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ion's theory of the case and the plea negotiations. 45. Mr. Thomas's calls to the USAO initiall were referred to Assistant United States Attorney David . AUSA informed Mr. Thomas that federal authorities were considering charging Mr. Epstein under 18 U.S.C. §§ 1591, 2422 and 2423, and told the r
federal charges that limited Epstein's sentencing exposure . . . " See Tab 1, May 19, 2008 Letter from . In fact, by a email dated August 3, 2007, Criminal Division Chief advised the defense that the federal government required a minimum term of two years of incarceration. See Tab 40, August 3, 2007 Email from
ile, attorney typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e)
ian Ave, Suite 400 West Palm Beach, FL 33132 FAX Case No. 08-80736-CV-MARRA P-003726 EFTA00086396 pirm—Au —evict U.S. Department et JliSrICC Criminal Division WiedlOPUM.PIAWARIIIMOORIrel The Honorable R. Alexander Acosta . United States Attorney , {r.; • • west Palm Beach, Florida 33401 Attention:
). Hawaii Man Sentenced to Over Twenty Nine Years for Extortion, Drug Trafficking, and Firearm Charges Hoodline Honolulu (09/07, Liu) reported that David Borges, a 43-year-old man from Kauai, has been sentenced to over 29 years in federal prison for extortion, drug trafficking, and firearm charges. According
ocious acts of violence, including kidnappings and murders, in Mexico," said Special Agent in Charge Reid Davis of the FBI Washington Field Office's Criminal Division in the press release. "The superseding indictment against him is the result of years of collaboration among multiple federal agencies and judicial
ile, attorney typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #9, 10, 11, 12, 13, 14 Work Product Deliberative Process 6(e) Also con
prosecution agreement" and "called a time-out." At that time, Acosta asked the Child Exploitation and Obscenity Section of the Justice Department's Criminal Division, located in Washington, D.C., to look at the case.l°6 CONCEALING THE NPA WHILE EPSTEIN SOUGHT REVIEW 92. Following the entry of the "time out," any
d AUSA cc'ing Stan Pottinger, Brad Edwards, and Sigrid McCawley (Feb. 29, 2016—Mar. 5, 2016) (Sealed) EXHIBIT M: Emails between AUSA and Chief of the Criminal Division (Mar. 3, 2016) (Sealed) EXHIBIT N: Emails between AUSA and AUSA and other AUSAs (Nov. 30, 2018—Dec. 6, 2018) (Sealed) EXHIBIT O: Email from Sta
Page: EFTA00028933 →en AUSA appeared before Judge McMahon barely four months later, however, he told her none of this, unequivocally and falsely disavowing any role by Boies Schiller in fomenting the investigation and denying any contacts between Boies Schiller and his office before November 2018. Even though AUSA had
Page: EFTA00028939 →y prosecution after a second meeting with attorneys, which took place after at least one of Maxwell's depositions. As reported in the Daily News, "David [Boles] was particularly frustrated by the failure to pursue a perjury charge.s13 "We have her dead to rights," he said.14 This Court cannot accept without
Page: EFTA00028946 →d AUSA cc'ing Stan Pottinger, Brad Edwards, and Sigrid McCawley (Feb. 29, 2016—Mar. 5, 2016) (Sealed) EXHIBIT M: Emails between AUSA and Chief of the Criminal Division (Mar. 3, 2016) (Sealed) EXHIBIT I: Emails between AUSA and AUSA and other AUSAs (Nov. 30, 2018—Dec. 6, 2018) (Sealed) EXHIBIT O: Email from Sta
Page: EFTA00029104 →en AUSA appeared before Judge McMahon barely four months later, however, he told her none of this, unequivocally and falsely disavowing any role by Boies Schiller in fomenting the investigation and denying any contacts between Boies Schiller and his office before November 2018. Even though AUSA had
Page: EFTA00029110 →y prosecution after a second meeting with attorneys, which took place after at least one of Maxwell's depositions. As reported in the Daily News, "David [Boles] was particularly frustrated by the failure to pursue a perjury charge.s13 "We have her dead to rights," he said.14 This Court cannot accept without
Page: EFTA00029117 →Entities connected to both David Boies and Criminal Division

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONSigrid McCawley
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
United States
LOCATIONthe Southern District
LOCATION
Donald Trump
PERSONLeon Black
PERSONJane Doe
PERSON
Virginia Giuffre
PERSON
Department of Justice
ORGANIZATION
Paul Cassell
PERSONSouthern District
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Alexander Acosta
PERSON
Marc Rich
PERSONMaria Farmer
PERSON