Epstein Secrets

onally governed by state regulation). real Rather, its is limited t trafficking that jgntig,0Nop or is accomplished by force, fraud, or coercion". United Stales Evans, 476 ■3d 1176, 1179 it I (I l• Ctr. 2007). Nor, has the Department of Justice deemed it appropriate. e e.g. Unit tates Department of Justic

of several men for conspiracy to hold young women in peonage, and to traffic them for commercial sex acts, involving force and threats; bail issue); United Stares v. 4 A review of the Linked Sutes Department of Justice Civil Rights Division Anti-Trafficking News Bulktins confirms that this same pattern exists

many instances, due to the lack of uniform regulation, these businesses have served to transfer funds which were the proceeds of illegal activity. See United States' Valdes, 2006 U.S. Dist. LEXIS 12432 (S.D.N.Y. 2006) (defendants transmitted proceeds of drug trafficking to Colombia); see also P.L. 103-325, Title

d to protect women agai t conduct, commercial whethv commercial or no t involves transportation and is exploitive or violent. See, e.g., De Vault I United States, 338 2d 179,180 (10th Cir. 1964) (applying the Act to protect girl who was raped). j r The Mann Act is a relatively antiquated morality statute th

d States! Hearn( 381 .3d 80 (2d Cir. 2004) (woman running prostitution business convicted for recruiting and transport of prostitutes under § 2421); United States' Footman, 215 1.3d 145 (I" Cir. 2000) (pimp who ran a prostitution ring convicted of violating § 2421). Likewise, in keeping with its purpose and tit

d Does Not Fall Within the Ambit of the Statute 18 § 1591 - "Sex Trafficking of Children or by Force, Fraud, or Coercion" — was passed as part of the Trafficking Victims Protection Act ("TVPA") to address a problem far removed from the present set of circumstances: human trafficking, in general, and human sex trafficking, in parti

inappropriate. The money laundering statute was designed to be used and has been construed as a "concealment" statute, not a spending statute. See United Stales v. Shepard, 396 F.3d 1116 (10th Cir.), cert. denied, 545 U.S. 1110 (2005); United States v. Hall, 434 F.3d 42 (1st Cir. 2006) (money laundering sta

d terrorism. The type of business contemplated by Congress is one which, for a fee, accepts funds for transfer within or outside the United States. See United States v. Talebnejad 460 F.3d 563, 565 (4th Cir. 2006); United States v. Velastegui, 199 F.3d 590 (2d Cir. 1999). Once the money transmitter receives the

tes v. Holland, 381 F.3d 80 (2d Cir. 2004) (woman running prostitution business convicted for recruiting and transport of prostitutes under § 2421); United States v. Footman, 215 F.3d 145 (1s1 Cir. 2000) (pimp who ran a prostitution ring convicted of violating § 2421). Likewise, in keeping with its purpose and

prostituting underage persons, either by force, fraud, or coercion. These cases bear no relationshijo to the circumstance at issue here. See, e.g., United Slates v. Norris, 188 Fed. Appx. 822 (11 Cir. 2006) (unpublished)(prosecution of several men for conspiracy to hold young women in peonage, and to traffi

Not Fall Within the Ambit of the Statute 18 U.S.C. § 1591 - "Sex Trafficking of Children or by Force, Fraud, or Coercion" — was passed as part of the Trafficking Victims Protection Act ("TVPA") to address a problem far removed from the present set of circumstances: human trafficking, in general, and human sex trafficking, in parti

Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 1 of 16 Reid Weingarten 1114 Avenue of the Americas New Vries. NY 10036 main direct www.stetocom July 11, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern Dis

ed States v. Chen, 820 F. Supp. 1205, 1207 (N.D. Cal. 1992). Mr. Epstein's lone foreign residence is in Paris; France has an extradition treaty with the United States. 5 Mr. Epstein owns one private jet. He sold the other jet in June 2019. 4 EFTA00058432 Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 5

. Senior officials at the Department of Justice reviewed the NPA and either authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litiga

of seeking bail. We will amplify it later, along with various other arguments, in full-blown dismissal motions. Section 1591 was passed as part of the Trafficking Victims Protection Act of 2000 ("TVPA"), Pub. L. No. 106-386, 114 Stat. 1464 (October 28, 2000). In enacting the TVPA, Congress recognized that human trafficking, particu

Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 1 of 16 Reid Weingarten 1114 Avenue of the Americas New York. NY 10036 212 506 3900 main 212 506 3955 direct www.steoloccorn nreeinoartenOsteotoe.com July 11, 2019 VIA ECF The Honorable Richard

ed States v. Chen, 820 F. Supp. 1205, 1207 (N.D. Cal. 1992). Mr. Epstein's lone foreign residence is in Paris; France has an extradition treaty with the United States. 5 Mr. Epstein owns one private jet. He sold the other jet in June 2019. 4 EFTA00076071 Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 5

. Senior officials at the Department of Justice reviewed the NPA and either authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litiga

of seeking bail. We will amplify it later, along with various other arguments, in full-blown dismissal motions. Section 1591 was passed as part of the Trafficking Victims Protection Act of 2000 ("TVPA"), Pub. L. No. 106-386, 114 Stat. 1464 (October 28, 2000). In enacting the TVPA, Congress recognized that human trafficking, particu

Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 1 of 16 Reid Weingarten 1114 Avenue of the Americas New York. NY 10036 WWW.StetO TI July 11, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern District of New Yo

ed States v. Chen, 820 F. Supp. 1205, 1207 (N.D. Cal. 1992). Mr. Epstein's lone foreign residence is in Paris; France has an extradition treaty with the United States. 5 Mr. Epstein owns one private jet. He sold the other jet in June 2019. 4 EFTA00097463 Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 5

. Senior officials at the Department of Justice reviewed the NPA and either authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litiga

of seeking bail. We will amplify it later, along with various other arguments, in full-blown dismissal motions. Section 1591 was passed as part of the Trafficking Victims Protection Act of 2000 ("TVPA"), Pub. L. No. 106-386, 114 Stat. 1464 (October 28, 2000). In enacting the TVPA, Congress recognized that human trafficking, particu

d and common objectives. Both Counts Three and Five are charged under the same statute, 18 U.S.C. § 371, for conspiracy to commit an offense against the United States. But going beyond this "general level" of similarity, the statutory objectives of the two counts differ. Macchia, 35 F.3d at 669. Count Three is a c

peculation, with the apparent presumption that absent evidence would necessarily favor the Defendant, is insufficient to establish actual prejudice. See United States v. Long, 697 F. Supp. 651, 657 (S.D.N.Y. 1988) (no prejudice where there is "no way of knowing what [an absent witness's] testimony would have been

. at 2895.2 Count Five of the Indictment also charged the Defendant under 18 U.S.C. § 371, but for conspiring to violate 18 U.S.C. §§ 1591(a) & (b) (the Trafficking Victims Protection Act), by trafficking individuals under the age of eighteen for commercial sex acts that affect interstate commerce. S2 Indictment 9¶ 22-24. Count Five'

first enacted by Congress in 1910 to prevent the use of interstate commerce to facilitate prostitution, concubinage, or other forms of immorality. Hoke I United States, 227 U.S. 308 (1913); Wilson I United States, 232 U.S. 563 (1914); Caminetti I United States, 242 U.S. 470 (1917). The statute's primary purpose was

illicit sexual conduct was an "important" "purpose of the travel, a significant motivating factor", or in other words, more than merely incidental. See United States' J!orschauer, 2007 WL 979931 (11th Cir. 2007) (unpublished). We understand from conversations with Ms. Villafaiia that she believes that Mr. Epstein

Not Fall Within the Ambit of the Statute 18 U.S.C. § 1591 - "Sex Trafficking of Children or by Force, Fraud, or Coercion" — was passed as part of the Trafficking Victims Protection Act ("TVPA") to address a problem far removed from the present set of circumstances: human trafficking, in general, and human sex trafficking, in parti

d terrorism. The type of business contemplated by Congress is one which, for a fee, accepts funds for transfer within or outside the United States. See United States v. Talebnejad, 460 F.3d 563, 565 (4th Cir. 2006); United States v. Velastegui, 199 F.3d 590 (2d Cir. 1999). Once the money transmitter receives the

tes v. Holland, 381 F.3d 80 (2d Cir. 2004) (woman running prostitution business convicted for recruiting and transport of prostitutes under § 2421); United States v. Footman, 215 F.3d 145 (Ig Cir. 2000) (pimp who ran a prostitution ring convicted of violating § 2421). Likewise, in keeping with its purpose and

Not Fall Within the Ambit of the Statute 18 U.S.C. § 1591 — "Sex Trafficking of Children or by Force, Fraud, or Coercion" — was passed as part of the Trafficking Victims Protection Act ("TVPA") to address a problem far removed from the present set of circumstances: human trafficking, in general, and human sex trafficking, in parti

ed States v. Chen, 820 F. Supp. 1205, 1207 (N.D. Cal. 1992). Mr. Epstein's lone foreign residence is in Paris; France has an extradition treaty with the United States. 5 Mr. Epstein owns one private jet. He sold the other jet in June 2019. 4 EFTA00095874 Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 5

. Senior officials at the Department of Justice reviewed the NPA and either authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litiga

of seeking bail. We will amplify it later, along with various other arguments, in full-blown dismissal motions. Section 1591 was passed as part of the Trafficking Victims Protection Act of 2000 ("TVPA"), Pub. L. No. 106-386, 114 Stat. 1464 (October 28, 2000). In enacting the TVPA, Congress recognized that human trafficking, particu