EFTA00176507

LAW orrecc• or 
GERALD B. LEFCOURT, P.C. 
Jeffrey Sloman, Esq. 
Matthew Menchel, Esq. 
Andrew Lourie, Esq. 
A. Marie Villafafia, Esq. 
The United States Attorney's Office 
Southern District of Florida 
July 6, 2007 
Page 20 
monthly with a teenage building workman whose expenses of vocational 
school are being paid by Mr. Epstein. Each month, Mr. Epstein reviews 
the workman's school progress and discusses career opportunities. One of 
the monthly reports is annexed at Tab "D". 
• 
In addition, Mr. Epstein blocks out time each week to meet with young 
professionals to discuss their career prospects and counsel them regarding 
appropriate next steps. 
Although Mr. Epstein is deeply committed to helping others in very personal and 
meaningful ways, he has also sought to use his good fortune to help others on a broader 
basis. Mr. Epstein has sponsored more than 70 athlete wellness programs, building 
projects, scholarship funds and community interest programs in the United States Virgin 
Islands alone. 
Moreover, Mr. Epstein has given generously to support philanthropic 
organizations across the United States and around the world, including America's 
Agenda; Robin Hood; Alliance for Lupus Research; Ovarian Cancer Research Fund; 
Friends of Israel Defense Forces; Seeds of Peace; the Jewish National Fund; the Hillel 
Foundation; the National Council of Jewish Women; and the Intrepid Fallen Heroes Fund 
— to name only a few. 
In a feature article about Mr. Epstein in New York Magazine, former President 
Clinton aptly described Mr. Epstein as "a committed philanthropist with a keen sense of 
global markets and an in-depth knowledge of twenty-first-century science." President 
Clinton reached this conclusion during a month-long trip to Africa with Mr. Epstein, 
which Mr. Epstein hosted. The purpose of that trip was to increase AIDS awareness; to 
work towards a solution to the AIDS crisis; and to provide funding to reduce the costs of 
delivering medications to those inflicted with the disease. 
Both before and after that trip to Africa, Mr. Epstein worked hard to achieve 
improvements in people's lives on a global basis. He actively sought advancement of his 
philanthropic goals through his participation and generous support of both the Trilateral 
Commission and the Council on Foreign Relations. As you may know, the Trilateral 
Commission was formed to foster closer cooperation among core democratic 
industrialized areas of the world in the pursuit of goals beneficial to the global 
population. The Council on Foreign Relations is an independent, national membership 
organization and a nonpartisan center for scholars dedicated to increase international 
understanding of world issues and the foreign policy decisions that affect those issues. 
EFTA00176527

LAW omen 
or 
GERALD B. LEFCOURT. PC 
Jeffrey Sloman, Esq. 
Matthew Menchel, Esq. 
Andrew Lourie, Esq. 
A. Marie Villafitfia, Esq. 
The United States Attorney's Office 
Southern District of Florida 
July 6, 2007 
Page 21 
Mr. Epstein was part of the original group that conceived the Clinton Global 
Initiative, which is described as a project "bringing together a community of global 
leaders to devise and implement innovative solutions to some of the world's most 
pressing challenges." Focuses of this initiative include poverty, climate change, global 
health, and religious and ethnic conflicts. 
Mr. Epstein has sought to improve people's lives through active participation in 
worthy scientific and academic research projects, as well. He spent hundreds of hours 
researching the world's best scientists, and he himself studied as a Harvard Fellow in 
order to increase his own knowledge in fields that he believed could provide solutions to 
the world's most difficult problems. He is committed to helping the right researchers find 
those solutions, especially in the fields of medical science, human behavior and the 
environment. 
In the past four years alone, Mr. Epstein has made grants to research programs at 
major institutions under the supervision of some of the most highly regarded research 
professionals and scholars in their fields, including Martin Nowak, a mathematical 
biologist who studies, among other things, the dynamics of infectious diseases and cancer 
genetics; Martin Seligman, known for his work on Positive Psychology — that is to say 
the psychology of personal fulfillment; Roger Schank, a leading researcher in the 
application of cognitive learning theory to the curricula of formal education; the renown 
physicist/cosmologist 
Krauss, and many others. Institutions funded include 
Harvard University; Penn State University; Lenox Hill Hospital (New York); the 
Biomedical Research and Education Foundation; the Santa Fe Institute; Massachusetts 
Institute of Technology; Case Western Reserve University; and Harvard Medical School's 
Institute for Music and Brain Science. 
Moreover, Mr. Epstein has sponsored and chaired symposia that have provided a 
rare opportunity for the world's leading scholars and research professionals to share ideas 
across interdisciplinary lines. These leaders gather to discuss important and complex 
topics, including the origin of life, systems for understanding human behavior, and 
personal genomics. 
In order to expand the pool of qualified research professionals actively engaged in 
addressing the world's numerous problems, Mr. Epstein co-founded, and served as a 
trustee and actively participated in the selection committee of, the Scholar Rescue Fund. 
The Scholar Rescue Fund (SRF) is a program of the Institute of International Education, 
the group that, inter alia, administers the Fulbright Scholarship program. The SRF 
provides support and safe haven to scholars at risk from around the world. Over the past 
EFTA00176528

LAW orrice. 
OF 
GERALD B. LEPDOURT. P.C. 
Jeffrey Sloman, Esq. 
Matthew Menchel, Esq. 
Andrew Lourie, Esq. 
A. Marie Villafatia, Esq. 
The United States Attorney's Office 
Southern District of Florida 
July 6, 2007 
Page 22 
five years, SRF has made 155 grants to scholars from more than 37 countries. Scholars 
are placed at host universities in a safe country. More than 87 institutions around the 
world have hosted SRF scholars to date, including eight of the top ten universities in the 
United States. Most recently, SRF launched the Iraq Scholar Rescue Project to save 
scholars in Iraq, many of whom have been particularly targeted for kidnapping and death 
since the conflict there began. Mr. Epstein is a highly valued member of the selection 
committee. Just a few articles mentioning these and other projects are annexed at Tab 
I 
Even a casual review of the good works large and small in which he has involved 
himself leads one to conclude that he has a powerful instinct to help others. He does this 
not simply because he can, but because he has a deeply ingrained desire to do so. In fact, 
he believes that, as a result of his good fortune, he is obligated to do so. 
Since 2000, Mr. Epstein has funded educational assistance, science and research 
and community and civic activities. As you can see, his philanthropy is not limited to 
financial support. To the contrary, it has involved the dedication of a remarkable amount 
of his time and effort and has yielded admirable results. It is noteworthy that a majority 
of the people he has helped over the years have been those with whom he has had little or 
no contact, which further confirms that he derives no personal benefit from his good 
works, other than the personal satisfaction derived from using his good fortune to help 
others. 
The sincere devotion to others evidenced by Mr. Epstein's philanthropic activities 
is no less apparent in his interpersonal relationships. Mr. Epstein has maintained both 
long term significant, intimate as well as professional relationships. He remains close 
personal friends with people with whom he went to high school and, to this day, 
maintains close business contacts with his former colleagues at Bear Stearns. Those who 
know Mr. Epstein well describe him admittedly as quirky but certainly not immoral; and 
overall as kind, generous and warm-hearted. They have remained staunch supporters 
despite the lurid media attention during this two-year investigation. 
Mr. Epstein acknowledges that the activities under investigation, as well as the 
investigation itself, have had and continue to have an unfortunate impact on many people. 
With a profound sense of regret, Mr. Epstein hopes to end any further embarrassment to 
all who are and who may become involved in this serious matter. Resolution of the 
outstanding charges in the state would put an appropriate end to the matter for everyone. 
EFTA00176529

LAW orrias or 
GERALD B. LEFCOURT. P.C. 
Jeffrey Sloman, Esq. 
Matthew Menchel, Esq. 
Andrew Lourie, Esq. 
A. Marie VillafaiIa, Esq. 
The United States Attorney's Office 
Southern District of Florida 
July 6, 2007 
Page 23 
Again, we and our colleagues thank you for your attention at the June 26 meeting. 
I welcome any questions or comments you may have and am available to discuss this and 
any other issues at your earliest convenience. 
Very truly yours, 
Goud? 
Gerald B. Lefcourt 
cati
a
.O i b m
Alan Dershowitz 
cc: Lilly Ann Sanchez, Esq. 
Roy Black, Esq. 
EFTA00176530

• 
C.) 
c 
EFTA00176531

STEVEN PINKER 
Johnstone Family Professor 
DEPARTMENT OF PSYCHOLOGY 
HARVARD UNIVERSITY 
Professor Alan Dershowitz 
Harvard Law School 
Harvard University 
Cambridge, MA 02138 
June 28, 2007 
Dear Alan, 
I'm happy to offer the help of my knowledge in linguistics to determine the natural 
interpretation of a statute you have inquired about. My comments refer to how a literate English 
speaker would interpret the statute, based on research on the syntax and semantics of verbs. I 
consider myself an expert on this topic, having written about it in many scholarly articles and in 
three books: Learnability and Cognition (MIT Press, 1989), Lexical and Conceptual Semantics 
(coedited with Beth Levin; Blackwell, 1992), and The Stuff of Thought: Language as a Window 
into Human Nature (Viking, 2007). 
The statute at issue is as follows: 
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 activity for which 
any person can be charged with a criminal offense, or attempts to 
do so, shall be fined under this title and imprisoned not less than 
ten years or for life. 
Your question, as I understand it, pertains to the temporal and causal relationship 
between the person's use of the mail (or other interstate/foreign instrument) and his knowingly 
persuading (inducing, cnticing, etc.) the minor. Simplifying the various disjuncts and subordinate 
clauses so that we may concentrate on the semantics, the relevant part of the statute is effectively 
this: 
Whoever, using the mail etc., knowingly persuades a minor to 
engage in a criminal sexual activity, shall be fined and imprisoned. 
So the question is: does this statute apply (1) to someone who uses the mail (or Internet or 
phone) and subsequently persuades a minor, in person, to engage in sex, or does it apply only to 
(2) someone who persuades a minor, over the phone (etc.) to engage in sex? That is, if John 
phones a woman asking her only to have dinner, and then, at dinner, persuades her to engage in 
illegal sex, does his behavior fall under the language of the statute? 
Linguistically, this boils down to how the appositive gerundive phrase "using the mail" 
relates to the causative main verb "persuades." The gerundive phrase is playing the semantic role 
William James.' 970 I 33 Kirkland Street I Cambridge I Massachusetts 02138 
P 617.495.0831 I f 617.495.8279 I oinker@wih.harvard.edu 
EFTA00176532

of instrument: something used as a means to the ends specified by the causative verb. So the 
question is how an instrument-phrase is ordinarily interpreted. We can clarify this by simplifying 
even further and substituting concrete events for the abstract ones in the statute: 
(a) John, using a hammer, broke the glass. 
Now consider the following scenarios: 
(b) John uses a hammer to bang nails into a piece of wood. Then 
he puts the hammer down, reaches for a glass, and deliberately 
smashes the glass against the table. 
(c) With his right hand, John hammers in a nail. While he is doing 
this, he reaches for a glass with his left hand, and deliberately 
smashes the glass against the table. 
(d) John takes a hammer and deliberately swings it against the 
glass, breaking it. 
It's clear that no English speaker would ever use the sentence (a) to describe scenario (b). 
Similarly, sentence (a) would almost certainly not be used to describe scenario (c): any English 
speaker would say "while using a hammer," not just "using a hammer." The only scenario that 
can be described by (a) is the one in (d). In other words, the event denoted by the instrumental 
gerundive phrase must immediately precede the event denoted by the causative verb, and the 
actor has to use the instrument in order to bring about the change indicated by the causative 
verb; that is, it has to be the means to an end. 
There is an additional condition that has to be met. Consider scenario (e): 
(e) Mary is holding a glass. John stands behind Mary, and bangs a 
hammer against an iron bar. The noise startles Mary, who drops 
the glass, breaking it. 
Here, too, it would be pretty weird to use sentence (a) to describe the scenario, even if John 
intended for the glass to break as a result of the scenario. As far as English verbs are concerned, 
the only means to the end that counts is the one that directly and immediately precedes the end. 
In addition, the way in which the means brings about the end has to be more-or-less 
stereotyped—the circuitous and unconventional means in this case (startling Mary) renders the 
sentence unacceptable. 
Finally, to be as charitable as possible to alternative interpretations, consider scenario (f): 
(f) A glass is packed in a wooden crate. John smashes the crate 
with a hammer in order to open it. He reaches for the glass and 
hurls it against the floor, breaking it. 
Even with this scenario it would be very odd to say "John, using a hammer, broke the glass." 
Once again, the use of the hammer has to the immediate cause of the breaking of the glass, not 
one separated from it by several links in a causal chain. 
Getting back to the statute in question, I would conclude that it would naturally apply 
only to someone who used the Internet or phone (or other relevant facility) as the direct, 
immediate, and intended means to the end of persuasion: that is, the sexual come-on would have 
to be on the phone or in the Internet message. If one doubts this, one only has to consider a 
scenario in which John phones Mary to invite her to dinner, having no sexual intentions 
whatsoever, and during dinner is struck by her beauty and relaxed by the wine, and decides on 
EFTA00176533

the spur of the moment to try to seduce her. No one could possibly describe that as "John, using 
the phone, seduced Mary," since he had no such intention at the time he used the phone. 
These properties of the use of verbs—immediateness, means-ends, directness, 
stereotypy—have been discussed in the literature on the lexical semantics of causative verbs for 
almost forty years. They have also been confirmed in experiments that ask people whether they 
could use various sentences to describe particular scenarios. I append below a few of the 
references to the relevant scholarly literature. 
My professional conclusion, in sum, is that an English speaker, reading the statute, would 
naturally understand it as applying only to persuasion (etc.) that is done while "using the mail" 
(etc.). To understand it as applying to persuasion (etc.) done subsequent to the use of the mail, 
phone, etc., would be an unnatural and grammatically inaccurate reading of the language. 
I hope this helps to clarify your question. Please don't hesitate to be in touch if I can 
clarify or expand on this analysis. 
Sincerely, 
Fodor, J. A. (1970). Three reasons for not deriving "kill" from "cause to die". Linguistic 
Inquiry, 1, 429-438. 
Gergely, G., & Bever, T. G. (1986). Relatedness intutions and mental represenation of 
causative verbs. Cognition, 23, 211-277. 
Levin, B., & Pinker, S. (Eds.). (1992). Lexical and conceptual semantics. Cambridge, Mass.: 
Blackwell. 
Pinker, S. (1989). Learnability and cognition: The acquisition of argument structure. 
Cambridge, Mass.: MIT Press. 
Shibatani, M. (1976). The grammar of causative constructions: A conspectus. In M. 
Shibatani (Ed.), Syntax and semantics 6: The grammar of causative constructions. New 
York: Academic Press. 
Talmy, L. (1988). Force dynamics in language and cognition. Cognitive Science, 12, 49-
100. 
Wolff, P. (2003). Direct causation in the linguistic coding and individuation of causal 
events. Cognition, 88, 1-48. 
Wolff, P., & Song, G. (2003). Models of causation and the semantics of causal verbs. 
Cognitive Psychology, 47, 276-332. 
EFTA00176534

It 
EFTA00176535

Southern District of Florida Cases Charging 18 U.S.C.S. 2422 (b) 
Case # 
Defendant 
Counts 
Other Charges 
Summary 
97-8093 
Paul Panunzio 
2 
2 counts 2422(6) 
Use of intemet to entice 
minor to engage in sex 
activity. 
00-6034 
John Palmer 
2 
18 U.S.C.S. 
2252A(a)(5)(B) 
Use of internet to entice 
minor to engage in sex 
activity. 
01-0704 
Michael Nyberg 
1 
[None] 
D met u/c officer (posing 
as 13 y.o. girl) on internet 
chat service. D had 
sexually explicit 
conversation with ofc., set 
up meeting on internet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
01-0734 
Franco Sabri 
1 
[None] 
D met u/c officer (posing 
as 13 y.o. girl) on intemet 
chat service. D had 
sexually explicit 
conversation with ofc., set 
up meeting on internet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
01-0756 
Eduardo Alvarez 
1 
[None] 
D met u/c officer (posing 
as 13 y.o. girl) on intemet 
chat service. D had 
sexually explicit 
conversation with ofc., set 
up meeting on internet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
01-0783 
Prem D'Sa 
1 
[None] 
D met u/c officer (posing 
as 13 y.o. girl) on intemet 
chat service. D had 
sexually explicit 
EFTA00176536

conversation with ofc., set 
up meeting on internet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
01-0961 
Jose Mayorga 
I 
[None] 
D met u/c officer (posing 
as 13 y.o. girl) on internet 
chat service. D had 
sexually explicit 
conversation with ofc., set 
up meeting on internet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
01-0998 
Gustavo Desouza 
1 
[None] 
D met u/c officer (posing 
as 13 y.o. girl) on internet 
chat service. D had 
sexually explicit 
conversation with ofc., set 
up meeting on internet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
01-1004 
Ferrys Miranda 
I 
[None] 
D met u/c officer (posing 
as 12 y.o. girl) on internet 
chat service. D had 
sexually explicit 
conversation with ofc., set 
up meeting on internet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
01-1139 
James Patterson 
1 
[None] 
D met u/c officer (posing 
as 13 y.o. girl) on internet 
chat service. D had 
sexually explicit 
conversation with ofc., set 
up meeting on internet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
01-1174 
Roberto 
I 
[None] 
Use of internet to entice 
minor to engage in sex 
2 
EFTA00176537

activity. 
01-6024 
James Boutin 
2 
18 U.S.C.S. 
2252A(a)(5)(B) 
Use of internee to entice 
minor to engage in sex 
activity. 
01-6107 
Otis Wragg 
1 
[None] 
Use of Internet to entice 
minor to engage in sex 
activity. 
01-6157 
Kelly Jones 
4 
18 U.S.C.S. 
2252A(a)( I ); 
18 U.S.C.S. 
2252A(a)(2)(A); 
18 U.S.C.S. 
2252A(a)(5)(B) 
Use of intemet to entice 
minor to engage in sex 
activity. 
01-6185 
Byron Matthai 
1 
[None] 
Use of internee to entice 
minor to engage in sex 
activity. 
01-6203 
Anthony Gentile 
2 
18 U.S.C.S. 
2252A(a)(5)(B) 
Use of intemet to entice 
minor to engage in sex 
activity. 
01-8073 
Jerrold Levy 
5 
2 counts 2422(b); 
18 U.S.C.S. 
2252A(a)(2); 
18 U.S.C.S. 
2252A(a)(5)(B); 
18 U.S.C.S. 
2252(a)(4) 
D communicated with u/c 
officer (posing as 14 y.o. 
boy) on Internet; D had 
sexually explicit 
conversation with ofc., set 
up meeting on internee for 
purpose of having sex; D 
arrested at meeting site. 
Police obtained SW for 
D's home and seized 
computer. Police located 
another minor boy that D 
had previously 
communicated w/ and 
engaged in sexual activity 
md; child pornography also 
found on computer. 
(Affidavit attached). 
01-8097 
John Estevez 
1 
[None] 
D met u/c officer (posing 
as 13/14 y.o. girl) on 
intemet chat service. D 
had sexually explicit 
3 
EFTA00176538

conversations with ofc.; D 
gave u/c his cell phone 
#; u/c called D (3 taped 
phone calls); set up 
meeting on internet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
01-8161 
Carlos Navas 
I 
[None] 
Use of internet to entice 
minor to engage in sex 
activity. 
02- 
14077 
Anthony Murrell 
I 
[None] 
D met u/c officer (posing 
as a mother with a 13 y.o. 
daughter) on Internet chat 
room; D was looking to be 
w/ a mother and daughter. 
D gave his phone # to u/c. 
D met same u/c (posing as 
dad with 13 y.o. daughter) 
in another chat room; D 
wanted to rent daughter. D 
gave his phone # to u/c and 
u/c called him to speak 
about arrangements. Next 
day D & u/c had further 
conversation thru the chat 
room. 4 days later D 
called u/c on phone 
making meeting 
arrangements & agreed to 
pay $300. D arrested at 
hotel meeting site. 
(Affidavit attached). 
02- 
14080 
Douglas 
Bourdon 
I 
[None] 
Use of internet to entice 
minor to engage in sex 
activity. 
02- 
14081 
James Hornaday 
I 
[None] 
D met u/c (posing as father 
with 2 minor 
children) in internet 
chatroom. D looking to 
have sex with family; u/c 
called D several times 
and D had sexually explicit 
conversations w/ 
4 
EFTA00176539

u/c. D also sent nude 
photos of himself for 
minors to see. 
02- 
Brian Pan fi I 
I 
[None) 
D met u/c officer (posing 
20342 
as 13 y.o. girl) on intemet 
chat service. D had 
sexually explicit 
conversation with ofc., set 
up meeting on Internet for 
purpose of having sex; D 
asked u/c to call him once 
she reached the meeting 
point; u/c called; D 
arrested at meeting site. 
(Affidavit attached). 
02- 
John Orrega 
I 
[None} 
D met u/c officer (posing 
20408 
as 13 y.o. girl) on Internet 
chat service. D had 
sexually explicit 
conversation with ofc., set 
up meeting on Internet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
02- 
Donald Kent 
I 
i None] 
D met u/c officer (posing 
20437 
as 13 y.o. girl) on Internet 
chat service. D had 
sexually explicit 
conversation with ofc., set 
up meeting on intemet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
02- 
Mark 0beinuner 
2 
18 U.S.C.S. 1470 
D met u/c officer (posing 
20705 
as 13 y.o. girl) on 
Internet chat service. D 
had sexually explicit 
conversation with ofc. D 
sent obscene photos to 
u/c and masturbated on 
webcam for u/c. D gave 
u/c his phone #; u/c called 
5 
EFTA00176540

D and D had sexually 
explicit conversation with 
u/c on phone. 
02- 
21012 
William Yon 
3 
3 counts of 2422(b) 
D contacted 2 15 y.o. 
girls/students via the 
Internet and had sexually 
explicit conversations with 
them. Girls went to police. 
D set up meeting with u/c 
ofc. posing as one of the 
girls for purpose of having 
sex. D went to meeting 
site and then returned 
home. D arrested at home. 
(Affidavit attached). 
02- 
80042 
Samuel Morton 
25 
2 counts 2422(b); 
18 U.S.C.S. 
2252A(a)(2); 
18 U.S.C.S. 
2252(a)(2); 
18 U.S.C.S. 
2252(a)(4); 
18 U.S.C.S. 2253 
D met several u/c officers 
(posing as minor 
girls) on intemet chat 
service. D had sexually 
explicit conversation with 
ofcs. D sent obscene 
photos to u/c. D had 
several phone 
conversations w/ different 
u/c officers. 
02- 
80072 
Todd Kroeber 
6 
18 U.S.C.S. 
2252(a)(2); 
18 U.S.C.S. 
2252A(a)(2); 
18 U.S.C.S. 
2252A(a)(5)(B) 
Use of facility of interstate 
commerce to entice a 
minor to engage in sex 
activity (does not specify 
the facility). 
Knowingly received child 
pornography. 
Knowingly distributed 
child pornography in 
interstate commerce by 
computer. 
02- 
80171 
Elias Guimaraes 
1 
[None] 
Use of intemet to entice 
minor to engage in sex 
activity. 
03- 
14028 
Edgar Searcy 
1 
[None] 
D met u/c officer (posing 
as a dad with a 13 y.o. 
6 
EFTA00176541

daughter) on intemet chat 
room utilized by people 
trading their children for 
sex. D gave his phone # to 
u/c. U/c called D at set up 
meeting. D stated that he 
intended to have sex w/ 
u/c's daughter. D arrested 
at meeting site. 
03- 
Joesph Poignant 
1 
[None] 
Use of intemet and 
13068 
telephone to entice minor 
to engage in sex activity. 
03- 
David Brautigam 
I 
[None] 
D met u/c officer (posing 
20043 
as 13 y.o. girl) on intemet 
chat service. D (using 2 
usernames) had sexually 
explicit conversation with 
ofc., set up meeting on 
intemet for purpose of 
having sex; arrested at 
meeting site. (Affidavit 
attached). 
03- 
Joseph Messier 
1 
I None] 
D met u/c officer (posing 
20060 
as 13 y.o. girl) on Internet 
chat service. D had 
sexually explicit 
conversation with ofc., set 
up meeting on intemet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
03- 
Marco Pena 
I 
[None] 
D met u/c officer (posing 
20132 
as 13 y.o. girl) on intemet 
chat service. D had 
sexually explicit 
conversation with ofc., set 
up meeting on intemet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
03- 
Jaime 
2 
2 counts of 2422(b) 
D met u/c officer (posing 
20133 
Montealegre 
as 14 y.o. girl) on intemet 
chat service. D had 
7 
EFTA00176542

sexually explicit 
conversation with ofc., set 
up meeting on intemet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
03- 
Kenneth Sciacca 
I 
(None I 
Use of intemet to entice 
80164 
minor to engage in sex 
activity. 
04- 
1 imothy Dal nail 
1 
[None] 
Use of intemet to entice 
14009 
minor to engage in sex 
activity. 
04- 
James Brown 
I 
[None] 
Use of intemet to entice 
14032 
minor to engage in sex 
activity. 
04- 
William Kama! 
I 
[None] 
Use of intemet to entice 
14063 
minor to engage in sex 
activity. 
04- 
Andres Rojas 
I 
[None] 
D met u/c officer (posing 
20040 
as minor girl) on 
intemet chat service. D 
had sexually explicit 
conversation with u/c ofc. 
04- 
Carlos Barroso 
3 
2 counts of 18 
Use of intemet to entice 
20055 
U.S.C.S. 1470 
minor to engage in sex 
activity. 
Transfer of obscene 
material via the intemet. 
04- 
Derek 
2 
18 U.S.C.S. 1594(a) 
D responded to an 
20408 
advertisement in a 
newspaper 
for Costa Rica Taboo 
Vacations, a fake travel 
agency run by federal 
investigators. D 
negotiated and paid for a 
trip to Costa Rica in 
which he planned to have 
sex with 16-year old 
minors. He cancelled the 
8 
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trip, but arranged for 
Taboo Vacations to 
provide him with underage 
sex with the Costa Rican 
girls in the U.S. D set 
up meeting at hotel. D 
arrested at hotel. 
04- 
.lames Marquez 
3 
18 U.S.C.S. 2423(e); 
Knowingly attempted to 
20409 
18 U.S.C.S. 1594(a) 
induce minor to engage in 
prostitution. [no other 
facts] 
04- 
Wallace Strevell 
3 
18 U.S.C.S. 2423(e); 
D called "travel agency" to 
20520 
18 U.S.C.S. 1594(a) 
arrange for trip to 
Costa Rica for sex w/ 
minors. D had several 
phone conversations w/ 
travel agency. D bought 
tickets and made 
reservations at hotel. D 
arrested at airport. 
04- 
Vincent Springer 
3 
18 U.S.C.S. 2423(e); 
Knowingly attempted to 
20551 
18 U.S.C.S. 1594(a) 
induce minor to engage in 
prostitution. [no other 
facts] 
04- 
Clarke 
18 U.S.C.S. 2423(e); 
D attempted to arrange to 
20656 
18 U.S.C.S. 1594(a) 
have sex w/ minor 
girls in Costa Rica thru 
fake "travel agency." 
04- 
Ryan Kannett 
9 
18 U.S.C.S. 
Use of Internet to entice 
20837 
2252A(a)(2)(A); 
18 U.S.C.S. 
minor under 12 y.o. to 
engage in sex activity. 
2252A(a)(5)(B); 
21 U.S.C.S. 841(a)(1); 
Possessed and distributed 
child pornography. 
18 U.S.C.S. 
924(c)(1XA); 
Possession with intent to 
sell drugs. 
18 U.S.C.S. 2253; 
21 U.S.C.S. 853 
18 U.S.C.S. 924(d)(1) 
Knowingly carry firearm 
during drug trafficking 
crime. 
04- 
Raymond 
13 
2 counts 2422(b); 
Use of intemet to entice 
60046 
Bohning 
18 U.S.C.S. 
2251(c)(1), (c)(2), and 
minor to engage in sex 
activity. 
(e); 
Traveled to England for 
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EFTA00176544

18 U.S.C.S. 2423(b) 
and (f); 
purpose of having sex with 
minor. 
18 U.S.C.S. 
2252A(a)(1); 
18 U.S.C.S. 
Sent, distributed, and 
received child 
pornography. 
2252A(a)(2)(A); 
18 U.S.C.S. 
2252A(a)(2)(B); 
18 U.S.C.S. 
2252A(a)(6)0; 
18 U.S.C.S. 
2252A(a)(5)(B) 
05- 
Gerald Smith 
1 
[None] 
Use of internet to entice 
14011 
minor to engage in sex 
activity. 
05- 
Timothy 
4 
2 counts of 2422(b) 
Use of internet to entice 
14024 
Campbell 
18 U.S.C.S. 
2252(a)(2); 
minor to engage in sex 
activity. 
18 U.S.C.S. 
2252(A)(4)(B) 
Received and possessed 
child pornography that had 
been transported in 
interstate commerce. 
05- 
Adam Statland 
3 
18 U.S.C.S. 2423(b) 
Use of internet to entice 
14039 
minor to engage in sex 
activity. 
Traveled from California 
to Florida w/ intent to 
engage in sexual activity 
with a minor. 
05- 
Robert Carlo 
1 
[None] 
Use of internet to entice 
14046 
minor to engage in sex 
activity. 
05- 
Mark Rader 
2 
18 U.S.C.S. 
Use of internet to entice 
14047 
2252(a)(1) 
minor to engage in sex 
activity. 
Knowingly transported 
child pornography in 
interstate commerce. 
05- 
Robert Latham 
2 
18 U.S.C.S. 
Use of internet to entice 
14060 
2252(a)(1) 
minor to engage in sex 
activity. 
Knowingly transported 
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child pornography by a 
computer. 
05- 
Ralph Poole, Jr. 
1 
[None] 
Use of internet to entice 
14099 
minor to engage in sex 
activity. 
05- 
Mark Madison 
3 
18 U.S.C.S. 
Operation of child 
20444 
Justin Evans 
3 
1591(a)(1); 
prostitution ring in Miami. 
Chad Ycarby 
3 
18 U.S.C.S. 
14 y.o. girl worked for 
1591(a)(2); 
Evans as prostitute. 
18 U.S.C.S. 2423(e) 
Evans arranged dates for 
her at hotels, and she 
gave money from dates to 
Evans. Evans called 
14 y.o. girl to inform her 
of dates. Evans also 
gave girl's phone /4 to 
customers. Evans 
supplied girl with 
condoms. 
05- 
Edward Byrd 
1 
[None] 
Use of internet to entice 
60049 
minor to engage in sex 
activity. 
05- 
Callahan 
2 
18 U.S.C.S. 2423(b) 
Use of internet to entice 
60073 
minor to engage in sex 
activity. 
05- 
Thomas 
1 
[None] 
D met u/c officer (posing 
80023 
Bohannon 
as 15 y.o. girl) on 
internet chat service. D 
had sexually explicit 
conversation with ofc., set 
up meeting on 
internet for purpose of 
having sex; arrested at 
meeting site. 
05- 
Laronn Houston 
1 
[None] 
D met u/c officer (posing 
80029 
as a mother with a 14 
y.o. daughter) on internet 
chat room. D set up 
meeting w/ mother & 
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