Subject: Re: RE: Re:¶
Date: Wed, 14 Aug 2019 13:31:29 +0000¶
So all conduct (of any kind) related to those victims was confined to Florida?¶
Sent from my iPhone¶
On Aug 14, 2019, at 9:27 AM,¶
Thanks— these are accurate, except for #1 you’d need to add the phrase “for which we have venue” to make it accurate. We have FL victims based on tip line calls, but no basis for venue for a substantive count.¶
Sent from my iPhone¶
On Aug 14, 2019, at 9:12 AM,¶
Yup, I hear all of that. Good to know re counsel.¶
Does the following accurately state your view of our evidence, or would you want to tweak anything:¶
(1) . The only trafficking offenses that involved the Florida property for which we have evidence are those involving victims identified in the original Florida investigation.¶
(2) We do not presently have evidence of trafficking offenses involving the VI property, recognizing that the search warrant results remain unknown.¶
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On Aug 13, 2019, at 11:01 PM,¶
Really really appreciate it, thanks. One thing I think would be useful to note – this isn’t anything you don’t already know, but just to say it – is if we were able to forfeit properties, precisely what (if any) process there is available to get the proceeds of an eventual presumable sale of the properties to the victims, and any limitations on distributions to particular victims either in terms of amounts or logistics.¶
And just as a heads up from our end, we’ve talked to multiple attorneys yesterday and today who intend to file lawsuits on behalf of multiple clients, respectively, starting tomorrow (when the New York State look-back law reopens the SOL for sex crimes without limitation) and who have asked whether a Government forfeiture action would have any effect of staying, delaying, or subrogating their civil claims.¶
Sent: Tuesday, August 13, 2019 22:48¶
Subject: Fwd: Re:¶
EFTA00105422¶
Nothing for you guys to do about the below yet, but I want you guys to be aware of it. I’m going to try to manage expectations tomorrow, but you may well get pulled into the discussion.¶
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Begin forwarded message:¶
From: “Berman, Geoffrey (USANYS)” <¶
Date: August 13, 2019 at 10:36:37 PM EDT¶
Subject: Re:¶
I want a cognizable theory to pursue residences in NY, FL and VI. If you need evidence beyond what the team has let’s talk about it tomorrow.¶
On Aug 13, 2019, at 10:11 PM,¶
Either is doable by Thursday am. Just making sure I know what you need.¶
Sent from my iPhone¶
On Aug 13, 2019, at 8:52 PM, Berman, Geoffrey (USANYS)¶
I will need a summary of our forfeiture options re Epstein Thursday morning, ok? Geoff¶
EFTA00105423¶