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an Dershowitz, Esq. November 19, 2007 Page 14 interstate journey and must be the dominant motive of such interstate movement.") (emphasis added); Cleveland v. United States, 329 U.S. 14, 20 (1946) ("There was evidence ... that the unlawful purpose was the dominant motive.").' Under these standards, the
(11h Cir. 2004); United States v. Miranda, 348 F.3d 1322 (11th Cir. 2003); United States v. Tillman 195 F.3d 640 (11th Cir. 1999); United States v.Panfil, 338 F.3d 1299 (11° Cir. 2003); United States v. Garrett, 190 F.3d 1220 (11th Cir. 1999); gintosovvsisto, 175 F.3d 1261 (11th Cir. 1999); United. St
t be found to exist before the conclusion of the interstate journey and must be the dominant motive of such interstate movement") (emphasis added)• Cleveland v, United States, 329 U.S. 14, 20 (1946) ("There was evidence that the unlawful purpose was the dominant motive.").2 Under these standards, there i
3 (1Is Cir. 2004); United States v. Miranda, 348 F.3d 1322 (11th Cir. 2003). United States v Tillmog, 195 F.3d 640 (1l d' Cir. 1999)• USA States v.Panfil 338 F.3d 1299 (11° Cir. 2003); United States v. Garrett, 190 F.3d 1220 Ws Cir. 1999). United States v. Burgess, 175 F.3d 1261 (11° Cir. 1999). Uni
T]he only factual issue in the case was whether paitioners dominant purpose in making the trip was to facilitate her practice of prostitution. . .); Cleveland I United States, 329 U.S. 14, 20 (1946) ("There was evidence .. . that the unlawful purpose was the dominant motive."). There is no basis for conc
ate or otherwise interact improperly with persons who turn out to be minors. A prosecution of Mr. Epstein would violate the teachings of Bailey and Panfil. As we believe we persuaded you at the June 26'h meeting, Mr. Epstein never targeted minors. On the contrary, what he did — at worst — was akin to
Entities connected to both Cleveland and Panfil

Jeffrey Epstein
PERSON
Donald Trump
PERSONLeon Black
PERSON
United States
LOCATION
George W. Bush
PERSON
Julie K. Brown
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Joe Biden
PERSON
Michael Jackson
PERSON
Houston
LOCATIONEmmy Taylor
PERSON
New York
LOCATION
Michigan
LOCATION
Stephen Hawking
PERSON
Prince Charles
PERSON
Eric Trump
PERSON
Scarlett Johansson
PERSON
Wisconsin
LOCATION
Paul Ryan
PERSON