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Case 1:20-cr-00330-PAE Document621 Filed 02/25/22 Page 49of51
2080-84 (shopping with Annie in New Mexico and teaching her to massage Epstein’s feet), 840-
45 (recruiting Virginia and instructing Alessi to bring her to Epstein’s Florida house), 1524
(Virginia receiving money for sex with Epstein), 1534 (inviting Carolyn to travel)). The jury
evidently credited this testimony, and based on that testimony and the reasonable inferences from
it, a rational jury easily could have (and did) find her guilty on Count One.
The defendant has made no substantive argument as to the sufficiency of the evidence on
the remaining counts, and for good reason. Just as the conspiracies in Counts One and Three are
multiplicitous because enticement and transportation are dual aims of the same conspiracy, see
supra Part III, Count Three is amply supported by the evidence underlying Count One. As to
Count Four, the record contains evidence that the defendant made travel arrangements for Jane,
including the specific incident in which Jane had difficulty returning from New York to Palm
Beach, and that the defendant traveled with Jane on Epstein’s private plane. (Tr. 2268-69; see Tr.
316-17 (testimony that the defendant traveled with Jane on Epstein’s private jet and would “assist”
in “making travel arrangements”); Tr. 323-24 (“[S]ometimes it would be — Jeffrey would ask her,
hey, can you get Jane, you know, tickets and the times and whatnot and make the arrangements to
be picked up.”). That, in combination with evidence of the defendant’s participation in Jane’s
abuse in New York, is sufficient on its own for the jury to convict on Count Four. See United
States v. Vargas-Cordon, 733 F.3d 336 (2d Cir. 2013) (“The record is replete with evidence from
which a reasonable jury could infer that sexual access to Jaire was a dominant purpose of Vargas-
Cordon’s repeated transport of her from his New Jersey home into Brooklyn.”); United States v.
Mi Sun Cho, 713 F.3d 716, 720 (2d Cir. 2013) (“Cho does not dispute that one who arranges
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Document Details
| Filename | DOJ-OGR-00009611.jpg |
| File Size | 706.1 KB |
| OCR Confidence | 94.9% |
| Has Readable Text | Yes |
| Text Length | 2,060 characters |
| Indexed | 2026-02-03 17:48:38.126427 |