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KIRKLAND & ELLIS LLP MMMM. at 6, 8, 22, 45; Tab 7, MEEr. 13; Tab SI Tr. at 8; Tab 9, MN Tr. at 5; and Tab 10, QJ Tr. at 14-15 (excerpts from these transcripts are included below). Furthermore, the women who visited Mr. Epstein’s home all visited voluntarily and many willingly returned several times. The State Attorney’s Office (the “SAO”) has vast experience prosecuting sex crimes and conducted an exhaustive, 15-month investigation of Mr. Epstein. A Grand Jury has concluded that Mr. Epstein was merely a local “John,” guilty of soliciting prostitution in violation of state law. Notably, Florida law distinguishes soliciting from procuring and compelling prostitution if minors are involved. Indeed, soliciting is a misdemeanor except for the commission of a third subsequent offense, turning it into a felony. The SAO, therefore, sought and obtained an indictment charging Mr. Epstein with felony solicitation of prostitution. Mr. Epstein is prepared to plead guilty and accept a sentence for that offense—a sentence that, notably, is far more severe than that meted out to other “Johns” convicted of violating Florida’s solicitation laws for cases in which sexual activity was alleged. Though CEOS points out its admirable goal of “protecting children,” a moniker that engenders high emotions, the conduct alleged here involves women over 16, which is the age of consent in 38 states and supplies the effective federal age of consent. The young women were by no means the target of high-school trolling; they were individuals who, with friends, visited Mr. Epstein’s house—a home full of friends and staff. The civil complaints filed against Mr. Epstein reiterate the fact that the individuals who visited Mr. Epstein would visit with their friends. And Mr. Epstein never spoke to or had any contact with these women before they arrived at his house. And again, the State is handling this matter appropriately. We respectfully submit that that should be the beginning and the end of this matter. As you know, the Department’s Petite Policy precludes successive federal prosecutions after a State has acted: “{A] state judgment of conviction, plea agreement [here held in abeyance solely as a result of the federal investigation], or acquittal on the merits shall be a bar to any subsequent federal prosecution for the same act or acts.” U.S.A.M. § 9-2.031A (emphasis added). Consistent with that principle, and of particular relevance to this case, the Department itself just recently observed the following: [P]rostitution-related offenses have historically been prosecuted at the state or local level. This allocation between state and Federal enforcement authority does not imply that these crimes are less serious, but rather reflects important structural allocations of responsibility between state and Federal governments.... [T]he Department is not aware of any reasons why state and local authorities are not currently able to pursue prostitution-related crimes such that Federal jurisdiction - is necessary. See Tab 11, November 9, 2007 Letter from Justice Department Principal Deputy Assistant Attorney General Brian Benczkowski to the House Committee on the Judiciary, p. 8-9. HOUSE_OVERSIGHT_012144