3
Shared Docs
3
Same-Page
8 / 3
Mentions
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
rence that she did not need to call anyone else back, . . . he got me the job! Just like that . . . I lied and said he was the old stock manager at Holister — she bought it.. ." This information and 16 A copy is annexed at Tab 8. 08-80736-CV-MARRA RFP WPB 000746 EFTA00184620 Case 9:08-cv-80736-KAM D
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
ference that she did not need to call anyone else back.. . . he got me the job! Just like that . .. I lied and said he was the old stock manager at Holister she bought it. . ." This inthrmation and supporting documentation was provided by the defense to the PRPD, hut was not included in the Police Repor
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
reference that she did not need to call anyone else back, ... he got me the job! Just like that ... I lied and said he was the old stock manager at Holister — she bought it..." This information and 16 A copy is annexed at Tab 8. EFTA00176252 LAW OFF ICES OF GERALD B. LE:poop-fa, P.C. C C ( C. i E
Entities connected to both United States and Holister

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSON
Joe Biden
PERSON
Jay Lefkowitz
PERSON
A. Marie Villafana
PERSONRoy Black
PERSON
Alfredo Rodriguez
PERSONGerald Lefcourt
PERSON
Barry Diller
PERSON
Palm Beach Police Department
ORGANIZATIONAnn Sanchez
PERSON
Chris Tucker
PERSON
Cleveland
LOCATION