Justice Alito
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EFTA00013811.pdf
This document is a legal submission by Kirkland & Ellis LLP to the Deputy Attorney General arguing against federal prosecution of Jeffrey Epstein in circa 2008. The defense argues that Epstein's conduct amounts to state-level solicitation of prostitution rather than federal sex trafficking or sex tourism, citing recent Supreme Court decisions to advocate for a narrow interpretation of federal statutes. The text asserts that Epstein did not target minors, did not use interstate commerce to lure victims, and that any underage women lied about their age.
HOUSE_OVERSIGHT_012148.jpg
This page from a Kirkland & Ellis legal memorandum argues that Jeffrey Epstein cannot be convicted under 18 U.S.C. ยง 2422(b) for using interstate commerce (telephones) to induce minors because the calls were merely for scheduling ('are you available') and did not contain explicit solicitations. The defense contends that any alleged sexual activity was spontaneous and occurred face-to-face after the call, meaning the 'plain language' of the statute regarding the use of a facility of interstate commerce was not violated. The document cites *Santos* and *Cuellar* to support the argument that the statute requires the criminal intent and conduct to occur during the communication itself.
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