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telephon·e, she declined to· d1scuss Epstein. - Nadia Marcinkova1 23, whose family in Yugoslavia Epstein paidmoneyto so that he could bring her to the United States to· be his "sex: sla.,ve;" two teenage girls· tplci police. One. gitl told :polite that Epstein instructed. Marciriko:va a:rtd het to kiss and have
ive co.uri.sel iri this matter." Marra quotedan equally pleasant note then-Pg.lrp ]?each County State Attorney 13;ircy Ifrischer sent to Assi~tc1nt U .S, Attorney Marie Viilafana:, who was the lead prosecutor in Epstein's case. "Glad We could get this worked out for feel.son~ l won't put in wrhing,
a, believing he would prosecute Epstein. He didn't. Reiter said he was heartened that 13 years later, Epstein will finally face justice. "Thankfully, U. S. Attorney Berman and the other authorities in New York have the good judgment to investigate and prosecute Epstein in the way that should have occurre
r grand jury proceedings because of the exceptional public interest in this case and the compelling circumstances supporting transparency. Carlson v. UnitedStates, 837 F.3d at 766 (“a district court has the inherent power to disclose [grand jury] materials in exceptional circumstances and . . . historic importa
d Epstein in jail four tirries in 13 days. She lists her address as on the Upper East side of Manhattan, not far from Epstein's enormous apartment. - Roger Schank, 62, founder of the Institute for Learning Sciences at Northwestern University and art expert On artificial intelligence, paid one visit to Epstein.
to make out the crime. See United States'. Root, 296 F.3d 1222, 1227-32 (j1 di Cir. 2002); United States' Sims, 428 F.3d 945, 9a9 (10th Cir. 2005); United Stalest. Helder, 452 F.3d 751 (8th Cir. 2006); United States'. Meek, 366 F.3d 705, 717-20 (9th Cir. 2004). Likewise, the Circuits have rejected void for vag
such an expansive reading, even if permissible, would very likely exceed the Commerce Clause power as the Supreme Court presently construes it. In United Statest. , 514 U.S. 549 (1995), the Supreme Court struck down the Gun- Free School Zones Act, holding that it exceeded Congress's Commerce Clause authority.
Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual
able minor and to convince, 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 ac
s diseases and cancer genetics; Martin Seligman, known for his work on Positive Psychology — that is to say the psychology of personal fulfillment; Roger Schank, a leading researcher in the application of cognitive learning theory to the curricula of formal education; the renown physicist/cosmologist Kraus
tl. Stare, 407 So. 2d 1007, 1010 (Fla. 5th DCA 1981). And "motive is always relevant in a criminal case, even if it is not an element of the crime." United Stalest. Hill, 643 F.3d 807, 843 (11th Cir. 2011) (internal quotation omitted). When speaking not to the Court but rather to the media, Dershowitz has clearl
agent's ensuing report, Rodriguez "discussed in detail the information contained within the book, and identified important information to the UCE." See United States'. Rodriguez, No. 9:10-cr- 80015-KAM, DE 3 at 5 (S.D. Fla. Dec. 9, 2009). While all of the details of the verbal information explained by Rodriguez to
Senate Judiciary Committee held a hearing regarding child endangerment via the Internet. See H.R. Conf. Rep. No. 104-458, at 193 (1996), quoted in United States ' Searcy, 418 F.3d 1193, 1197 (11th Cir. 2005); see also K. Seto, "Note: How Should Legislation Deal with Children and the Victims and Perpetrators
Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual
s diseases and cancer genetics; Martin Seligman, known for his work on Positive Psychology — that is to say the psychology of personal fulfillment; Roger Schank, a leading researcher in the application of cognitive learnin theory to the curricula of formal education; the renown physicist/cosmologist Krauss
izes travel for the 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 Pen
ternational travel, left untouched the,standard for domestic travel, and thus underscores the strict standard needed for a prosecution in this area. See United States I Clark, 435 F.3d 1100, 1104- 05 (9°' Cir. 2006). 08-80736-CV-MARRA RFP WPB 000735 EFTA00184609 Case 9:08-cv-80736-KAM Document 361-43 Entered o
thern District of Florida February 1, 2007 Page 22 Clause imposes real limitations on Congress's power to criminalize essentially local behavior. See United States' Morrison, 529 U.S. 598 (2000) (Violence Against Women Act exceeded Congressional power under the Commerce Clause or § 5 of the Fourteenth Amendment)
Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual
s diseases and cancer genetics; Martin Seligman, known for his work on Positive Psychology — that is to say the psychology of personal fulfillment; Roger Schank, a leading researcher in the application of cogniti theory to the curricula of formal education; the renown physicist/cosmologist Krauss, and man
6 artaCirtip L cs uniniun Sat g-ht•ta 4rot fortli bota. 0111- 4 4-ok hewt Subs/aad 44J - rkethot.+- CEPVAIWei uhdu-d 4 La taibanN n Cw- U. S v. euart,S) ) ;tic. F34 irn at. . 2001) rnicisitestomite Sotto-4 4rzur0.0 5 o.ed at:eiribtat4 uncto r ks _ 3Siak aveutyaret also /2.9..a_Je
n writing his belief that he was dealing with a child well below the age of onsent. E.g., lifted States' 7),Icarsky, 44613d 458, 473 (3d Cii 2006); United State' Thomas, 410 3d 1235, 1243-44 (10h Cir. 005); United States Pang supra, 338 3d at 1300-01 (11th Cir. 2003)." " There are approximately two dozen
those who ' owingly' persuade or entice, or attempt If to persuade or entice, minors. United States Bailey, 228 F.3d 637, 639 (611' Cir. 2000). See United States' Panfil, 338 I3d 1D Indeed, this last problem is best illustrated by any calls may claim to have made to solicit persons to massage Mr. Epstein. Th
Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual
s diseases and cancer genetics; Martin Seligman, known for his work on Positive Psychology — that is to say the psychology of personal fulfillment; Roger Schank, a leading researcher in the application of cognitive learnin theory to the curricula of formal education; the renown physicist/cosmologist Krauss
ve who Markus said called Muentes repeatedly and steered him toward an underage prostitute. CI) Holy Cross p Hos ital 2" Year in a row <J4, ‘s, AMERICAS 50 BEST HOSPITALS But prosecutors insisted Muentes made the choice to request a teenager without encouragement and took concrete steps toward act
sraelis bag past when Arab fighters would see the advancing Israeli army, dis- card their boots and flee in terror. The strategy of Israel's (and Americab) enemies today is to lure the military superpower into a pro- tracted conflict 'lb accept the bait, as the Israelis did in assaulting Leb- anon and
hattan home address. ached by telephone, she dieclii~pstein. ■ 23, whose fam- ily in ugos via ps in paid money to so that he could bring her to the United States to be his "sex slave," two teenage - tikrthlkat. -LE S-Cirtunk- I cloy -Sivt Is Icovk -1 351N feillo -1 • • • girls told police. One gir th
tein urging. Epstein in jail four days. She lists her address as on the Upper East side of Manhattan, not far from Epstein enormous apartment ■ Roger Schank, 62. founder of the Institute for Learning Sciences at Northwestern University and an expert on artificial intelligence, paid one visit to Epstei
ies to those who `knowingly' persuade or entice, or attempt to persuade or entice minors. United States' Bailey, 228 F.3d 637, 639 (6th Cir. 2000). See United States' Panfil, 338 F.3d 1° indeed, this last problem is best illustrated by any calls Haley Robson may claim to have made to solicit persons to massage Mr
Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual
s diseases and cancer genetics; Martin Seligman, known for his work on Positive Psychology — that is to say the psychology of personal fulfillment; Roger Schank, a leading researcher in the application of cognitive lear a tin theory to the curricula of formal education; the renown physicist/cosmologist Kra
elephone, she declined to discusstpstein. ■ Nadia Marcinkova, 23, whose fam- ily in Yugoslavia Epstein paid money to so that he could bring her to the United States to be his "sex slave," two teenage girls told police. One girl told police that Epstein instructed Marcinkova and her to kiss and have sex while h
Epstein in jail four times in 13 days. She lists her address as on the Upper East side of Manhattan, not far from Epstein's enormous apartment. ■ Roger Schank, 62, founder of the Institute for Learning Sciences at Northwestern University and an expert on artificial intelligence, paid one visit to'Epstei
Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual
s diseases and cancer genetics; Martin Seligman, known for his work on Positive Psychology — that is to say the psychology of personal fulfillment; Roger Schank, a leading researcher in the application of cognitive learning theory to the curricula of formal education; the renown physicist/cosmologist Lawren
Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual
s diseases and cancer genetics; Martin Seligman, known for his work on Positive Psychology — that is to say the psychology of personal fulfillment; Roger Schank, a leading researcher in the application of cognitive learning theory to the curricula of formal education; the renown physicist/cosmologist Lawren
Entities connected to both United States and Roger Schank

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Phoenix
LOCATION
Ghislaine Maxwell
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
John F. Kennedy
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Alexander Acosta
PERSONJane Doe
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Kenneth Marra
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Bradley Edwards
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Prince Charles
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Marc Rich
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New York
LOCATION
Donald Trump
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Bill Clinton
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Scarlett Johansson
PERSONJack Goldberger
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