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gress, and administration policy statements intended in 18 U.S.C. § 1591 prosecutions. Evans, and his co-conspirators (Madison and Yearby) were not "Johns." They operated a for profit prostitution ring marked by control of, and extreme violence toward, the victims, who they knew were underage. Indeed,
Page: EFTA00013797 →1313-1314 (11th Cir. 2007) (Jane Doe #2 stated that she traveled to Atlanta, Georgia with Madison to work as a prostitute). Thus, courts, including the Eleventh Circuit in Evans, have underscored the point that § 1591 simply is not intended to cover the kind of alleged conduct at issue here. "Section 1591 does not
Page: EFTA00013797 →stein is prepared to plead guilty and accept a sentence for that offense—a sentence that, notably, is far more severe than that meted out to other "Johns" convicted of violating Florida's solicitation laws for cases in which sexual activity was alleged. Though CEOS points out its admirable goal of "p
individual woman. As the statute makes clear, the essence of this crime is the communication itself—not the resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point: The defendant in Bailey contended that attempt under § 2422(6) 'requires the specific intent to commit illegal
stein is prepared to plead guilty and accept a sentence for that offense—a sentence that, notably, is far more severe than that meted out to other "Johns" convicted of violating Florida's solicitation laws for cases in which sexual activity was alleged. Though CEOS points out its admirable goal of "p
individual woman. As the statute makes clear, the essence of this crime is the communication itself—not the resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point: The defendant in Bailey contended that attempt under § 2422(b) `requires the specific intent to commit illegal
ted States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 162 United States v. Jimenez, 824 F. Supp. 351 (S.D.N.Y. 1993) 240, 268 United States v. Johns, 15 F.3d 740 (8th Cir. 1994) 37 United States v. Johnson, 21 F. Supp. 2d 329 (S.D.N.Y. 1998) 294 United States v. Jones, 482 F.3d 60 (2d Cir.
rt to apply a bizarre and unprecedented choice-of- federal-law doctrine, under which the defendant asks the Court to apply non-existent rulings from the Eleventh Circuit on an issue that Court does not appear to have reached. (Def. Mot. 1 at 23- 25). This argument has no legal foundation, and the defendant offers no a
ited States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 162 United States v. Jimenez, 824 F. Supp. 351 (S.D.N.Y. 1993) 240, 268 United States v. Johns, 15 F.3d 740 (8th Cir. 1994) 37 United States v. Johnson, 21 F. Supp. 2d 329 (S.D.N.Y. 1998) 294 United States v. Jones, 482 F.3d 60 (2d Cir.
rt to apply a bizarre and unprecedented choice-of- federal-law doctrine, under which the defendant asks the Court to apply non-existent rulings from the Eleventh Circuit on an issue that Court does not appear to have reached. (Def. Mot. 1 at 23- 25). This argument has no legal foundation, and the defendant offers no a
ited States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 162 United States v. Jimenez, 824 F. Supp. 351 (S.D.N.Y. 1993) 240, 268 United States v. Johns, 15 F.3d 740 (8th Cir. 1994) 37 United States v. Johnson, 21 F. Supp. 2d 329 (S.D.N.Y. 1998) 294 United States v. Jones, 482 F.3d 60 (2d Cir.
rt to apply a bizarre and unprecedented choice-of- federal-law doctrine, under which the defendant asks the Court to apply non-existent rulings from the Eleventh Circuit on an issue that Court does not appear to have reached. (Def. Mot. 1 at 23- 25). This argument has no legal foundation, and the defendant offers no a
ited States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 110 United States v. Jimenez, 824 F. Supp. 351 (S.D.N.Y. 1993) 159, 176 United States v. Johns, 15 F.3d 740 (8th Cir. 1994) 28 United States v. Johnson, 21 F. Supp. 2d 329 (S.D.N.Y. 1998) 202 United States v. Jones, 482 F.3d 60 (2d Cir.
rt to apply a bizarre and unprecedented choice-of- federal-law doctrine, under which the defendant asks the Court to apply non-existent rulings from the Eleventh Circuit on an issue that Court does not appear to have reached. (Def. Mot. 1 at 23- 25). This argument has no legal foundation, and the defendant offers no a
ted States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 162 United States v. Jimenez, 824 F. Supp. 351 (S.D.N.Y. 1993) 240, 268 United States v. Johns, 15 F.3d 740 (8th Cir. 1994) 37 United States v. Johnson, 21 F. Supp. 2d 329 (S.D.N.Y. 1998) 294 United States v. Jones, 482 F.3d 60 (2d Cir.
rt to apply a bizarre and unprecedented choice-of- federal-law doctrine, under which the defendant asks the Court to apply non-existent rulings from the Eleventh Circuit on an issue that Court does not appear to have reached. (Def. Mot. 1 at 23- 25). This argument has no legal foundation, and the defendant offers no a
Epstein is prepared to plead guilty and accept a sentence for that offense—a sentence that, notably, is far more severe than that meted out to other “Johns” convicted of violating Florida’s solicitation laws for cases in which sexual activity was alleged. Though CEOS points out its admirable goal of “pr
Page: HOUSE_OVERSIGHT_012144 →s to engage in a criminal sex act or (b) that Owens was under the age of 18.) (emphasis added). Again, none of these factors is present in this case. The Eleventh Circuit’s interpretation of the statute makes perfect sense: were § 1591 not limited in this fashion, it would threaten to criminalize a host of localized beha
Page: HOUSE_OVERSIGHT_012196 →Entities connected to both Johns and the Eleventh Circuit

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Scarlett Johansson
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Department of Justice
ORGANIZATIONJack Goldberger
PERSON
George W. Bush
PERSON
Alexander Acosta
PERSONMaria Farmer
PERSONFBI
ORGANIZATION
A. Marie Villafana
PERSONMartin Weinberg
PERSON
Julie K. Brown
PERSON
Supreme Court
ORGANIZATION
Jay Lefkowitz
PERSON
Alan Dershowitz
PERSON