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

long as such a reading is not plainly contrary to the .• intent of Con ess. United States X-Citement Video, Inc., 513 U.S. 64, 78 (1994), citing . DeBartolo Corp. Florida Gulf Coast Building & Constr. Thades Council, 485 U.S. 568 (1988). At c least, to eliminate questions as to its constitutionality, §2422(b)

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n writing his belief that he was dealing with a child well below the age of onsent. E.g., lifted States' 7),Icarsky, 44613d 458, 473 (3d Cii 2006); United State' Thomas, 410 3d 1235, 1243-44 (10h Cir. 005); United States Pang supra, 338 3d at 1300-01 (11th Cir. 2003)." " There are approximately two dozen

those who ' owingly' persuade or entice, or attempt If to persuade or entice, minors. United States Bailey, 228 F.3d 637, 639 (611' Cir. 2000). See United States' Panfil, 338 I3d 1D Indeed, this last problem is best illustrated by any calls may claim to have made to solicit persons to massage Mr. Epstein. Th

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

as such a reading is not plainly contrary to the intent of Congress United States X-Citement Video, Inc., 513 U.S. 64, 78 (1994), citing Edward." DeBartolo Corp. Florida GulfCoast Building & Constr. Trades Council, 485 U.S. 568 (1988). At e least, to eliminate questions as to its constitutionality, §2422(b)

ator Feinstein)(explaining that the right to confer was "intended to be expansive," applying to "any critical state or disposition of the case") and United States v. Heaton, 458 F. Supp. 2d 1272 (D. Utah 2006)(government motion to dismiss charge of using facility of interstate commerce to entice minors to enga

ted States of America. (Lee, Dexter) (Entered: 01/26/2012) 01/26/2012 .1.44 RESPONSE in Opposition re_12$ Motion for Miscellaneous Relief filed by United States of America. (Sanchez, Eduardo) (Entered: 01/26/2012) 01/27/2012 145 ENDOR ingitl Motion for Leave to File Excess Pages. Signed by Judge on 1/27/2012. (ir)

Congress . . . The elementary rule is that every reasonable construction must be resorted to, in order to save a statute from unconstitutionality." DeBartolo Corp. v. Florida Gulf Coast Trades Council, 485 U.S. 568, 575 (1988). B. Recognition of a Privilege Under Rule 501. The Court rejected intervenors' cont