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e are several emails between myself and Jay Lefkowitz about the appointment of I GAL and the possibility of I restitution trust fund similar to the Boehm case out of Alaska. I obtained the trust fund agreement and spoke with the in Alaska. The trust fund a reement was very complex and required I bank
tation cases was I hot-button issue at the time. The District of Alaska USAO had multi-victim child exploitation case with I wealthy % defendant (Boehm) where they had set u trust fund with I bank and I trustee. With Drew help, I ex lored setting up I similar situation in the Epstein case (Exhibit
ein was taking I consistent position with the State Attorney's Office, Judge McSorley, and the USAO, so I asked for I copy of what was filed in the State Court. This led to multiple letters with counsel for Epstein before I could finalize the victim notification letters (Exhibits B-57 through B-65). On July
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
30, #32, and #38 7/21/2008 Villafaiia; cc: Senior Sloman Email response to Vilkfaiia's 7/21/08 email regarding Motion for Return of Property in State Court 7/22/2008 Villafaiia K tz% rkcndall Email chain regarding victim addresses 7/22/2008 Emails between A. M. Vitiate's, A. Acosta, J. Sloman, R. S
ter handled between Mr. Epstein and the victims' representatives, and that this Office should not act as intermediary. Finally, I would note that in Boehm as well, the victims' identities were not initially disclosed. As the AUSA wrote in that cast "This filing is made cx parte because Boehm, in his p
terest in maintaining their privacy; (6) Experience litigating in federal court in the Southern District of Florida; Your lent,. references U.S. v Boehm, No. 3:04CR00003 (D. Ala 2004) as a model for a restitution fund statement I asked our prosecutor to contact the AUSA in that case. In that matter,
ment available to the victims, the United States sought to confirm that counsel for Mr. Epstein had filed the complete Agreement under seal with the State Court at the time of the entry of his guilty plea to the State charges, to insure that an exact copy of that Agreement would be provided in this case, sh
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
Ltr to folder, CVs from folder, Signed Protective Orders folder EFTA00194838 Box DD: White Box 2 Redwell Final Agreements with Agrmts Filed in State Court folder, 12/19/07 Ltr folder Loose Papers: Flight Manifest 11/26/08 email M= to , 7/3/08 email to 12/6/07 Letter to a 12/6/07 Draft Victim Not
interest in maintaining their privacy; (6) Experience litigating in federal court in the Southern District of Florida; Your letter references U.& 'Boehm, No. 3:04CR00003 (D. Ala 2004) as a model for a restitution fund statement I asked our prosecutor to contact the AlffiA in that case. In that matter
ment available to the victims, the United States sought to confirm that counsel for Mr. Epstein had filed the complete Agreement under seal with the State Court at the time of the entry of his guilty plea to the State charges, to insure that an exact copy of that Agreement would be provided in this case, sh
Entities connected to both Boehm and State Court

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSONthe Southern District
LOCATION
United States
LOCATION
Kenneth Marra
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
Ken Starr
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONLeon Black
PERSON
A. Marie Villafana
PERSONGerald Lefcourt
PERSON
Alan Dershowitz
PERSON
Jay Lefkowitz
PERSONRoy Black
PERSONAnn Sanchez
PERSON
Jeffrey Sloman
PERSON
Palm Beach County
LOCATION