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Case 1:20-cr-00330-PAE Document621 Filed 02/25/22 Page8of51 the Government “consistently maintained that to convict [the defendant] on the Mann Act Counts (Counts One through Four), it was necessary to prove that [the defendant] enticed or caused underaged girls to travel to New York, or conspired to do the same, with the intent that they would engage in illegal sexual activity that violated New York law.” (Def. Mot. at 1). The Government never advanced a theory that the illegal sexual activity identified in the S2 Indictment was sexual activity that occurred outside New York. At trial, the Government marshalled evidence that the defendant knowingly transported Jane to New York, and aided and abetted Epstein in doing so, with the intent that Jane engage in criminal sexual activity there in violation of New York law. That evidence included testimony from Jane in detail about Epstein’s New York residence (Tr. 316-19) and specific sexual acts that took place in New York while Jane was a minor (Tr. 319-20). As the defendant rightly concedes, “most of [Jane’s] trips were to New York” and “the majority of Jane’s testimony about the trips consisted of a description of Epstein’s house in New York and the sexual abuse she experienced there.” (Def. Mot. at 13). The Government also offered significant corroborating evidence, including flight records and photographs of Epstein’s New York residence. On the conspiracy counts, the Government also offered evidence that the defendant and Epstein transported another victim, Virginia Roberts, to New York while she was a minor. (See, e.g. Tr. 1862 (describing a flight from 2001 in which Epstein, the defendant, and Virginia flew from Maine to Teterboro, New Jersey)). The Government’s summation similarly discussed the Mann Act offenses as encompassing conduct directed at New York. The Government explained that Count Two “is about Jane and DOJ-OGR-00009570