Epstein Secrets

24 F.3d 65, 76-77 (1" Cir. 2005); United States' Brown, 43 F.3d 618, 625 (11`h Cir. 1995). The governmen

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

f an opportunity to engage in prohibited conduct. See, e.g,. United States v. Sanchez-Berrios, 424 F.3d 65, 76-77 (ls' Cir. 2005); United States v. Brown, 43 F.3d 618, 625 (11th Cir. 1995). The government cannot fairly, or consistent with the rule of lenity, advocate a broader definition of the same t

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

of an opportunity to engage in prohibited conduct. See, e.g,. United States v. Sanchez-Berrios, 424 F.3d 65, 76-77 (1" Cir. 2005); United States v. Brown, 43 F.3d 618, 625 (I1th Cu. 1995). The government cannot fairly, or consistent with the rule of lenity, advocate a broader definition of the same te

e. When asked, the closest case suggested by the prosecutors was United Stares 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, 841(a)(1), and 859(a)

ion of a firearm, in violation of 18 U.S.C. § 922(g)(1); and sex trafficking of children in violation of 18 U.S.C. §§ 371 and 1591. United States v. Boehm, Case No. 3:04CR00003 (D. Alaska 2004). Boehm's actions, unlike Mr. Epstein's, also had a strong interstate nexus: Boehm purchased and distributed

2006 Subpoena to The Dalton School (return date 9/29/09) 9/26/2006 Acosta, Mulvihill, Sloman, Noto, Waters, L°urie' Stefin, Atkinson, Garcia, Brown, Boscovich, Martinez Villafaila Memo regarding changes to Child Explotation Statutes in Tide 18 16 10/19/2006 Subpoena to Individual #28 (retu

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

-Prosecution Agreement with highlighted portions Brown file folder with 6/23/08 letter from John Roth (D

copies and 1 color copy Plea Negotiations (redwell) — folders: Non Prosecution Agreement — Final; Attorney Notes re Revised Indictment; Research re Boehm case; Research re possible misdemeanors; Notes re Plea Negotiations; Plea Agreement drafts; Draft Non Prosecution Agreements; Information Packet dra

n, the director of Victims for Justice, and Susan Brown, the Executive Director of the Alaska Violent Cr

penses if the Court finds that such expenses fall within the restitution statute. Because any restitution is deducted from the agreed $1.2 million, Boehm, through his attorney Kevin Fitzgerald, has waived notice of such motion, which may be filed with the Court ex parte under seal. After 30 days from

n, the director of Victims for Justice, and Susan Brown, the Executive Director of the Alaska Violent Cr

penses if the Court finds that such expenses fall within the restitution statute. Because any restitution is deducted from the agreed $1.2 million, Boehm, through his attorney Kevin Fitzgerald, has waived notice of such motion, which may be filed with the Court ex pane under seal. After 30 days from

n, the director of Victims for Justice, and Susan Brown, the Executive Director of the Alaska Violent Cr

penses if the Court finds that such expenses fall within the restitution statute. Because any restitution is deducted from the agreed $1.2 million, Boehm, through his attorney Kevin Fitzgerald, has waived notice of such motion, which may be filed with the Court ex pane under seal. After 30 days from

f an opportunity to engage in prohibited conduct. See, e.g,. United States v. Sanchez-Berrios, 424 F.3d 65, 76-77 (ls' Cir. 2005); United States v. Brown, 43 F.3d 618, 625 (11th Cir. 1995). The government cannot fairly, or consistent with the rule of lenity, advocate a broader definition of the same t

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