Epstein Secrets

re. When asked, the closest case suggested by the prosecutors was United States I 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)

ral prosecutors have pursued under the federal sta tes at issue here. When asked, the closest case suggested by the prosecutors was United States I 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

rney I Member of New Jersey & Florida Bars May 10, 2007 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 VIA HAND-DELIVERY JEGE, Inc. ("JEGE') and Hyperion Air, Inc. ("Hyperion") Dear Ms. IM I write as counsel to the above noted entities to respond to the subpoenas dated April 24,

e are several emails between myself and Jay Lefkowitz about the appointment of a GAL and the possibility of a restitution trust fund similar to the Boehm case out of Alaska. I obtained the trust fund agreement and spoke with the AUSA in 21 Mandatory restitution under § 3663A requires a conviction for

itation cases was a hot-button issue at the time. The District of Alaska USAO had a multi-victim child exploitation case with a wealthy defendant (Boehm) where they had set up a trust fund with a bank and a trustee. With Drew Oosterbaan's help, I explored setting up a similar situation in the Epstein

te 8/18/06) 8/2/2006 Subpoena to Chase (return date 8/18/06) 8/2/2006 Subpoena to Hyperion Air, Inc. (return date 8/18/06) 8/2/2006 Subpoena to JEGE, Inc. (return date 8/18/06) 8/2/2006 Subpoena to David Neville Rodgers (return date 8/18/06) 8/2/2006 Subpoena to DTG Operations d/b/a Dollar Rent-a-ca

copies and 1 color copy Plea Negotiations (redwell) — folders: Non Prosecution Agreement — Final; Attorney Notes re Revised Indictment; Research re Boehm case; Research re possible misdemeanors; Notes re Plea Negotiations; Plea Agreement drafts; Draft Non Prosecution Agreements; Information Packet dra

der) Redwell with folders — Computer Search; Attorney Notes from Doc Review; Notes from FedEx Records Colonial Bank Records (redwell) with folders: JEGE, Inc.; NES, LLC EFTA00066358 Epstein Corporate Records OLY-51, OLY-52, OLY-53, OLY-54 (red folder) Colonial Bank (green file folder) JEGE & Hyperion f

copies and 1 color copy Plea Negotiations (redwell) — folders: Non Prosecution Agreement — Final; Attorney Notes re Revised Indictment; Research re Boehm case; Research re possible misdemeanors; Notes re Plea Negotiations; Plea Agreement drafts; Draft Non Prosecution Agreements; Information Packet dra

der) Redwell with folders — Computer Search; Attorney Notes from Doc Review; Notes from FedEx Records Colonial Bank Records (redwell) with folders: JEGE, Inc.; NES, LLC Epstein Corporate Records M-51,1.1-52, M-53, M-54 (red folder) Colonial Bank (green file folder) JEGE & Hyperion from M-46 & M-47 (file

impartial, independent representative be. appointed to administer that fund. Notably, such a restitution fund was created in a federal case, U.S. v. Boehm, Case No. 3:04CR00003 (D. Alaska 2004). The federal prosecutors here rejected this idea, and they insisted that an attorney representative, paid for

GUST 16, 2007 PAGE 2 OF 2 With respect fo paragraph 7, the information provided regarding the pilots came from the corporate records of Hyperion and JEGE, Inc., not NES. However, I have provided a shorter list in the new subpoena attachment. I also have enclosed another certification for the Custodian of Re

penses if the Court finds that such expenses fall within the restitution statute. Because any restitution is deducted from the agreed $1.2 million, Boehm, through his attorney Kevin Fitzgerald, has waived notice of such motion, which may be filed with the Court ex pane under seal. After 30 days from

irgin Islands Foundation, Inc. J.Epstein & Company, Inc. Epstein Interests Financial Trust company, Inc. NES, LLC New York Strategy Group, Inc. JEGE, Inc. EFTA00233918 Hyperion Air, Inc. Jeffrey Epstein would be the defendant in any lawsuit, but the other individuals are persons involved in the cri

penses if the Court finds that such expenses fall within the restitution statute. Because any restitution is deducted from the agreed $1.2 million, Boehm, through his attorney Kevin Fitzgerald, has waived notice of such motion, which may be filed with the Court ex pane under seal. After 30 days from

irgin Islands Foundation, Inc. J.Epstein & Company, Inc. Epstein Interests Financial Trust company, Inc. NES, LLC New York Strategy Group, Inc. JEGE, Inc. 2 Case No. 08-80736-CV-MARRA 000590 EFTA00233249 Hyperion Air, Inc. Jeffrey Epstein would be the defendant in any lawsuit, but the other indiv