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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
he Palm Beach area. Beginning in 2003 and continuing through most of 2004, Epstein also traveled frequently to Florida to negotiate the purchase of the Abraham Gosman Estate, which was finally sold at auction in November 2004. Although, Epstein was ultimately outbid, nearly a dozen trips to Florida were made in direct p
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
he Palm Beach area. Beginning in 2003 and continuing through most of 2004, Epstein also traveled frequently to Florida to negotiate the purchase of the Abraham Gosman Estate, which was finally sold at auction in November 2004. Although, Epstein was ultimately outbid, nearly a dozen trips to Florida were made in direct p
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
he Palm Beach area. Beginning in 2003 and continuing through most of 2004, Epstein also traveled frequently to Florida to negotiate the purchase of the Abraham Gosman Estate, which was finally sold at auction in November 2004. Although, Epstein was ultimately outbid, nearly a dozen trips to Florida were made in direct p
Entities connected to both United States and the Abraham Gosman Estate

Jeffrey Epstein
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSONSouthern District
LOCATION
Stephen Hawking
PERSONRoy Black
PERSON
Alfredo Rodriguez
PERSONGerald Lefcourt
PERSON
Barry Diller
PERSON
Palm Beach Police Department
ORGANIZATIONAnn Sanchez
PERSON
Chris Tucker
PERSON
Cleveland
LOCATION
West Palm
LOCATION
Barry Krischer
PERSON
Bailey
PERSONMorrison
PERSONMySpace
ORGANIZATION