Epstein Secrets

much less for the purpose of engaging in "illicit sexual conduct." To the contrary, the prospect that Mr. Epstein might engage in sexual activity in Florid was not the dominant motive—or even a significant motive—for his travel. See Mortensen I United EFTA00225877 • Page 32 Federal prosecutors have

sentence does not change the fact that the sentence was available to the State and rejected in its discretion. Therefore, Petite's presumption that the State of Florida's prior prosecution of Mr. Epstein has vindicated the federal interest cannot be said to have been overcome. • • Second, the State's proposed plea

t in question has been accurately characterized by a d jury as solicitation of prostitution, a quintessential State law concern. See United States Evans, 476 F.3d 1176, n.1 (11th Cir. 2007) (federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulation

rved. JUN 3 0 2O3 [ I Specific sentences: In the event the above sentence is to the Department of Correctiens, the Sheriff of Palth Beach County, Plerida is hereby ordered and directed to deliver the Defendant to the Department of Correction4 togetheeiwitliateleY of the Judgment and Sentence, and any

from "sexual assault" under Florida law. Celebrity Cruises, 394 F.3d at 916-17. The court also cited with approval the dissenting opinion in Doe'. Evans, 814 So. 2d 370, 380 (Fla. 2002) (Wells, C.J., dissenting), where Florida Chief Justice Wells admonished against "the use of broad, indefinite, and

ize all acts of prostitution (a vice traditionally governed by state rogulationy)). and there is no evidence that Palm Beach County authorities and Florid* prosecutors cannot effectively prosecuic and punish the conduct, there is no reason why this matter should be extracted from die hands of state pro

mounted to, at most, the solicitation of prostitution, is unprecedented. Since prostitution is fundamentally a state concern. free United Stater v. Evans, 476 F.36 3176, 1 (I lot Cir. 2007) (federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state rogulationy

he pertinent federal statutes, and respectfully request that the Office of the Deputy Attorney General end federal involvement in this matter so that the State of Florida may resolve this case appropriately. Summary of the Facts Mr. Epstein has maintained a home in Palm Beach, Florida for the past 20 years. While the

creates a substantive right which prevents prosecution and conviction of an individual after the statute has run.” See State v. King, 282 So. 2d 162 (Fla. 1973); Tucker v. State, 417 So. 2d 1006 (Fla. 3d D.C.A. 1982) (citing cases). Given the one-year statute of limitations, any conduct that might amou

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 (11" Cir. 2007) as a case that, standing alone, involved wholly intrastate conduct, the facts of that case are far different in key re