Epstein Secrets

ction 2422(b) expressly requires that the crime be committed "knowingly," and that requisite mental element applies as to each element of the crime. United Slates v, XCitement Video, Inc., 513 U.S. 64, 68.69 (1994); United States v. Meek, 366 F.3d 705, 718 (9lh Cir. 2004); United States v. Root, 296 F.3d 1222,

imited to sex trafficking that involves children or is accomplished by force, fraud, or coercion." United States v. Evans 476 F.3d at 1179 n. 1. Sec aho United States v, Sims, 171 Fed. 3505-019 Page 19 of 63 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003291 EFTA00157673 ALLEN GUTHR

a result of the federal investigation], or acquittal on the merits shall be a bar to any subsequent federal prosecution for the same act or acts." U.S.A.M. § 9-2.031A (emphasis added). Consistent with that principle, and of particular relevance to this case, the Department itself just recently observed

ically underscore these principles and help to highlight why federal prosecution in this case would be improper as a matter of both law and policy. See United States v. Santos, No. 06-1005 (June 2, 2008); Cuellar v. United States, No. 06-1456 (June 2, 2008). Though they both address the interpretation and applica

tein had an actual practice of attempting to verify age, and would not let them in his house if they were under the age of 18. See United States v. Kennard, 472 F.3d 851, 857-858 (1 3'Cir. 2006), quoting, United States v Puche, 350 F.3d t 137, 1149 (11th Cir. 2003) (An instruction on deliberate ignoranc

o lie because Mr. Epstein had an actual practice of attempting to verify age, and would not let them in his house if they were under the age of 18. ss& United States v. Kennard, 472 F.3d 851, 857-858 (11th Cir. 2006), quoting, United States v. Puche 350 F.3d 1137, 1149 (111° Cir. 2003) (An instruction on delibera

ction 2422(b) expressly requires that the crime be committed "knowingly," and that requisite mental element applies as to each element of the crime. United States v. XCitement Video. Inc., 513 U.S. 64, 68-69 (1994); United States v. Meek, 366 F.3d 705, 718 (9th Cir. 2004); United States v. Root, 296 F.3d 1222,

tein had an actual practice of attempting to verify age, and would not let them in his house if they were under the age of 18. ss& United States v. Kennard, 472 F.3d 851, 857-858 (11th Cir. 2006), quoting, United States v. Puche 350 F.3d 1137, 1149 (111° Cir. 2003) (An instruction on deliberate ignoranc

e fnanad neutron and performance of the Company on a comtmed basis througnol those periods in accordance with accounting pnnciples generagy accepted n the United States of Amenca Management of KapteiwielOassiefcritein Wind Energy Facility (RF) Proprietary Lmited Severeacnes 159 (RF) Proprietary Limited and Limarco 7

eneration at re 27MW Klicheinsel-DaSSielOnlein Vend Energy Faolity near Caleden in the Western Cape, South Afnca a 10MW Solar Pit Energy racily rear Kennard, in the Northern Cape. South Afnca and a 10MW Korikocraies Solar PV Energy Facility near Potadier n to Northern Cape. South Alma The Company has a c

iminal statutes, including those enacted to protect important federal interests. In cases involving the federalization of activity that is within the States’ historic police power, Congress must speak with particular clarity. See, e.g., Will v. Michigan Dep’t of State Police, 491 U.S. 58, 65 (1989). 12

tter points out (CEOS letter at p. 3), I was a member of CEOS. In fact, I served as a federal prosecutor for twelve years; five years as an Assistant United States Attorney for the Southern District of West Virginia, and seven years at CEOS. I began working as a trial attorney for CEOS in 1999, and was pr

pstein had an actual practice of attempting to verify age, and would not let them in his house if they were under the age of 18. See United States v. Kennard, 472 F.3d 851, 857-858 (11" Cir. 2006), quoting, United States v. Puche, 350 F.3d 1137, 1149 (11™ Cir. 2003) (An instruction on deliberate ignorance