Epstein Secrets

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)"

Kenneth W. Starr Kirkland & Ellis LLP m South Figueroa Street Los Angel oo Phone• May 19, 2008 Joe D. Whitley Alston & Bird LLP The Atlan i it 'n VIA FACSIMILE - CONFIDENTIAL

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

KIRKLAND & ELLIS LLP SUBMISSION TO THE OFFICE OF THE DEPUTY ATTORNEY GENERAL IN THE MATTER OF JEFFREY E. EPSTEIN Jeffrey Epstein, a successful businessman and noted ph

ulation). Rather, its reach is limited to sex trafficking that involves children or is accomplished by force, fraud, or coercion". United States v. Evans, 476 F.3d 1176, 1179 n. 1 (11* Cir. 2007). Nor, has the Department of Justice deemed it appropriate. See, e.g. United States Department of Justice C

. Alexander Acosta Gerald Lefcourt Roy Black FOWLER WHITE BURNETT P.A. EFTA00310836 MAY 14, 2008 - FROM THE DEFENSE TO THE GOVT EFTA00310837 KIRKLAND & ELLIS LLP Kenneth W. Starr To Call Writer Directly-. VIA FACSIMILE AND AMMO PARTNUtSkun Los Angeles. California 90017 www.kirkland.COM May 14, 2008 Hon

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)

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CONFIDENTIAL SUBMISSION TO THE OFFICE OF THE DEPUTY ATTORNEY GENERAL RE J. EPSTEIN HOUSE_OVERSIGHT_012135 --- PAGE BREAK --- KIRKLAND & ELLIS LLP AND AFFILIATED PARTNERSHIPS 777 South Figueroa Street Los Angeles, California 90017 Kenneth W. Starr : To Call Writer Directly: FP Facsimile: www

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

Kenneth W. Starr Joe D. Whitley Kirkland & Ellis LLP Alston & Bird LLP 777 South Figueroa Street The Atlantic Building Los Angeles, CA 90017-5800 950 F Street, NW Washington, DC 20004-1404 May 19, 200

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)”

Kenneth W. Starr Joe D. Whitley Kirkland & Ellis LLP Alston & Bird LLP 777 South Figueroa Street The Atlantic Building Los Angeles, CA 90017-5800 950 F Street, NW a = DC _ May 19, 2008 VIA FACSIMILE C

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)”

Kenneth W., Starr Joe D, Whitley Kirkland & Ellis LLP Alston & Bird LLP 777 South Figueroa Street The Atlantic Building Los Angeles, CA 90017-5800 050 F Street, NW Phone: 213-680-8440 ~ Washington, DC 20

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}’

KIRKLAND & ELLIS LLP SUBMISSION TO THE OFFICE OF THE DEPUTY ATTORNEY GENERAL IN THE MATTER OF JEFFREY E. EPSTEIN Jeffrey Epstein, a successful businessman and noted ph

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