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

of New York for in excess of half of each year, visiting his mother and brother, meeting with business associates, and negotiating the purchase of the Gosman Estate — Epstein made 65 separate trips to Florida in 2004 and 20058. There trips are reflected on the flight records previously provided to you. We are not reproduc

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

of New York for in excess of half of each year, visiting his mother and brother, meeting with business associates, and negotiating the purchase of the Gosman Estate — Epstein made 65 separate trips to Florida in 2004 and 20058. There trips are reflected on the flight records previously provided to you. We are not reproduc

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

of New York for in excess of half of each year, visiting his mother and brother, meeting with business associates, and negotiating the purchase of the Gosman Estate — Epstein made 65 separate trips to Florida in 2004 and 20058. $ There trips are reflected on the flight records previously provided to you. We are not reprod