Epstein Secrets

solicitation under State law. After all, prostitution, even when the allegations involve minors, is fundamentally a State concern, United States v. Evans, 476 F.3d 1176, n.1 (11th Cir. 2007) (noting that federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state

e. When asked, the closest case suggested by the prosecutors was United States v. Boehm—and it hardly could differ more from Mr. Epstein's case. In Boehm, the defendant was charged with conspiracy to distribute cocaine and cocaine base to minors, in violation of 21 U.S.C. §§ 846, 84I(a)(1), and 859(a)

l prosecutors have pursued under the federal statutes at issue here. When asked, the closest case suggested by the prosecutors was United States v. Boehm—and it hardly could differ more from Mr. Epstein's case. In Boehm, the defendant was charged with conspiracy to distribute cocaine and cocaine base

or intimidation. These arc the elements required by the statute, and they are not met here. Although CEOS could, perhaps, point to United Slat% 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

e. When asked, the closest case suggested by the prosecutors was United Stares v. Boehm—and it hardly could differ more from Mr. Epstein's case. In Boehm, the defendant was charged with conspiracy to distribute cocaine and cocaine base to minors, in violation of 21 U.S.C. §§ 846, 841(a)(1), and 859(a)

ion of a firearm, in violation of 18 U.S.C. § 922(g)(1); and sex trafficking of children in violation of 18 U.S.C. §§ 371 and 1591. United States v. Boehm, Case No. 3:04CR00003 (D. Alaska 2004). Boehm's actions, unlike Mr. Epstein's, also had a strong interstate nexus: Boehm purchased and distributed

state statute and the more general statute is a federal statute, especially in an area traditionally prosecuted by the states. See United States v. Evans, 476 F.3d 1176 (11th Cir. 2007) ("prostitution [is] a vice traditionally governed by state regulation"). We believe with great conviction that Cong

thing. Therefore, we urge that you direct that a full and fair and complete examination of the most trustworthy evidence be ordered. 10 In U.S. v. Boehm, the defendant bought and distributed crack cocaine and cocaine to underage girls; admitted to knowing that the girls were underage; arranged for un

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

ts. In addition to the well-established state restitution statute, the defense offered a federal proposal that was similar to the resolution in the Boehm case, where the conduct was far more egregious. There, the defendant bought and distributed crack cocaine and cocaine to underage girls; admitted t

ral prosecutors have pursued under the federal statutes at issue here. When asked, the closest case suggested by the prosecutors was United States v. Boehm—and it hardly could differ more from Mr. Epstein’s case. In Boehm, the defendant was charged with conspiracy to distribute cocaine and cocaine base t

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

solicitation under State law. After all, prostitution, even when the allegations involve minors, is fundamentally a State concern, United States v. Evans, 476 F.3d 1176, n.1 (11th Cir. 2007) (noting that federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state

l prosecutors have pursued under the federal statutes at issue here. When asked, the closest case suggested by the prosecutors was United States v. Boehm—and it hardly could differ more from Mr. Epstein's case. In Boehm, the defendant was charged with conspiracy to distribute cocaine and cocaine base