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or intimidation. These are the elements required by the statute, and they are not met here. Although CEOS could, perhaps, point to United States v. Evans, 476 F.3d 1176 (11th Cir. 2007) as a case that, standing alone, involved wholly intrastate conduct, the facts of that case are far different in key
here. In fact, the United States Supreme Court prohibited the criminalization of travel under identical circumstances over a half century ago. Sis, Mortenson v. United States 322 U.S. 369, 374 (1944) (intention to engage in proscribed conduct must "exist before the conclusion of the interstate journey an
or intimidation. These arc the elements required by the statute, and they are not met here. Although CEOS could, perhaps, point to United Slat% v. Evans, 476 F.3d 1176 (11°' Cir. 2007) as a case that, standing alone, involved wholly intrastate conduct, the facts of that case are far different in key
here. In fact, the United States Supreme Court prohibited the criminalization of travel under identical circumstances over a half century ago. Sce, Mortenson v. United Stalo, 322 U.S. 369,374 (1944) (intention to engage in proscribed conduct must "exist before the conclusion of the interstate journey and
here. In fact, the United States Supreme Court prohibited the criminalization of travel under identical circumstances over a half century ago. Sis, Mortenson v. United States 322 U.S. 369, 374 (1944) (intention to engage in proscribed conduct must "exist before the conclusion of the interstate journey an
Page: EFTA00013796 →or intimidation. These are the elements required by the statute, and they are not met here. Although CEOS could, perhaps, point to United States v. Evans, 476 F.3d 1176 (11th Cir. 2007) as a case that, standing alone, involved wholly intrastate conduct, the facts of that case are far different in key
Page: EFTA00013797 →co-conspirators. None of this type of activity comes close to the facts regarding Mr. Epstein. Finally, but significantly, the prostitution ring in Evans was not, in fact, entirely intrastate as the companion case of one of the Evans co-defendants makes clear. See, United States v. Madison, 477 F.3d 1
Page: EFTA00013797 →Entities connected to both Evans and Mortenson

Jeffrey Epstein
PERSON
United States
LOCATION
George W. Bush
PERSON
Virginia Giuffre
PERSON
Alexander Acosta
PERSONJane Doe
PERSONthe Southern District
LOCATION
Atlanta
LOCATION
Mike Pence
PERSON
Bailey
PERSONMurrell
PERSON
Woody Allen
PERSON
Jay Lefkowitz
PERSON
Southern District of New York
ORGANIZATIONBerger
PERSONThe Eleventh Circuit's
ORGANIZATIONMySpace
ORGANIZATION
Palm Beach
LOCATIONPuche
PERSON
United States Department of Justice
ORGANIZATION