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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
rsey & 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, 2007, served, respectively, on
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
turn date 8/18/06) 8/2/2006 Subpoena to Capital One (return date 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
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
nc. 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 criminal activity. All of the corporat
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
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 individuals are persons involved in the criminal activity. All of the corporat
Entities connected to both Boehm and Hyperion Air, Inc.

Jeffrey Epstein
PERSONJEGE, Inc.
ORGANIZATION
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
United States
LOCATION
Marc Rich
PERSONLeon Black
PERSON
Alexander Acosta
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONGerald Lefcourt
PERSON
Martha Stewart
PERSONJack Goldberger
PERSON
Hyperion
ORGANIZATION
Ken Starr
PERSONRoy Black
PERSONNew York Strategy Group
ORGANIZATIONAnn Sanchez
PERSON
A. Marie Villafana
PERSON
Alan Dershowitz
PERSON