Epstein Secrets

or intimidation. These are the elements required by the statute, and they are not met here. Although CEOS could, perhaps, point to United States v. Evans, 476 F.3d 1176 (11th Cir. 2007) as a case that, standing alone, involved wholly intrastate conduct, the facts of that case are far different in key

them in his house if they were under the age of 18. ss& United States v. Kennard, 472 F.3d 851, 857-858 (11th Cir. 2006), quoting, United States v. Puche 350 F.3d 1137, 1149 (111° Cir. 2003) (An instruction on deliberate ignorance is appropriate only if it is shown [among other things] ... that the de

or intimidation. These arc the elements required by the statute, and they are not met here. Although CEOS could, perhaps, point to United Slat% v. Evans, 476 F.3d 1176 (11°' Cir. 2007) as a case that, standing alone, involved wholly intrastate conduct, the facts of that case are far different in key

t them in his house if they were under the age of 18. See United States v. Kennard, 472 F.3d 851, 857-858 (1 3'Cir. 2006), quoting, United States v Puche, 350 F.3d t 137, 1149 (11th Cir. 2003) (An instruction on deliberate ignorance is appropriate only if it is shown [among other things] ... that the

ulation). Rather, its reach is limited to sex trafficking that involves children or is accomplished by force, fraud, or coercion". United States v. Evans, 476 F.3d 1176, 1179 n. 1 (11* Cir. 2007). Nor, has the Department of Justice deemed it appropriate. See, e.g. United States Department of Justice C

age 4 proceeds of specified unlawful activity,' or (c) 'to avoid a transaction reporting requirement under State or Federal law"'. United States v. Puche, 350 F.3d 1137 (11 Cir. 2003);5 see also United States v. Arditti, 955 F.2d 331 (5th Cir.), reh'g denied, cert. denied 506 U.S. 998 (1992), cert. d

egulation). Rather, its reach is limited to sex trafficking that Involves children or is accomplished by force, fraud, or coercion". United States. Evans, 476 F.3d 1176, 1179 n. 1 (II* Cir. 2007). Nor, has the Department of Justice deemed it appropriate. See, e.g. United States Department of Justice C

Page 4 proceeds of specified unlawful activity,' orAc) `to avoid a transaction reporting requirement under State or Federal law". United States'. Puche, 350 F.3d 1137 (11th Cir. 2003);5 see also United States" Arditti, 955 F.2d 331 (5th Cir.), reh'g denied, cert denied 506 U.S. 998 (1992), cert. de

ulation). Rather, its reach is limited to sex trafficking that involves children or is accomplished by force, fraud, or coercion". United States v. Evans, 476 F.3d 1176, 1179 n. 1(11' Cir. 2007). Nor, has the Department of Justice deemed it appropriate. See, e.g. United States Department of Justice Ci

age 4 proceeds of specified unlawful activity,' or (c) `to avoid a trenchetion reporting requirement under State or Federal law"'. United States v. Puche, 350 F.3d 1137 (11th Cir. 2003);5 see also United States v. Arditti, 955 F.2d 331 (5th Cir.), reh's denied cert. denied 506 U.S. 998 (1992), cert.

ulation). Rather, its reach is limited to sex trafficking that involves children or is accomplished by force, fraud, or coercion". United States v. Evans, 476 F.ad 1176, 1179 n. 1 (1 I th Cir. 2007). Nor, has the Department of Justice deemed it appropriate. See, e.g. United States Department of Justic

Page 4 proceeds of specified unlawful activity,' or (c) `to avoid a transaction reporting requirement under State or Federal law'. United States v. Puche, 350 F.3d 1137 (11th Cir. 2003);5 see also United States v. Arditti, 955 F.2d 331 (5'h Cir.), reh'g denied, cert. denied 506 U.S. 998 (1992), cert.

-MARRA P-011934 EFTA00226722 .O.cet at Gramm B. Liwcount, P.C. Sims, 161 Fed. Appx. 849, 2006 WL 14581 (I I° Cir. 2006) (unpublished). See also Evans, supra, 47613d 1176. The second involves sex tourism sting operations where the defendants signed up for a "Taboo Vacation," usually to go to Costa

Int:our, P.G I proceeds of specified unlawful activity,' or ) 'to avoid araction reporting requirement under State orf ederal law"'. United States Puche, 350 3d 1137 (11" Cir. 2003);' see also United States I Arditti, 955'.2d 331 (5° Cir.), reh'g denied cert. denied 506 U.S. 998 (1992), cert. denie

et them in his house if they were under the age of 18. See United States v. Kennard, 472 F.3d 851, 857-858 (11" Cir. 2006), quoting, United States v. Puche, 350 F.3d 1137, 1149 (11™ Cir. 2003) (An instruction on deliberate ignorance is appropriate only if it is shown [among other things] . . . that the d

or intimidation. These are the elements required by the statute, and they are not met here. Although CEOS could, perhaps, point to United States v. Evans, 476 F.3d 1176 (11" Cir. 2007) as a case that, standing alone, involved wholly intrastate conduct, the facts of that case are far different in key re

s co-conspirators. None of this type of activity comes close to the facts regarding Mr. Epstein. Finally, but significantly, the prostitution ring in Evans was not, in fact, entirely intrastate as the companion case of one of the Evans co-defendants makes clear. See, United States v. Madison, 477 F.3d 13

hem in his house if they were under the age of 18. ss& United States v. Kennard, 472 F.3d 851, 857-858 (I 1th Cir. 2006), quoting, United States v. Puche 350 F.3d 1137, 1149 (111° Cir. 2003) (An instruction on deliberate ignorance is appropriate only if it is shown [among other things] ... that the de

or intimidation. These are the elements required by the statute, and they are not met here. Although CEOS could, perhaps, point to United States v. Evans, 476 F.3d 1176 (11th Cir. 2007) as a case that, standing alone, involved wholly intrastate conduct, the facts of that case are far different in key

co-conspirators. None of this type of activity comes close to the facts regarding Mr. Epstein. Finally, but significantly, the prostitution ring in Evans was not, in fact, entirely intrastate as the companion case of one of the Evans co-defendants makes clear. See, United States v. Madison, 477 F.3d 1