Epstein Secrets

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)

ey Herman, had met with the father of one of the prospective plaintiffs, At the same time (and until as recently as March of 2008), the O Official Florida Bar website continued to identify Mr. Sloman as a named partner in Mr. I ferman's firm. See Tab 31, Florida Bar Website page. 39. Mr. Herman, who is t

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

ai lerman, had met with the father of one of the prospective plaintiffs, .5 At the same time (and until as recently as March of 2008), the Official Florida Bar website continued to identify Mr. SIM as a named partner in Mr. Herman's firm. See Tab 31, Florida Bar Website page. 39. Mr. Herman, who is the na

as recently as March of 2008), the Official Florida Bar website continued to identify Mr. Sloman as a named partner in Mr. Herman’s firm. See Tab 31, Florida Bar Website page. Mr. Herman, who is the named pariner in the former firm of Herman, Sloman, & Mermelstein, filed five lawsuits, each asking for $50 mil

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

c., 528 U.S. 167, 180-81 (2000); see also, e.g., Young Apartments, Inc. v. Town of Jupiter, 529 F.3d 1027, 1038 (11th Cir. 2008) (quoting Harris v. Evans, 20 F.3d 1118, 1121 (11th Cir. 1994) (en banc)). Moreover, "a plaintiff must demonstrate standing separately for each form of relief sought." Friend

07/05/2013 Page 15 of 20 Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: Dexter A. Lee Assistant United States Attorney Florida Bar No. 0936693 99 N.E. 4th Street Miami, Florida 33132 Tel: (305) 961-9320; Fax: (305) 530-7139 Email: [email protected] Eduardo 1. Sanchez Ass