Epstein Secrets

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

anyone relying on the Police Report or Probable Cause Affidavit would have a skewed view of the facts material to this matter. Examples follow. 1. The Video Surveillance Equipment Located in Epstein's Office and Garage. Both the Police Report (at 43) and the Probable Cause Affidavit (at 18) make particular mention of the "discovery"

this procedure because. as I mentIona I think It to probably in their best WOWS. In terms of plea agreement language. let me suggest the following: Thu United Slates agrees to make a minion seeking the appointment of a Guardian ad titan to mpresent the identified victims, Following the appointment of such Guardia

mber I I, 2007 Page 4 The final agreement was very similar to what was proposed by Ms. Villotbna in her initial draft agreement on July 31. 2007: The United Stoles shall provide l3poein's anomey's with u list of individuals whom ii fins identified as victims, as defined in IR U.S.C. § 2255. alter Epstein has si

hich point they were eliminated by your Office: IT APPEARING, idler an invizligation of the offenses and Epstcin's background, thin the interest or the United Stales pursuant to the Petite policy will be served by the Following procedure ... Epstein understands that the United Stales Attorney has no authority to

evidence. Thus, the Police Report and Probable Cause Affidavit only affix a skewed view of the facts material to this matter. Examples follow. 1. The Video Surveillance Equipment Located in Mr. Epstein's Office and Garage. Both the Police Report (at 43) and the Probable Cause Affidavit (at I make EFTA00176119 12/11/2007 11:39 FAX

to undcdakc discussion with the Slate Attomey's Office Ia custom caswpiiiiitim with these procedures. which compliance will be necessary to satisfy the United States' intero.t, pursuant to the Petite policy. We reiterate that this case was at heart a local mutter that was being billy addressed by the state crimi

ugh such misconduct was, as we contend it is, inextricably intertwined with the credibility of the accusations being made against Mr. Epstein by the United States Attorney's Office in Miami (''USAO"). Moreover. CEOS did not assess the terms of the Deferred Prosecution Agreement now in effect, nor did CEOS revi

t evidence. Thus. the Police Report and Pmbahle Cause Affidavit only affix a skewed view of the facts material to this matter. examples follow. 1. The Video Surveillance Equipment Located in Mr. Enteln's Office and G'arame. Ruth the Police Report (at 43) and the Probable Cause Affidavit (at IS) make RFP MIA 000449 EFTA00208930 12/

S L LP Jay P I otternWs, P C. loP 11Wr r ly blk Orland can VIA FACSIMILE (303) SM1-4444 Honorable R. Alexander Acosta united States Attorney United Slates Attorney's ()filet Southern District of Florida 99 NE itlh Street Miami. Fla 33132 Dear Alex: nap MIn IARD 'Armen-. Cinarmap Conte, 153 Emit

to undertake discussion with the Slate Attorney's 011ie,: to ensure compliance with these procedures. which compliance will he necessary to satisfy the United Status' interest. pursuant In the Poise policy. We reiterate that this ease was at heart a local matter that was being fully addressed by the state crimin

evidence. 1 has, the Police RCM* and Probable Cause Affidavit only oiler a skewed view of tlx: facts material to this matter. Examples follow. I. The Video Surveillance Equipment Located in Mr. Epstein!r Office and Garage. Ruth the Police Report (at 43) and the Probable Cause Affidavit (at 18) make EFTA00214298 12/11/2007 11:39 FA

ly desires that result, whatever the likelihood of that result happening from his conduct." United Stalest Bailey, 444 U.S. 394, 404 (1980), quoting United States' United States Gypsum Co., 438 U.S. 422, 445 (1978).7 The Supreme Court has repeatedly interpreted this language to require that the illegal activity

to which the legislation is addressed. After all, it is a first principle that the Constitution creates a federal government of enumerated powers. See United States v.= 514 U.S. 549, 552 (1995) ("Just as the separation and independence of the coordinate branches of the Federal Government serve to prevent the a

anyone relying on the Police Report or Probable Cause Affidavit would have a skewed view of the facts material to this matter. Examples follow. 1. The Video Surveillance Equipment Located in Epstein 'c Office and Garage. Both the Police Report (at 43) and the Probable Cause Affidavit (at 18) make particular mention of the "discovery"