Subject: RE: Decision on motion to strike Date: Sun, 07 Nov 2021 15:12:38 +0000¶
Will do!¶
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| Sent: Sunday, November 7, 2021 10:06 AM | ||
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| 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 legalrequirement 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).¶
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| Sent: Sunday, November 7, 2021 9:58 AM | |
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| Subject: RE: Decision on motion to strike |
thanks, would you mind also sending me our brief on this?¶
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| Sent: Sunday, November 7, 2021 9:49 AM | |
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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,¶
Assistant United States Attorney Southern District of New York 1 Saint Andrews Plaza New York, New York 10007¶