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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
her in touch with his attorney, Jack Goldberger; and Goldberger had his friend, Jim Eisenberg, serve as Individual #28's lawyer while Epstein paid Eisenberg's fees. Individual #28 later told Brad Edwards that someone (Epstein, Goldberger, or Eisenberg) told her that "the government" planned to take away
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
the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States'. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983) (citing United States'. Procter & Gamble Co., 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained i
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
Menchel with attached letter containing counter- proposal for plea to two years of 'supenised custody.' 9 8/24/2006- 10/24/2006 Entails betweenJim Eisenberg and Marie Villafana regarding #28 10 10/30/2006- 10/31-2006 Emails between Marie Vitt:liana and Guy Lewis regarding Lewis respresentation of Eps
Entities connected to both Boehm and James Eisenberg

Jeffrey Epstein
PERSON
United States
LOCATION
George W. Bush
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSONthe Southern District
LOCATION
Bradley Edwards
PERSON
Alexander Acosta
PERSON
Scarlett Johansson
PERSONFBI
ORGANIZATIONJack Goldberger
PERSONLeon Black
PERSON
Jay Lefkowitz
PERSON
A. Marie Villafana
PERSON
Ken Starr
PERSON
Paul Cassell
PERSON
Southern District of New York
ORGANIZATIONGerald Lefcourt
PERSON
Barry Diller
PERSON