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d to use or promote the same unlawful activity. Accordingly, one could charge Epstein alone with individual counts ofviolating Section 1960 for each Western Union transfer and for each ATM withdrawal that occurred immediately prior to one of Banasiak's documented payments to one of the girls. I decided not to
Page: EFTA02857524_p31 →massage. 1. The Overt Acts Based upon Activity with Jane Doe #1 1. On or about March 11 2004, Defendants JEFFREY EPSTEIN, MI and traveled from Teterboro, New Jersey, to Palm "During her interview with the police, caught herself and said "He likes girls who are 18 to 20," but in talking with the fed
Page: EFTA02857524_p34 →hat I forego the Section 1956 charge and, instead, charge Epstein with aiding and abetting the unlicensed money transmitting by causing his bank and Western Union unwittingly to transmit funds intended to be used to promote and support sex trafficking and white slave traffic. The Money Laundering Section refe
Page: EFTA02857763_p16 →the massage. 1. The Overt Acts Based upon Activity with Jane Doe #5 1. On or about March 11, 2004, Defendants JEFFREY EPSTEIN, and traveled from Teterboro, New Jersey, to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. 2. On or about March 12, 2004, Defe
Page: EFTA02857763_p19 →stern Union were the innocent intermediaries who operated the money transmitting business. Nonetheless, Epstein's directions to pay the girls caused Western Union to transmit funds that were intended to be used to promote or support unlawful activity — the prostitution of minors. Epstein's directions to Banasi
Page: EFTA02857810_p17 →e Charges and Overt Acts Based upon Activity with JD#1 a. Overt Acts #. On or about March 11, 2004, Defendants JEFFREY EPSTEIN, and traveled from Teterboro, New Jersey, to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. #. On or about March 12, 2004, Defe
Page: EFTA02857810_p19 →Entities connected to both Teterboro and Western

Jeffrey Epstein
PERSON
Marc Rich
PERSONLeon Black
PERSON
Palm Beach
LOCATIONJanusz Banasiak
PERSON
U.S. Virgin Islands
LOCATION
Ghislaine Maxwell
PERSON
New York
LOCATION
Virginia Giuffre
PERSON
United States
LOCATION
Sarah Kellen
PERSON
New Jersey
LOCATION
Barry Diller
PERSON
Aspen
LOCATION
Alexander Acosta
PERSON
Palm Beach County
LOCATION
Van Nuys
LOCATIONEmmy Taylor
PERSON
Columbus
LOCATION
Colorado
LOCATION