PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) MEMORANDUM TO: Geoffre S. Berman. U.S. Attorne FROM: AUSAs DATE: RE: December 5, 2019 Analysis of Possible Corporate Prosecution In connection with the investigation of Jeffrey Epstein for sex trafficking, we have been asked to analyze the feasibility of bringing criminal charges against one or more Epstein-controlled co ..rate entities that fonnall owned 'ro. dies at which he abused certain minor victims. As described herein, the well-established requirements for prosecution of a corporation are that its agent or agents committed criminal acts' while (1) acting within the scope of corporate duties, and (2) intending at least in part to benefit the corporation itself. This memorandum presumes familiarity with relevant prior case memoranda as well as the charges set forth in United States v. Jeffrey Epstein, 19 Cr. 490 (RMB), and similarly presumes that the corporate agent—Epstein himself—committed criminal acts, namely sex trafficking offenses in violation of Tide 18, United States Code, Section 1591. 1 EFTA02731069