(Compl. Ti 155-56) 12 12 Although Plaintiffs' allegations are assumed as true for purposes of this motion, we note that Perlitz was convicted of one count of travel with intent to engage in illicit sexual conduct, in violation of 18 U.S.C. § 2423(b), which is not a predicate offense for purposes of 18 U.S.C. § 1595. -28- Case 3:11-cv-00614-RNC Document 158 Filed 01/30/12 Page 34 of 37 Section 1595 provides: (a) An individual who is a victim of a violation of this chapter may bring a:civil action against the perpetrator (or whoever knowingly benefits, financially or by receiving anything of value from participation in a venture which that person knew or should have known has engaged in an act in violation of this chapter) in an appropriate district court of the United States and may recover damages and reasonable attorneys fees.

Case 4:14-cv-01631 Document 14 Filed in TXSD on 07/21/15 Page 1 of 21 first attempt at § 2255 relief. On July 8, 2009, Davis was charged by Indictment with sex trafficking of children in violation of 18 U.S.C. §1591(a) (Count One), transportation of minors with intent to engage in sexual activity in violation of 18 U.S.C. § 2423(a) (Count Two), and coercion and enticement of an individual to travel in interstate commerce to engage in prostitution or any sexual activity for which an individual would be charged with a criminal offense in violation of 18 U.S.C. § 2422 (Count Three). (Document No. 1).

Sexual trafficking is not the only crime that could support Jane Doe No. 3’s joinder in this case. There are also various federal sex offenses, such as travel with intent to engage in illicit sexual conduct, 18 U.S.C. § 2423(b), which Jane Doe No. 3’s proffer supported. And perhaps most obviously, Jane Doe No. 3 was the victim of a conspiracy under 18 U.S.C. § 371.

In this case, the Department of State in its initial Report specifically cited both Private Action Statutes and each additional statute which Case: 4:10-cv-01740-TCM Doc. #: 33 Filed: 01/24/11 Page: 22 of 30 PageID #: 158 23 plaintiff claims was violated, including 18 USC 2251, 18 USC 2252, 18 USC 2252A, 18 USC 2421, 18 USC 2422, 18 USC 2423, 18 USC 1590, and 18 USC 1591. Nowhere is 42 USC 230 mentioned in the treaty documents.