York
LOCATION
West Palm Beach
LOCATION
Marc Rich
PERSON
Palm Beach County
LOCATIONJane Doe
PERSON
U.S. Virgin Islands
LOCATION
Department of Justice
ORGANIZATION
Teterboro
LOCATION
Palm Beach Police Department
ORGANIZATION
Barry Diller
PERSON
Virginia Giuffre
PERSON
Alexander Acosta
PERSON
Barry Krischer
PERSON
Joe Biden
PERSONRoy Black
PERSON
The Palm Beach Post
ORGANIZATION