Epstein

Hello everyone — Sorry to bother you. I have a child exploitation case with a large number of victims. Defense counsel has proposed setting up a victims' rights fund, rather than having each victim sue individually. He says that this was done in a case in Alaska. Does anyone know about such a thing? And, if so, who set up the fund? The court? The parties? And did all of the victims have to consent to the procedure?

Thank you!

Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777

3153

08-80736-CV-MARRA

P-014103

EFTA00189127

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 the indictment reviewed by then as well.

Hi Drew — I tracked down the AUSA in Alaska and he is sending the trust agreement out to me. I will let you know how things go in the morning.

Thanks.

Assistant U.S. Attorney
500 S. Australian Ave. Suite 400
West Palm Beach, FL 33401
Phone 561 209-1047
Fax 561 820-8777

Final Trust.wpd

Trust Exhbit E.wpd

Trust Exhbit C.wpd

Notice and Notice of >proval of trust_foeneficiaries.wpd

Good luck.

Hi Drew — Sorry to bother you, but the plea negotiations are getting fast and furious. Epstein's lawyers are fixated on this idea of a "victim's fund" rather than having the girls file separate 2255 actions. I know that the reason they want to do it is not out of the goodness of their hearts but to keep this stuff out of the public Court files, but in some ways it will help the girls, too. Do you know anything about how the fund in Alaska was worked out? Did all the victims consent or did the Court just do it?

Thank you for your help. I also turned in the indictment package to my immediate supervisor today, so I expect some edits back from her before it goes higher up the chain. If you had any thoughts, please let me know.

Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401

3164

08-80736-CV-MARRA

P-014104

EFTA00189128

Phone 561 209-1047

Fax 561 820-8777