4
Shared Docs
4
Same-Page
6 / 7
Mentions
sing the State Attorney's Office to arrest Epstein. Det. had prepared series of probable cause affidavits for the arrests of Jeffrey Epstein, and Haley Robson, charging I large number of state criminal violations. Chief had asked the Palm Beach County State Attorney, Barry to authorize the arrests and h
ts for the arrests of Jeffrey Epstein, and Haley Robson, charging I large number of state criminal viola
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
LLP FR Tr. at 6 8, 22, 45; Tab 7, Tr. 13; Tab 8 Robson Tr. at 8; Tab 9, Tr. at 5; and O, MI Tr. at 14
e. 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 to minors, in violation of 21 U.S.C. §§ 846, 84I(a)(1), and 859(a)
l 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
irls m Florida, New York and on his private island, known as Little St. James, in St. Thomas, 12. An integral player in Epstein’s Florida scheme was Haley Robson, a Palm Beach HERMAN & MERMELSTEIN, P, A. www.hermaniaw.com HOUSE_OVERSIGHT_012638 Comnmnity College student from Loxahatchee, Florida. She recmit
Florida. She recmited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein’s plan, Ms. Robson would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or someone on his behalf d
impartial, independent representative be. appointed to administer that fund. Notably, such a restitution fund was created in a federal case, U.S. v. Boehm, Case No. 3:04CR00003 (D. Alaska 2004). The federal prosecutors here rejected this idea, and they insisted that an attorney representative, paid for
telephone, computer or any other facility of interstate commerce, but rather in a face-to-face discussion with a third party who was her friend (Ms. Robson) and who told her to lie to Mr. Epstein about her age. As such, it is simply impossible to shoehorn this conduct into any of the above-discussed fe
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,
Entities connected to both Haley Robson and Boehm

Jeffrey Epstein
PERSONLeon Black
PERSON
George W. Bush
PERSON
United States
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Alan Dershowitz
PERSON
Ghislaine Maxwell
PERSON
Joe Biden
PERSON
Julie K. Brown
PERSONJack Goldberger
PERSON
Bill Clinton
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSON
Alfredo Rodriguez
PERSON
Sarah Kellen
PERSON
Marc Rich
PERSONJane Doe
PERSON
Eric Trump
PERSONFBI
ORGANIZATION