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2.73 MB
Extraction Summary
8
People
2
Organizations
1
Locations
2
Events
3
Relationships
5
Quotes
Document Information
Type:
Legal correspondence / defense memorandum (page 5)
File Size:
2.73 MB
Summary
This document is a legal memorandum addressed to Mark Filip arguing against the federal prosecution of Jeffrey Epstein. The author cites deposition testimony from alleged victims (Miller, Beale, Gonzalez, Laduke) to claim there was no interstate coercion, that the women lied about their ages (claiming to be 18), and that the encounters were often non-sexual or consensual without force. The document also criticizes the conduct of federal prosecutors and notes a connection between a prosecutor and civil attorney Jeffrey Herman.
People (8)
| Name | Role | Context |
|---|---|---|
| Mark Filip | Recipient / Official |
Addressed as 'Honorable', likely Deputy Attorney General at the time.
|
| Jeffrey Epstein | Subject / Defendant |
Accused of sexual misconduct; defense argues he did not use interstate commerce or coercion.
|
| Tatum Miller | Witness / Alleged Victim |
Testified regarding coaching girls to lie about age and the non-sexual nature of some massages.
|
| Brittany Beale | Witness / Alleged Victim |
Testified that Epstein never tried to force her to do anything.
|
| Saige Gonzalez | Witness / Alleged Victim |
Testified Epstein never used email/text/interstate commerce before her visit.
|
| Jennifer Laduke | Witness / Alleged Victim |
Testified Epstein never touched her physically, only received massages.
|
| Carolyn | Recruiter / Associate |
Mentioned by Miller as the person who approached her and established the pattern of lying about age.
|
| Jeffrey Herman | Attorney |
Attorney for civil complainants; quoted in Palm Beach Post regarding clients lying about age.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Federal Prosecutors / Government |
Accused by the author of irregularities and improprieties in the deferred prosecution agreement.
|
|
| Palm Beach Post |
Newspaper that quoted Jeffrey Herman.
|
Timeline (2 events)
Prior to May 2008
Negotiations of a deferred prosecution agreement
Unknown
Federal Prosecutors
Epstein Defense Team
Various times
Visits to Epstein's home for massage
Epstein's residence
Locations (1)
| Location | Context |
|---|---|
|
Location where massages and alleged encounters took place.
|
Relationships (3)
Miller stated: 'I would tell my girlfriends just like Carolyn approached me.'
described as 'the former law partner of one of the federal prosecutors involved in this matter'
described as 'the attorney for most of the civil complainants'
Key Quotes (5)
"I would tell my girlfriends just like Carolyn approached me. Make sure you tell him you're 18."Source
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Quote #1
"[s]ometimes [Mr. Epstein] just wanted his feet massaged. Sometimes he just wanted a back massage."Source
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Quote #2
"never touched [her] physically"Source
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Quote #3
"it doesn't matter [that his clients lied about their ages]"Source
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Quote #4
"Not only is a federal prosecution of this matter unwarranted, but the irregularity of conduct by prosecutors... are beyond any reasonable interpretation..."Source
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Quote #5
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