Epstein Secrets

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

holarship program. The SRF provides support and safe haven to scholars at risk from around the world. Over the past EFTA00176528 LAW orrice. OF GERALD B. LEPDOURT. P.C. Jeffrey Sloman, Esq. Matthew Menchel, Esq. Andrew Lourie, Esq. A. Marie Villafatia, Esq. The United States Attorney's Office Sou

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

736-CV-MARRA RFP WPB 000749 EFTA00184623 Case 9:08-cv-80736-KAM Document 361-43 Entered on FLSD Docket 02/10/2016 Page 22 of 26 LAW OFFICES or GERALD B. ince -ant, P.C. A , Esq., Assistant United States Attorney Andrew Lourie, Esq., Deputy Chief, Northern Region Office of the United States Attorne

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

nternational travel, left untouched thestandard for domestic travel, and thus underscores the strict standard needed for a prosecution in this area. See United States v. Clark, 435 F.3d 1100, 1104- 05 (9th Cir. 2006). EFTA01728473 LAW OF !ICC S OP Gip B. LEPCOURT, P.G. PEW ., Assistant United States Attorney

ir. 2006). EFTA01728473 LAW OF !ICC S OP Gip B. LEPCOURT, P.G. PEW ., Assistant United States Attorney .,Deputy Chief, Northern Region ice of the Unite States Attorney Southern District of Florida February 1, 2007 Page 7 by his need to be outside of New York for tax reasons. That was the principal purpo

• LAW OFFICES OF GEZRALD B. LErcouar, A PROFESSIONAL CORPORATION raw YORE, NEW YORK 10021 GERALD B. LEFC0URT BY HAND February 1, 2007 ., Assistant United States Attorney puty Chief, Northern Region ice o t e rr mte tates Attorney Southern Dis

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

all the issues we have raised herein or any other lingering concerns you have. Case No. 08-80736-CV-MARRA P-013322 EFTA00230227 LAW CONCIES Or GERALD B. IncounT, P.C. A. Esq. O ce o the United States Attorney Southern District of Florida June 25, 2007 Page 19 Thank you for your cooperation in t

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

Adam Walsh Child Protection and Safety Act of 2006, which also eliminated any statute of limitations. See 18 U.S.C. EFTA00284176 LAW Ortioto or GERALD B. LEFCOTJEtT. PC. The United States Attorney's Office Southern District of Florida July 6, 2007 Page 3 §3299.2 The law was named in memory of Adam