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

6 Entered on FLSD Docket 02/10/2016 Page 9 of 24 LAW OFPIcES OF GERALD B. LEFCOURT. BC. Jeffrey Matthew Esq. Andrew !Anne Es . Escl• e nite tates Attorney's Office Southern District of Florida July 6, 2007 Page 8 the mail, phone, etc., would be an unnatural and grammatically inaccurate reading of the

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

RENATO C. STABILE FAITH A. FRIEDMAN BY FEDERAL EXPRESS July 6, 2007 Esq., First Assistant United States Attorney Esq., Chief, Criminal Division tates Attorney's Office Southern District of Florida 99 NE 4u' Street Miami, Florida 33132 De uty Chief, Northern Region Assistant United States Attorney e nit

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

the exercise of sentencing discretion, allowing the punishment to fit both the crime and the EFTA00284178 LAW orfKC• OF GERALD B. LEECOURT. PC tates Attorney's Office Southern District of Florida July 6, 2007 Page 5 perpetrator. Section 2422(b), with its ten-year mandatory minimum is far too blunt a tool