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Our evidence of the interstate commerce element here would include testimony
regarding phone calls she received from New York while in Florida to arran e massages, as well
as Victoria's Secret lingerie that Epstein sent from New York to home in Florida.
Additionally, the labels on the massage table and sex toys recov m Epstein's Palm Beach
residence during the October 2005 search indicate that those products were manufactured outside
of the state of Florida.
Finally, we would propose to establish venue through the same evidence referenced in our
discussion of Counts One and Three. Conspiracy charges may be brought "in any district in which
an overt act in furtherance of the conspiracy was committed." United States v. Lange, 834 F.3d
58, 68 (2d Cir. 2016). Here, the calls from New York to schedule appointments and the packages
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