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EFTA00284175

91 sivua
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Sivu 21 / 91
SAW OFFICES or 
GERALD B. LEFCOURT. P.C. 
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 Lawrence 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 
EFTA00284195
Sivu 22 / 91
LOON OIICCl OF 
GERALD B. LEFCOURT. PC. 
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 
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 Steams. 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. 
EFTA00284196
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LAW OFF- CLS OV 
GERALD B. LEITCOUHT. PC. 
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, 
§c4-14 
/( 0=1-vb --a
Gerald B. Lefcourt 
hi4640 L..) 6Th
Alan Dershowitz 
cc: Lilly Ann Sanchez, Esq. 
Roy Black, Esq. 
EFTA00284197
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Tab A 
EFTA00284198
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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, enticing, 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 Hall 970 I 33 Kirkland Street I Cambridge I Massachusetts 02138 
I f 
EFTA00284199
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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 bas 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 (1): 
(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 
EFTA00284200
Sivu 27 / 91
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. 
EFTA00284201
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Tab B 
EFTA00284202
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Southern District of Florida Cases Charging 18 U.S.C.S. 2422 (b) 
Case it 
Defendant 
Counts 
Other Chargcs 
Summary 
97-8093 
Paul Panunzio 
2 
2 counts 2422(b) 
Use of Internet 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 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). 
01-0756 
Eduardo Alvarez 
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 intemet 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 internet 
chat service. D had 
sexually explicit 
EFTA00284203
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01-0961 
Jose Mayorga 
1 
[None) 
01-0998 
Gustavo Desoun 
1 
[None] 
01-1004 
Fenys Miranda 
1 
[None] 
01-1139 
James Patterson 
[None) 
01-1174 
Roberto 
Gonzalez 
1 
[None] 
conversation with ofc., set 
up meeting on Internet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
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 intemet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
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). 
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 intemet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
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). 
Use of Internet to entice 
minor to engage in sex 
EFTA00284204
Sivu 31 / 91
activity. 
01-6024 
James Boutin 
2 
18 U.S.C.S. 
2252A(a)(5)(B) 
Use of intemet to entice 
minor to engage in sex 
activity. 
01-6107 
Otis Wragg 
1 
[None] 
Use of intemet to entice 
minor to engage in sex 
activity. 
01-6157 
Kelly Jones 
4 
18 U.S.C.S. 
2252A(a)(1); 
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 intemet to entice 
minor to engage in sex 
activity. 
014203 
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 intemet; D had 
sexually explicit 
conversation with ofc., set 
up meeting on Internet 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 
vd; child pornography also 
found on computer. 
(Affidavit attached). 
01-8097 
John Estevez 
I 
[None] 
D met u/c officer (posing 
as 13/14 y.o. girl) on 
intemet chat service. D 
had sexually explicit 
3 
EFTA00284205
Sivu 32 / 91
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 intemet 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 intermit chat 
room; D was looking to be 
w/ a mother and daughter. 
D gave his phone if to tile. 
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 
1 
[None] 
Use of intemet to entice 
minor to engage in sex 
activity. 
02- 
14081 
James Homaday 
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 
EFTA00284206
Sivu 33 / 91
u/c. D also sent nude 
photos of himself for 
minors to see. 
02- 
20342 
Brian Panfil 
1 
iNoncl 
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 intemet 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- 
20408 
John Orrega 
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 intemet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
02- 
20437 
Donald Kent 
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 intemet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
02- 
20705 
Mark Obermaier 
2 
18 U.S.C.S. 1470 
D met u/c officer (posing
as 13 y.o. girl) on 
intemet chat service. D 
had sexually explicit 
conversation with ofc. D 
sent obscene photos to 
u/c and masturbated on 
webaun for u/c. D gave 
u/c his phone #; u/c called 
5 
EFTA00284207
Sivu 34 / 91
D and D had sexually 
explicit conversation with 
u/c on phone. 
02- 
21012 
William Yon 
3 
3 counts of 2422(6) 
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(aX2); 
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 interne 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 1Croeber 
6 
18 U.S.C.S. 
2252(a)(2); 
18 U.S.C.S. 
2252A(aX2); 
18 U.S.C.S. 
2252A(a)(5XB) 
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. 
3
EFTA00284208
Sivu 35 / 91
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. E) arrested 
at meeting site. 
03- 
13068 
Joesph Poignant 
1 
[None] 
Use of intemet and 
telephone to entice minor 
to engage in sex activity. 
03- 
20043 
David Brautigam 
1 
[None] 
D met u/c officer (posing 
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- 
20060 
Joseph Messier 
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 intemet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
03- 
20132 
Marco Pena 
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 intemet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
03- 
20133 
Jaimc 
Nlontealegre 
2 
2 counts of 2422(b) 
D met u/c officer (posing 
as 14 y.o. girl) on intemet 
chat service. D had 
EFTA00284209
Sivu 36 / 91
sexually explicit 
conversation with oft., set 
up meeting on internet for 
purpose of having sex; 
arrested at meeting site. 
(Affidavit attached). 
03- 
80164 
Kenneth Sciacca 
1 
[None] 
Use of internet to entice 
minor to engage in sex 
activity. 
04- 
14009 
Timothy Damall 
1 
[None] 
Use of intemet to entice 
minor to engage in sex 
activity. 
04- 
14032 
James Brown 
I 
[None] 
Use of intemet to entice 
minor to engage in sex 
activity. 
04- 
14063 
William Kamal 
1 
[None] 
Use of intemet to entice 
minor to engage in sex 
activity. 
04- 
20040 
Andres Rojas 
1 
[None] 
D met u/c officer (posing 
as minor girl) on 
Internet chat service. D 
had sexually explicit 
conversation with u/c ofc. 
04- 
20055 
Carlos Barroso 
3 
2 counts of 18 
U.S.C.S. 1470 
Use of intemet to entice 
minor to engage in sex 
activity. 
Transfer of obscene 
material via the intemet. 
04- 
20408 
Derek Roberts 
2 
18 U.S.C.S. 1594(a) 
D responded to an 
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 
EFTA00284210
Sivu 37 / 91
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- 
James 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- 
George 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 Kennett 
9 
18 U.S.C.S. 
Use of Internet to entice 
20837 
2252A(aX2)(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(cX1XA); 
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 Internet to entice 
60046 
Boluting 
18 U.S.C.S. 
2251(c)(1), (eX2), and 
minor to engage in sex 
activity. 
(e); 
Traveled to England for 
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18 U.S.C.S. 2423(6) 
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 intemet to entice 
14011 
minor to engage in sex 
activity. 
05- 
Timothy 
4 
2 counts of 2422(b) 
Use of intemet to entice 
14024 
Campbell 
18 U.S.C.S. 
2252(aX2); 
minor to engage in sex 
activity. 
18 U.S.C.S. 
2252(AX4XB) 
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 intemet 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 intemet to entice 
14046 
• 
minor to engage in sex 
activity. 
05- 
N4alk Rader 
2 
18 U.S.C.S. 
Use of internet to entice 
14047 
2252(aX1) 
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 
10 
EFTA00284212
Sivu 39 / 91
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(aX1); 
prostitution ring in Miami. 
Chad Yearby 
3 
18 U.S.C.S. 
14 y.o. girl worked for 
1591(aX2); 
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 # 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- 
Patrick 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 
interact 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 intemet 
chat room. D set up 
meeting w/ mother & 
11 
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Sivu 40 / 91
minor. D arrested at 
meeting site. 
05- 
80200 
Lucas Phelps 
5 
18 U.S.C.S. 1470 
Use of internet to entice 
minor to engage in sex 
activity. 
Attempt to knowingly 
transfer child pornography 
in interstate commerce to a 
minor. 
06- 
14003 
Octavio 
Villalona 
2 
18 U.S.C.S. 
2252(a)(1) 
Use of internet to entice 
minor to engage in sex 
activity. 
Knowingly transported 
child pornography by a 
computer. 
06- 
14006 
Daniel Williams 
I 
[None] 
Use of Internet to entice 
minor to engage in sex 
activity. 
06- 
14007 
Ricky Barnett 
1 
[None] 
Use of intemet to entice 
minor to engage in sex 
activity. 
06- 
14011 
John Everhart, Il 
1 
I None) 
Use of internet to entice 
minor to engage in sex 
activity. 
06- 
14016 
Eric Rollins 
3 
2 counts 2422(b) 
18 U.S.C.S. 2422(a) 
Use of internet to entice 
minor to engage in sex 
activity. 
Knowingly enticed a 
minor to travel in interstate 
commerce to engage in 
sexual activity. 
06- 
14053 
Richard Grande, 
Jr. 
1 
[None] 
Use of internet to entice 
minor to engage in sex 
activity. 
06- 
14069 
Eric Matthews 
4 
18 U.S.C.S. 1470; 
18 U.S.C.S. 
2252(a)(2) 
Use of internet to entice 
minor to engage in sex 
activity. 
Knowingly transferred 
obscene material to a 
minor in interstate 
commerce. 
12 
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