Epstein Secrets

s New York. NY 10036 August , 2016 By E-Mail Eric Rayman Miller Korzenik Sommers Rayman LLP 488 Madison Avenue New York, New York 10022 Re: Jeffrey Epstein Dear Eric: Steptoe $TIPTOE S JOHNSON Ur As you know, our firm represents Jeffrey Epstein. I write further to our correspondence concerning the b

lous). EFTA00583736 Eric Rayman August , 2016 Page 3 Steptoe • JONNION Lir Among the cases he filed after being released was one against Mr. Epstein. Mr. Hoffenberg claimed to be suing on behalf of his own fraud victims to recover from Mr. Epstein for allegedly having conspired with Mr. Hoffenbe

88 Madison Avenue New York, New York 10022 Re: Jeffrey Epstein Dear Eric: Steptoe $TIPTOE S JOHNSON U

ses he filed after being released was one against Mr. Epstein. Mr. Hoffenberg claimed to be suing on behalf of

ued filing unsuccessful Towers Financial related litigation. See, e.g, 200,000 Towers Invirs Restitution Victims v. CI.S. ex rel. U.S. Prob. Office New York City Staff Breach of Crime Victims Act, No. 13 CIV. 8563 PKC, 2013 WL 6673612, at *2 (S.D.N.Y. Dec. 18, 2013) (Hoffenberg's counsel ordered to show cause why

8. Moreover, on the facts of this case, the Government's construction leads to an absurd result. As the Court is aware, the Government arranged for Epstein to execute his NPA on about September 24, 2007 — in secret. At that time, the victims could not "assert[] the right to be heard before or during th

ommenced within three years after the disability ceases." 28 U.S.C. § 2401(a) (2012) (emphasis added). In this case, Jane Doe No. 3 was hiding from Jeffrey Epstein and his co-conspirators in Australia from the time her claim accrued until October 2013, when she returned to the United States. See Ex. I at 3 ("I

d). In this case, Jane Doe No. 3 was hiding from Jeffrey Epstein and his co-conspirators in Australia from

tution Victims'. 7 EFTA00210675 Case 9:08-cv-80736-KAM Document 310 Entered on FLSD Docket 02/06/2015 Page 8 of 20 U.S. a reL U.S. Prob. Office New York City Staff Breach of Crime Victims Act, 2013 WL 6673612, at *2 (S.D.N.Y. 2013) ("This petition is brought pursuant to the CVRA, which does not provide for a p

on to take notes during his meetings with probation officers.° (Petition at 10-15.) The petition asserts that a non- party "multi-billionaire" named Jeffrey Epstein can "easily" provide for restitution through his "over one hundred billion dollar hedge fund" that was formed with Hoffenberg's assistance. (Petiti

at a non- party "multi-billionaire" named Jeffrey Epstein can "easily" provide for restitution through his

serts that a non- party "multi-billionaire" named Jeffrey Epstein can "easily" provide for restitution thro

& Fraade, P.C., commenced these proceedings.1 Their petition names as the sole respondent the "United States of America by the U.S. Probation Office New York City Staff." The sole claim is asserted under the Crime Victims' Rights Act ("CVRA"), 18 U.S.C. § 3771, Hoffenbcrg has been convicted of conspiracy to commit

on to take notes during his meetings with probation officers.4 (Petition at 10-15.) The petition asserts that a non- party "multi-billionaire" named Jeffrey Epstein can "easily" provide for restitution through his "over one hundred billion dollar hedge fiord" that was formed with Hoffenberg's assistance. (Petit

at a non- party "multi-billionaire" named Jeffrey Epstein can "easily" provide for restitution through his

serts that a non- party "multi-billionaire" named Jeffrey Epstein can "easily" provide for restitution thro

& Fraade, P.C., commenced these proceedings.I Their petition names as the sole respondent the "United States of America by the U.S. Probation Office New York City Staff." The sole claim is asserted under the Crime Victims' Rights Act ("CVRA"), 18 U.S.C. § 3771, I Hof enberg has been convicted of conspiracy to conun