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

d met with the father of one of the prospective plaintiffs, Saige Gonzalez.5 At the same time (and until as recent] as March of 2008), the Official Florida Bar websitc continued to identify Mr. as a named partner in Mr. Herman's firm. See Tab 31, Florida Bar Website page. 39. Mr. Herman, who is the named

e. When asked, the closest case suggested by the prosecutors was United Stares v. 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)

ion of a firearm, in violation of 18 U.S.C. § 922(g)(1); and sex trafficking of children in violation of 18 U.S.C. §§ 371 and 1591. United States v. Boehm, Case No. 3:04CR00003 (D. Alaska 2004). Boehm's actions, unlike Mr. Epstein's, also had a strong interstate nexus: Boehm purchased and distributed

ai lerman, had met with the father of one of the prospective plaintiffs, .5 At the same time (and until as recently as March of 2008), the Official Florida Bar website continued to identify Mr. SIM as a named partner in Mr. Herman's firm. See Tab 31, Florida Bar Website page. 39. Mr. Herman, who is the na

erest in maintaining their privacy; (6) Experience litigating in federal court in the Southern District of Florida; 2 Your letter references U.S I Boehm, No. 3:04CR00003 (D. Ala 2004) as a model for a restitution fund settlement. I asked our prosecutor to contact the AUSA in that case. In that matter

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 case: "This filing is made ex pane because Boehm, in his p

06 530 0440 fay P. Issgowitz, ESQ. DaCeectiteitt% 2007 Non 2 0P4 MECUMS Olutica glotta any past or Altura delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney scheduling is not an adequate basis for delay. Three weeks ago/ sts° asked you to provide our Office wItht

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

l chain titled Things to do in West Palm 11/4/2008 Villafafia Senior Email thanking Villafatia for her 11/3/08 email advising she spoke with the Florida Bar 11/4/2008 Correspondence from Florida Bar Ethics Counsel regarding Florida Ethics Rules involved in distributing victim notification letters 11/1

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,

3 FAX 305 630 8440 EXECUTIVE OFFICE JAY P. LEEKOWITZ, ESQ. DECEMBER 6, 2007 PACE 2 OF 4 any past or figure delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney scheduling is not an adequate basis for delay. Three weeks ago I also asked you to provide our Office with

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

Release Application; CVRA research with notes and Westlaw printouts; CVRA Research (green file folder) Jane Does v. U.S. Misc (green file folder) Florida Bar (redwell) with Self Report folder and 9/16/08 Herman Ltr to EFTA00066351 Box 5: (green file folder) Motion to Quash (file folder) Motion to Qua

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

ation; CVRA research with notes and Westlaw printouts; CVRA Research (green file folder) EFTA00194823 Jane Does I. U.S. Misc (green file folder) Florida Bar (redwell) with Self Report folder and 9/16/08 Ltr to Box E: (green file folder) Motion to Quash (file folder) Motion to Quash Riley Subpoenas (r

er handler! between It. apatdit and the victims' representatives, and that this Office should not act as intermediary. Finally, I would note that in Boehm is well, the victims' identities were net Initially disclosed. At the AUSA wrote In dint cam "This filing is made cx ante because Boehm in hit plea

8:23 PAX 305 530 8440 EXECUTIVE OFFICE JAY P. 1111KOWT7Z, Esq. Damen 6, 2007 PACE 2 OP 4 any past or future delay. Mr. Epstein eunently has four Florida Bar members on his defense team, 30 attorney scheduling is not an adequate basis for delay. Three weeks ago I also asked you to provide our Office with

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

3 FAX 305 630 8440 EXECUTIVE OFFICE JAY P. LEEKOWITZ, ESQ. DECEMBER 6, 2007 PACE 2 OF 4 any past or figure delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney scheduling is not an adequate basis for delay. Three weeks ago I also asked you to provide our Office with

ral prosecutors have pursued under the federal statutes at issue here. When asked, the closest case suggested by the prosecutors was United States v. 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 t

as recently as March of 2008), the Official Florida Bar website continued to identify Mr. Sloman as a named partner in Mr. Herman’s firm. See Tab 31, Florida Bar Website page. Mr. Herman, who is the named pariner in the former firm of Herman, Sloman, & Mermelstein, filed five lawsuits, each asking for $50 mil