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inappropriate. The money laundering statute was designed to be used and has been construed as a "concealment" statute, not a spending statute. See United Stales v. Shepard, 396 F.3d 1116 (10th Cir.), cert. denied, 545 U.S. 1110 (2005); United States v. Hall, 434 F.3d 42 (1st Cir. 2006) (money laundering sta
d terrorism. The type of business contemplated by Congress is one which, for a fee, accepts funds for transfer within or outside the United States. See United States v. Talebnejad 460 F.3d 563, 565 (4th Cir. 2006); United States v. Velastegui, 199 F.3d 590 (2d Cir. 1999). Once the money transmitter receives the
tes v. Holland, 381 F.3d 80 (2d Cir. 2004) (woman running prostitution business convicted for recruiting and transport of prostitutes under § 2421); United States v. Footman, 215 F.3d 145 (1s1 Cir. 2000) (pimp who ran a prostitution ring convicted of violating § 2421). Likewise, in keeping with its purpose and
prostituting underage persons, either by force, fraud, or coercion. These cases bear no relationshijo to the circumstance at issue here. See, e.g., United Slates v. Norris, 188 Fed. Appx. 822 (11 Cir. 2006) (unpublished)(prosecution of several men for conspiracy to hold young women in peonage, and to traffi
ecause it authorized agents to seize everything, even if unrelated to the offense under investigation and even if wholly personal); United States v. Clough, 246 F.Supp.2d 84, 87-88 (D.Me. 2003)(warrant to search computers which contained no limitations on the search was unconstitutionally overbroad); U
first enacted by Congress in 1910 to prevent the use of interstate commerce to facilitate prostitution, concubinage, or other forms of immorality. Hoke I United States, 227 U.S. 308 (1913); Wilson I United States, 232 U.S. 563 (1914); Caminetti I United States, 242 U.S. 470 (1917). The statute's primary purpose was
illicit sexual conduct was an "important" "purpose of the travel, a significant motivating factor", or in other words, more than merely incidental. See United States' J!orschauer, 2007 WL 979931 (11th Cir. 2007) (unpublished). We understand from conversations with Ms. Villafaiia that she believes that Mr. Epstein
because it authorized agents to seize everything, even if unrelated to the offense under investigation and even if wholly personal); United States. Clough; 246 F.Supp.2d 84, 87-88 (D.Me. 2003)(warrant to search computers which contained no limitations on the search was unconstitutionally overbroad); U
d terrorism. The type of business contemplated by Congress is one which, for a fee, accepts funds for transfer within or outside the United States. See United States v. Talebnejad, 460 F.3d 563, 565 (4th Cir. 2006); United States v. Velastegui, 199 F.3d 590 (2d Cir. 1999). Once the money transmitter receives the
tes v. Holland, 381 F.3d 80 (2d Cir. 2004) (woman running prostitution business convicted for recruiting and transport of prostitutes under § 2421); United States v. Footman, 215 F.3d 145 (Ig Cir. 2000) (pimp who ran a prostitution ring convicted of violating § 2421). Likewise, in keeping with its purpose and
ecause it authorized agents to seize everything, even if unrelated to the offense under investigation and even if wholly personal); United States v. Clough; 246 F.Supp.2d 84, 87-88 (D.Me. 2003)(warrant to search computers which contained no limitations on the search was unconstitutionally overbroad); U
y had been in his home and/or belonged to him, which would, in turn, at a minimum, implicitly authenticate the contents of the materials. See, e.g., United States v. Stewart, 2003 WL 23024461 at *3 (S.D.N.Y. December 29, 2003) (act of production privileged where government's claimed relevance for requiring the
n in effect until you arc granted leave to depart by the court or by an officer acting • ni behalf of the court. poem) is issued upon application 'Med States of America DATE: March 2, 2007 Name, Address and Phone Number of Assistant U.S. Attorney ssistant U.S. Attorney 500 So. Australian Avenue, Suite 400 West
se "what the government seeks is a license to roam through everything_ in the computer without limitation and without standards"); United States v. Clough, 246 F.Supp.2d 84, 87-88 (D. Me. 2003) (warrant to search computers which contained no limitations on the search and no references to statutes, cri
d terrorism. The type of business contemplated by Congress is one which, for a fee, accepts funds for transfer within or outside the United States. See United States v. Talebnejad, 460 F.3d 563, 565 (4th Cir. 2006); United States v. Velastegui, 199 F.3d 590 (2d Cir. 1999). Once the money transmitter receives the
ates v. Holland 381 F.3d 80 (2d Cir. 2004) (woman running prostitution business convicted for recruiting and transport of prostitutes under § 2421); United States v. Footman, 215 F.3d 145 (1th Cir. 2000) (pimp who ran a prostitution ring convicted of violating § 2421). Likewise, in keeping with its purpose and
because it authorized agents to seize everything even if unrelated to the offense under investigation and even if wholly personal); United States'. Clough, 246 F.Supp.2d 84, 87-88 (D.Me. 2003Xwarrant to search computers which contained no limitations on the search was unconstitutionally overbroad); Un
y had been in his home and/or belonged to him, which would, in turn, at a minimum, implicitly authenticate the contents of the materials. See, e.g., United States v. Stewart, 2003 WL 23024461 at *3 (S.D.N.Y. December 29, 2003) (act of production privileged where government's claimed relevance for requiring the
use "what the government seeks is a license to roam through everything- n the computer without limitation and without standards"); United States v. Clough, 246 F.Supp.2d 84, 87-88 (D. Me. 2003) (warrant to search computers which contained no limitations on the search and no references to statutes, cri
Entities connected to both United States and Clough

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONLeon Black
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSONMaria Farmer
PERSONSouthern District
LOCATION
Joe Biden
PERSON
A. Marie Villafana
PERSON
Martha Stewart
PERSONRoy Black
PERSON
Supreme Court
ORGANIZATIONEmmy Taylor
PERSONGerald Lefcourt
PERSON
Palm Beach Police Department
ORGANIZATION
Las Vegas
LOCATION