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onally governed by state regulation). real Rather, its is limited t trafficking that jgntig,0Nop or is accomplished by force, fraud, or coercion". United Stales Evans, 476 ■3d 1176, 1179 it I (I l• Ctr. 2007). Nor, has the Department of Justice deemed it appropriate. e e.g. Unit tates Department of Justic
of several men for conspiracy to hold young women in peonage, and to traffic them for commercial sex acts, involving force and threats; bail issue); United Stares v. 4 A review of the Linked Sutes Department of Justice Civil Rights Division Anti-Trafficking News Bulktins confirms that this same pattern exists
many instances, due to the lack of uniform regulation, these businesses have served to transfer funds which were the proceeds of illegal activity. See United States' Valdes, 2006 U.S. Dist. LEXIS 12432 (S.D.N.Y. 2006) (defendants transmitted proceeds of drug trafficking to Colombia); see also P.L. 103-325, Title
d to protect women agai t conduct, commercial whethv commercial or no t involves transportation and is exploitive or violent. See, e.g., De Vault I United States, 338 2d 179,180 (10th Cir. 1964) (applying the Act to protect girl who was raped). j r The Mann Act is a relatively antiquated morality statute th
d States! Hearn( 381 .3d 80 (2d Cir. 2004) (woman running prostitution business convicted for recruiting and transport of prostitutes under § 2421); United States' Footman, 215 1.3d 145 (I" Cir. 2000) (pimp who ran a prostitution ring convicted of violating § 2421). Likewise, in keeping with its purpose and tit
g that when asked by Mr. Epstein, the girls affirmatively misrepresented their ages as bein 18, and/or Mr. Ein i was not aware of their true ages. (Gonzales Statement at 39, Statement at 12, Statement at 5, Statement at 9). Indeed, although he noted that Gonzales had told Mr. Epstein she was 18, omitted from th
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 See United States' J!orschauer, 2007 WL 979931 (11th Cir. 2007) (unpublished).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
that when asked by Mr. Epstein, the girls affirmatively misrepresented their ages as bein 18, and/or Mr. Epstein was not aware of thcir true ages. (Gonzales Statement at 39, Statement at 12, Pentek Statement at 5, Statement at 9). Indeed, although he noted that Gonzales had told Mr. Epstein she was 18, omitted f
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
that when asked by Mr. Epstein, the girls affirmatively misrepresented their ages as being 18, and/or Mr. Epstein was not aware of their true ages. (Gonzales Statement at 39, Robson Statement at 12, Pentek Statement at 5, Laduke Statement at 9). Indeed, although he noted that Gonzales had told Mr. Epstein she was
Entities connected to both United States and Gonzales Statement

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSONSouthern District
LOCATION
Joe Biden
PERSON
A. Marie Villafana
PERSONRoy Black
PERSONEmmy Taylor
PERSONGerald Lefcourt
PERSON
Palm Beach Police Department
ORGANIZATION
Las Vegas
LOCATION
Jeffrey Sloman
PERSON
New York State
LOCATION
Alberto Gonzales
PERSON