Epstein Secrets

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 Appx. 822 (11 Cir. 2006) (unpublished)(prosecution of several men for conspiracy to hold young women in peonage, and to traffi

9th Cir. 2001) (defendant charged with running an illegal escort service and using proceeds from that business to pay credit cards 5 Instructive is Eleventh Circuit Pattern Jury Instruction 70.4 which states that the defendant can be found guilty of § 1956(a)(3XA) only if (1) he knowingly conducted a financial transacti

lm Beach, FL 33401 (561) 820-8711 Facsimile: (56!) 820-8777 July 10, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH

e victim all asked to address the Court. I cited the CVRA and other statutes to support the Court's authority to hear from them. The second case was United States' Oliver, which was the Office's first case seeking the appointment of a guardian ad litem (GAL). Through these cases, I researched statutes, cases,

, and London, England. Ms. Villafafia remained in civil practice, specializing in intellectual property litigation until 2001, when she was hired by the United States Attorney's Office in Miami. While she enjoyed civil practice, Ms. Villafafia for many years had wanted to be an Assistant United States Attorney. T

and agents on how to investigate and prosecute those cases. U.S.'. Alfonso Diaz Cardenas, 07-Cr-80108 AUSA Villafafia assisted in the drafting of Eleventh Circuit Pattern [Criminal] Jury Instructions related to child exploitation offenses, including clarifying that, in cases of actual contact with a child, there is n

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

9th Cir. 2001) (defendant charged with running an illegal escort service and using proceeds from that business to pay credit cards $ Instructive is Eleventh Circuit Pattern Jury Instruction 70.4 which states that the defendant can be found guilty of § 1956(a)(3)(A) only if ( I) he knowingly conducted a financial transac

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

ates 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 (1th Cir. 2000) (pimp who ran a prostitution ring convicted of violating § 2421). Likewise, in keeping with its purpose and

9th Cir. 2001) (defendant charged with running an illegal escort service and using proceeds from that business to pay credit cards s Instructive is Eleventh Circuit Pattern Jury Instruction 70.4 which states that the defendant can be found guilty of § 1956(a)(3)(A) only if (I) he knowingly conducted a financial transact

l shall execute the form (which can be retrieved from www.flsd.uscourts.gov) entitled "Notice of Right to Consent to Disposition of a Civil Case by a United States Magistrate Judge," and forward the original, executed form to defendants' counsel. After completion by all defendants or their counsel, the origina

tipulated proposed verdict form in hard copy form and on 3.5" diskette. All requested instructions shall be typed on a separate page, and except for Eleventh Circuit Pattern instructions, must be supported by citations of authority. Any objections to the proposed instructions shall be stated clearly and concisely and al

, and London, England. Ms. Villafafia remained in civil practice, specializing in intellectual property litigation until 2001, when she was hired by the United States Attorney's Office in Miami. While she enjoyed civil practice m. many years had wanted to be an Assistant United States Attorney. Two early career

er prosecutors and agents on how to investigate and prosecute those cases. • U.S.'. Alfonso Diaz Cardenas, 07-Cr-80108 =isted in the drafting of Eleventh Circuit Pattern [Criminal] Jury Instructions rel exploitation offenses, including clarifying that, in cases of actual contact with a child, there is no requiremen

is no evidence that the phone was used to induce the young women to do anything other than provide EFTA00225884 • • • Page 25 (1995) (quoting United States' Enmons, 410 U.S. 3%, 411-12 (1973)). In Enmons, the Court refused to accept the Government's "broad concept" of the Hobbs Act, because it would have

t, the Government must prove that Mr. Epstein had the specific intent to target a known minor at the time of the call. See Offense Instructions 80, Eleventh Circuit Pattern Jury Instructions-Criminal, (2003), see supra part H.A.I. ("The Defendant can be found guilty of that offense only if . . . the Defendant believed