Epstein Secrets

igueroa Street Los Angel oo Phone• May 19, 2008 Joe D. Whitley Alston & Bird LLP The Atlan i it 'n VIA FACSIMILE - CONFIDENTIAL Honorable Mark Filip Office of the Deputy Attorney General United States Department of Justice 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530 Dear Judge Filip:

mounted to, at most, the solicitation of prostitution, is unprecedented. Since prostitution is fundamentally a state concern, (see United States v. Evans, 476 F.3d 1176, n.1 (11th Cr. 2007) (federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulation)"

13 1 Kenneth W. Starr Joe D. Whitley Kirkland & Ellis LLP Alston & Bird LIP May 19, 2008 VIA FACSIMILE (202) 514.0467 CONFIDENTIAL honorable Mark Filip Office of the Deputy Attorney General United States Department of Justice Dear Judge Filip: In his confirmation hearings last fall, Judge Mukasey

t amounted to, at most, the solicitation of prostitution, is unprecedented. Since prostitution is fundamentally a mute concern, (see United Stares' Evans, 476 F.3d 1176, n.1 (1Ith Cir. 2007) (federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulation)

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at amounted to. at moss, the ,elicitation of prostitution, is unprecedented. Since prostitution is fundamentally a state concern. (rye Unita Shawl. Evans, 476 F.3d 1176, c.1 (11th Cir. 2007) (federal law -does not criminalize all acts of prostitution (a vice traditionally governed by state regulation)

lnacani. :N.: i 171. ..4:4:::444.1181, F44 4‘ rivtristdrYfrJa..II:Igai May 27, 2008 fn rACS1M(.11:: <2021 514-0467 CONNOKA177.4/. I lottomhle Mark Filip ( /like blthe l)epiity adarnincy General I initial States Department °rho:lice Q50 Pennsylvania Avenue, N.V.'. WaShi !Wien. D.C. 7.0531) Dear Ju

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

an oral presentation to supplement our written submissions, and we will promptly respond to any inquiries you may have. cc: Deputy Attorney General Mark Filip HOUSE_OVERSIGHT_012140 --- PAGE BREAK --- MAIN SUBMISSION HOUSE_OVERSIGHT_012141 --- PAGE BREAK --- KIRKLAND & ELLIS LLP SUBMISSION TO THE OFF

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

s co-conspirators. None of this type of activity comes close to the facts regarding Mr. Epstein. Finally, but significantly, the prostitution ring in Evans was not, in fact, entirely intrastate as the companion case of one of the Evans co-defendants makes clear. See, United States v. Madison, 477 F.3d 13

The Atlantic Building Los Angeles, CA 90017-5800 950 F Street, NW Washington, DC 20004-1404 May 19, 2008 VIA FACSIMILE Po CONFIDENTIAL Honorable Mark Filip Office of the Deputy Attorney General United States Department of Justice 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530 Dear Judge Filip: I

amounted to, at most, the solicitation of prostitution, is unprecedented. Since prostitution is fundamentally a state concern, (see United States v. 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)”

amounted to, at most, the solicitation of prostitution, is unprecedented. Since prostitution is fundamentally a state concern, (see United States v. 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)”

ON IN ERROR, PLEASE NOTIFY US IMMEDIATELY AT: (213) 680-8400. To: . ' Company: Fax #: Direct #: _ Office of the Deputy Attorney General | Honorable Maris Filip United States Department of Justice From: Date: Pageswicover - Fax #: . Direct #: Kenneth W. Sta May 19, 2008 es Message: HOUSE_OVERSIGHT_019232

500 Ph: 202-756-3189 [email protected] Fax: 202-654-4889 [email protected] May 19, 2008 VIA FACSIMILE (202) 514-0467 CONFIDENTIAL Honorable Mark Filip Office of the Deputy Attorney General United States Department of Justice 950 Pennsylvania Avenue, N.W. Washington, D.C, 20530 Dear Judge Filip: |

amounted to, at most, the solicitation of prostitution, is unprecedented, Since prostitution is fundamentally a state concern, (see United States v. 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}’