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s alleged to have had improper sexual contact, solely in Florida, with womcn who were under the age of 18. Mr. Epstein maintained residences both in New York and Florida and would repeatedly fly from New York to Florida where his primary residence was located He would travel to Florida for purposes of re
el for the Purpose of engaging in unlawful sexual activities. United States v, Hayward 359 F.3d 631, 638 (3d Cir. 2004). See also United States v. Tykarsky 446 F.3d 458, 471 (3d Cir. 2006): EFTA00214725 12/07/07 FRI 15:39 FAI 1 213 880 8500 R I RMANDRELL I S 1.1.P lib 0 21 Alan Dcrshowitz, Esq. D
ate with the young prostitute, even if the date never happened. And that would be so even if the prostitute were 17 'A (and despite the fact that in New York the age of consent is 17, since prostitution is a "sexual offense" in New York). Clearly, these are applications and outcomes Congress did not conte
nvince, or to try to convince, her to engage in conduct proscribed by law, the statute may not be unconstitutional on its face. See United States'. Tykarsky, 446 F.3d 458, 470 (3d Cir. 2006) (both §§ 2422(b) and 2423(6) "fall squarely Congress's power to regulate the first two categories of activities d
ate with the young prostitute, even if the date never happened. And that would be so even if the prostitute were 17'/2 (and despite the fact that in New York the age of consent is 17, since prostitution is a "sexual offense" in New York). Clearly, these are applications and outcomes Congress did not conte
he purpose of knowingly engaging in unlawful sexual activity with minors. United States Hayward, 359 F.3d 631, 638 (3d Cir. 2004); United Stales v Tykarsky, 446 F.3d 458, 471 (3d Cir. 2006). This is the highest level of culpability in the four tier hierarchy of culpability that the Model Penal Codc uses
ate with the young prostitute, even If the date never happened. And that would be so even if the prostitute were 17 /2 (and despite the fact that in New York the age of consent is 17, since prostitution is a "sexual offense" in New York). Clearly, these are applications and outcomes Congress did not conte
vince, or to try to convince, her to engage in conduct proscribed by law, the statute may not be unconstitutional on its face. See United States v. Tykarsky, 446 F.3d 458, 470 (3d Cir. 2006) (both §§ 2422(b) and 2423(b) "fall squarely within Congress's power to regulate the first two categories of activ
Entities connected to both New York and Tykarsky

Jeffrey Epstein
PERSON
United States
LOCATION
Prince Andrew
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Bill Clinton
PERSON
Julie K. Brown
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSONDarren Indyke
PERSON
New York City
LOCATION
Prince Charles
PERSON
U.S. Virgin Islands
LOCATION
Stephen Hawking
PERSON
Michael Jackson
PERSON
Eric Trump
PERSONJane Doe
PERSON