EFTA00022177.pdf

Type: pdf
Source set: data-set-8
Extracted text

From: ' 
To: ' 
)"  
Subject: RE: Decision on motion to strike 
Date: Sun, 07 Nov 2021 15:12:38 +0000 
Will do! 
From: 
/ •c
)' 
Sent: Sunday, November 7, 2021 10:06 AM 
To: 
Subject: RE: Decision on motion to strike 
Let's put this language in our letter! Maybe in the paragraph I added at the end about checking ID's at the door? I think 
this is an important point. 
First, as the Indictment itself makes clear, the defendant's and Epstein's interactions with Minor Victim-3 were part 
of a broader scheme and agreement to entice and transport minor victims with intent to commit illegal sex acts. 
Even if Minor Victim-3 was not ultimately transported as a minor, the core of a conspiracy is an agreement to 
engage in criminal conduct; there is no legal requirement that the agreed upon crime be completed. 
Because a conspiracy does not require the completion of a substantive crime, it does not matter whether Minor 
Victim-3 was ever in fact transported as a minor,  or whether the elements of the substantive crimes of 
transportation an enticement are satisfied as to her. See Salinas, 522 U.S. at 65. 
From: 
Sent: Sunday, November 7, 2021 10:00 AM 
To: 
Subject: RE: Decision on motion to strike 
Sure thing. The discussion starts on page 184 of the PDF (157 of the pagination). 
From: 
Sent: Sunday, November 7, 2021 9:58 AM 
To: 
Subject: RE: Decision on motion to strike 
thanks, would you mind also sending me our brief on this? 
From: 
Sent: Sunday, November 7, 2021 9:49 AM 
To: 
< 
Subject: Decision on motion to strike 
Heys, 
Attached is Judge Nathan's first decision denying the pretrial motions. The (very brief) discussion of MV-3 starts on page 
26. 
Thanks, 
EFTA00022177


Assistant United States Attorney 
Southern District of New York 
1 Saint Andrews Plaza 
New York, New York 10007 
EFTA00022178
Open in the interactive archive →