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of their official duties. A. The Nature of the Litigation Our client, Jane Doe, alleges that Jeffrey Epstein repeatedly sexually abused her in his Upper East side mansion beginning around 2002, when Doe was only fourteen years old, until approximately 2005. See Complaint in Doe v. Indyke et al., No. 19-cv
e's litigation and corroborative of her claims. Specifically, we understand that our client has had repeated interactions with the U.S. Attorney's Office for the Southern District of New York (the "Office") and with the Federal Bureau of Investigation ("FBI") over the course of the past fifteen years. Doe was first contacted by the FBI a
tein could provide her with some advantage in gaining entrance to an institution of higher learning and because she was given living quarters on the Upper East Side of Manhattan, the use of a car service and a cell phone. These factual allegations do not demonstrate that she was a victim of fraud, much les
e reasons explained above, Plaintiff fails to state a violation of Section 1594(a). Stein v. World-Wide Plumbing Supply Inc., 71 F.Supp.3d 320, 330 (E.D.N.Y. 2014) ("a claim of attempt requires plaintiff to allege that defendants had the intent to commit 17 EFTA00307114 the underlying crime"). As disc
they were moving to seize Mt Epstein's townhouse. Mr. Epstein, however, was not even supposed to become the owner of the opulent stone house on the Upper East Side. In 1989, Mr. Epstein's mentor, Leslie H. Wexner, the founder and chairman of L Brands, the parent company of Victoria's Secret and Bath & Bo
or girls experienced horrible sexual abuse and rape in Florida. But then Epstein was given a slap-on- the-wrist deal in 2008 from the U.S. Attorney's Office for the Southern District of Florida and some of his co- conspirators were shielded from prosecution. To make matters even worse, that deal seems to have been the product of
Entities connected to both Upper East and Southern District of New York

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Alexander Acosta
PERSON
Kenneth Marra
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Bradley Edwards
PERSONJane Doe
PERSONJack Goldberger
PERSON
George W. Bush
PERSONSouthern District
LOCATION
New York
LOCATION
Scarlett Johansson
PERSON
Alan Dershowitz
PERSON
Julie K. Brown
PERSON
Lesley Groff
PERSON