Insufficient Factual Basis to Support Travel Act Violation

U.S. v. Bergman, 2006 WL 2338069 (8/14/06)(unpub'd) - The appellate attorney filed an Anders brief. The client raised her own issue. The government eventually concedes the defendant is right. There was an insufficient factual basis to support a Travel Act violation guilty plea where the defendant paid an undercover government agent $ 30,000 to kill her ex-husband. The facts did not establish the money constituted "proceeds of any unlawful activity" (see 18 U.S.C. §§ 1952(a)(1), 1956) or "criminally derived property" (see 18 U.S.C. § 1957(a)).