This legal document, filed on June 22, 2022, presents evidence to argue that a defendant remained a close associate of Jeffrey Epstein for several years after 2002. The evidence includes flight logs showing she flew on his private jet dozens of times between 2003 and 2005, records of Epstein paying for her travel through 2006, and a bank record of Epstein transferring over $7.7 million to her account as of 2007. The document also mentions a 2005 police search of Epstein's Palm Beach residence which found items indicating the defendant's 'forceful presence' in the house.
This legal document, part of a court filing, argues that the 2004 U.S. Sentencing Guidelines Manual should be applied to the defendant's case. It refutes the defendant's objections, which are based on the Ex Post Facto Clause, by establishing that the criminal conduct continued until December 31, 2004, after the 2004 Manual became effective. The argument is supported by citations to the Guidelines and Second Circuit case law.
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