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an unlicensed money-transmitting business (18 U.S.C. § 1960), though tin never had such a business. See Tab 22, August 31, 2007 Letter from M. to Ross (reciting, in a target letter to one of Epstein's employees, that the investigation concerns "suspected violations of federal law, including but no
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
rong case ag three rsonal assistants — Adriana Ross, a/k/a " and The case was presented for federal
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
w statute should apply. See Radzanower v. Touche Ross & Co., 426 U.S. 148 (1976) ("It is a basic princ
thing. Therefore, we urge that you direct that a full and fair and complete examination of the most trustworthy evidence be ordered. 10 In U.S. v. Boehm, the defendant bought and distributed crack cocaine and cocaine to underage girls; admitted to knowing that the girls were underage; arranged for un
rson can be charged with an offense? a. How many to one calls have you been able to document between Jane Doe # 16 and Between Jane Doe # 16 and Ross? And between Jane Doe # 16 and ? 17. What was the sexual activity that Jane Doe # 16 and B3 engaged in that also violated Fl. Stat. 794.05? (Sex
ts. In addition to the well-established state restitution statute, the defense offered a federal proposal that was similar to the resolution in the Boehm case, where the conduct was far more egregious. There, the defendant bought and distributed crack cocaine and cocaine to underage girls; admitted t
ncluding but not limited to Sarah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova. Further, upon
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
Entities connected to both Wilbur Ross and Boehm

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Joe Biden
PERSON
Marc Rich
PERSON
Prince Andrew
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Eric Trump
PERSON
Department of Justice
ORGANIZATION
Bill Clinton
PERSON
Virginia Giuffre
PERSON
Lesley Groff
PERSON
Samantha Power
PERSON
Supreme Court
ORGANIZATION
Barry Diller
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION