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Jay Lefkowitz Response to email that Jenny from Judge Marra's office spoke with the Judge and he agreed to t
and Roy Black; cc: Gerald Lefcourt, John McMillan, Karen Atkinson, and Andrew Lourie . Jay Lefkowitz Response to email that Jenny from Judge Marra's office spoke with the Judge and he agreed to take the matter off the calendar. If a plea agreement is reached, USAO will withdraw the subpoena an
ceeding conducted by the Justice Department's Office of Professional Responsibility (OPR) arising out of a decision by United States District Judge Kenneth A. Marra in the matter of Jane Doe 1 and Jane Doe 2I United States, S.D. Fla. Case No. 08-80736-Civ-Marra; (3) the materials are needed to avoid an injusti
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
of the agents and myself the matter was, in fact, "currently under investigation." The NPA was signed on September 24, 2007. The letters that Judge Marra referred to in his order were dated January 10, 2008 and May 30, 2008. During the period that the letters were sent, Epstein was asserting that: (I
as signed on September 24, 2007. The letters that Judge Marra referred to in his order were dated January 10,
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
: I write to confirm my conversation with Mr. Lefkowitz of June 12, 2009. As I mentioned during that conversation and during the hearing with Judge Marra, the U.S. Attorney's Office is not a party to any of the civil suits against Mr. Epstein pending in the U.S. District Court or any state court and
ing that conversation and during the hearing with Judge Marra, the U.S. Attorney's Office is not a party to an
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,
federal prosecutorial authority. IO 08-80736-CV-MARRA RFP WPB 001653 EFTA00209832 KIRKLAND & ELLIS
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
ubx YES iN COMPLAINT O UNDER F.R.C.P. 23 complaint: JURY DEMAND: . go NO Vill. RELATED (See Instructions): (SEE ATTACHED) : CASE(S) IF ANY JUDGE KENNETH A. MARRA DOCKET NUMBER 08-CV-80119-MARRA-JOHNSON Jane Doe 2 v. Jeffrey Epstein 3-W-O*€ SIGNATURE OF ATTORNEY OF RECORD UNITED STATES DISTRICT COURT FOR OF
(SEE ATTACHED) : CASE(S) IF ANY JUDGE KENNETH A. MARRA DOCKET NUMBER 08-CV-80119-MARRA-JOHNSON Jane Doe
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
vernment, and openings are set 2724 08-80736-CV-MARRA REP WPB-002020 EFTA00184828 Case 9:08-cv-8073
erest in maintaining their privacy; (6) Experience litigating in federal court in the Southern District of Florida; 2 Your letter references U.S I Boehm, No. 3:04CR00003 (D. Ala 2004) as a model for a restitution fund settlement. I asked our prosecutor to contact the AUSA in that case. In that matter
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 case: "This filing is made ex pane because Boehm, in his p
: I write to confirm my conversation with Mr. Lefkowitz of June 12, 2009. As I mentioned during that conversation and during the hearing with Judge Marra, the U.S. Attorney's Office is not a party to any of the civil suits against Mr. Epstein pending in the U.S. District Court or any state court and
ing that conversation and during the hearing with Judge Marra, the U.S. Attorney's Office is not a party to an
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
ents with notes White binder labeled Leap YearJ Marra Issue with notes and opinion and filed documents
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
561 209-1047 Fax 561 820-8777 3153 08-80736-CV-MARRA P-014103 EFTA00189127 From: Sent: Thursday.
eptember 13, 2007 7:54 PM ToPIPISMINISUMNIIIIMINIMISIOAFLS) Subject: RE: Epstein ■ Thanks for the information, Marie. I'll get the details on the Boehm arrangements from the prosecutors and get back to you tomorrow. I believe the girls agreed to the arrangement, but I'll confirm that. I should have
nts with notes White binder labeled Leap Year J Marra Issue with notes and opinion and filed documents
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
Entities connected to both Kenneth Marra and Boehm

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
A. Marie Villafana
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATIONLeon Black
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Jay Lefkowitz
PERSONRoy Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSONFBI
ORGANIZATION