Attorney cites flight logs and RICO claim in Jane Doe vs. Epstein litigation; mentions Rothstein Ponzi victim notice

necessary because: (a) Jane Doe filed a federal RICO claim against Epstein that was an active claim through much of the litigation. The RICO claim alleged that Epstein ran an expansive criminal enterprise that involved and depended upon his plane travel. Although Judge Marra dismissed the RICO claim at some point in the federal litigation, the legal team representing my clients intended to pursue an appeal of that dismissal. Moreover, all of the subjects mentioned in the RICO claim remained relevant to other aspects of Jane Doe’s claims against Epstein, including in particular her claim for punitive damages; (b) Jane Doe also filed and was proceeding to trial on a federal claim under 18 U.S.C. § 2255. Section 2255 is a federal statute which (unlike other state statutes) guaranteed a minimum level of recovery for Jane Doe. Proceeding under the statute, however, required a “federal nexus” to the sexual assaults. Jane Doe had two grounds on which to argue that such a nexus existed to her abuse by Epstein: first, his use of the telephone to arrange for girls to be abused; and, second, his travel on planes in interstate commerce. During the course of the litigation, | anticipated that Epstein would argue that Jane Dee’s proof of the federal nexus was inadequate. These fears were realized when Epstein filed a summary judgment motion raising this argument. In respo-nse, the other attorneys and I representing Jane Doe used the flight log evidence to respond to Epstein’s summary judgment motion, explaining that the flight logs demonstrated that Epstein had traveled in interstate commerce for the purpose of facilitating his sexual assaults. Because Epstein chose to settle the case before trial, Judge Marra did not rule on the summary judgment motion. (c) Jane Doe No. 102’s complaint outlined Epstein’s daily sexual exploitation and abuse of underage minors as young as 12 years old and alleged that he used his plane to transport underage females to be sexually abused by him and his friends. The flight logs accordingly might have information about either additional girls who were victims of Epstein’s abuse or friends of Epstein who may have witnessed or even participated in the abuse. Based on this information, 1 believed that the flight logs and related information was relevant information to prove the cases against Jeffrey Epstein and accordingly I pursued them in discovery. 20. In approximately November 2009, the existence of Scott Rothstein’s Ponzi scheme became public knowledge. It was at that time that I, along with many other reputable attorneys at RRA, first became aware of Rothstein criminal scheme. At that time, I left RRA with several other RRA attorneys to form the law firm of Farmer Jaffe Weissing Edwards Fistos and Lehrman (“Farmer Jaffe”). I was thus with RRA for less than one year. 21. In July 2010, along with other attorneys at Farmer Jaffe and Professor Cassell, I reached favorable settlement terms for my three clients L.M., E.W., and Jane Doe in their lawsuits against Epstein. 22. On July 26, 2010, I received a letter from the U.S. Attorney’s Office for the Southern District of Florida — the office responsible for prosecuting Rothstein’s Ponzi scheme. The letter indicated that law enforcement agencies had determined that I was “a victim (or potential victim)” of Scott Rothstein’s federal crimes. The letter informed me of my rights as a victim of Rothstein’s federal crimes and promised to keep me informed about HOUSE_OVERSIGHT_013368