(USANYS) From: Sent: To: Cc: Subject: USANYS) 3 Wednesday, August 14, 2019 2:14 PM Epstein Forfeiture Options To inform our meeting at 3, below is a brief overview of my assessment of our options after discussing with the team and My bottom lines are: (1) We currently have a potentially viable action against the New York property, albeit with significant litigation risk. The team is exploring a potentially viable action against the VI property, but it will take additional investigative work. We do not have viable action against the Florida property absent further evidence. (2) A resolution with the Estate involving a victim compensation fund outside the forfeiture process would be most likely to fully compensate victims. (3) It is possible that even absent such a resolution, the victims would be better served by litigating directly against the Estate rather than our pursuing a forfeiture. Viability of Actions • New York: Based on my discussions with the team, it appears we trafficking offenses against 6 victims that involve the New York property which could potentially withstand a statute of limitations challenge: the victim referred to as -n the indictment, who was served with a grand jury subpoena in 2008 but declined to cooperate with law enforcement and was not interviewed, and five new victims who came forward in various ways after our charges were announced. o We would need to more thoroughly investigate whether the offenses against these victims could have been discovered by a reasonable investigation between the start of the Florida investigation and 2014. o The case would require the cooperation and testimony of the victims, of whom only had previously committed to testifying. Unfortunately, her counsel have already indicated that it is an open question if she would agree to testify in a forfeiture proceeding, and in my view hers is also the weakest case for SOL purposes. • Virgin Islands: The team has met with one witnes