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

terest in maintaining their privacy; (6) Experience litigating in federal court in the Southern District of Florida; 2 Your letter references US v 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 ease• "This filing is made ex pane because Boehm, in his p

te that in Boom as well, the victims' identities were not initially disclosed. As the AUSA wrote in that case: "This filing is made cx pane because Boehm, in his plea agreement, waived any rights he had pertaining to the selection of beneficiaries and the disbursement of funds to such beneficiaries."

erest in maintaining their privacy; (6) Experience litigating in federal court in the Southern District of Florida; ' Your letter references U.S v Boehm, No. 3:04CR00003 Ala 2004) as a model for a restitution fund settlement. I asked our prosecutor to contact the ALMA in that case, In that matter, t

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,

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 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 exparte because Boehm, in his p

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 ease• "This filing is made ex pane because Boehm, in his p

terest in maintaining their privacy; (6) Experience litigating in federal court in the Southern District of Florida; 2 Your letter references US v 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

erest in maintaining their privacy; (6) Experience litigating in federal court in the Southern District of Florida; 2 Your letter references US. 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 ease• "This filing is made ex pane because Boehm, in his p

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

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

at in that case as well, the victim's identities were not initially disclosed. As that AUSA wrote in that case: "This filing is made ex pane because Boehm, in his plea agreement, waived any rights he had pertaining to the selection of beneficiaries and the disbursement of funds to such beneficiaries.

ey may choose to walk away, they may choose to settle, or they may choose to sue. It should be the victims' choice.- 2 Your letter references U.S. '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 parte because Boehm, in his

rest 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 ease• "This filing is made ex pane because Boehm, in his p

terest in maintaining their privacy; (6) Experience litigating in federal court in the Southern District of Florida; 2 Your letter references US v 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

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

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

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

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)

n impartial, independent representative be appointed to administer that fund. Notably, such a restitution fund was created in a federal case, US. v. Boehm, Case No. 3:04CR00003 (D. Alaska 2004). The federal prosecutors here rejected this idea, and they insisted that an attorney representative, paid fo

est in maintaining their privacy: (6) Experience litigating in federal court in the Southern District of Florida; ' Your letter refaitinces U.S. v Boehm, No. 3:04CR00003 (D. Ala 2004) as a model for a restitution fund sealement I asked ow prosecutor to contact the AOSA in that ease. In that matter, t

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

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

an impartial, independent representative be appoinied to administer that fund. Notably, such a restitution fund was created in a federal case, US. 1 Boehm, Case No. 3:04CR00003 (D. Alaska 2004). The federal prosecutors here rejected this idea, and they insisted that an attorney representative, paid fo