[GRADE A1 -- EFTA02731069 (AUSA Memorandum, December 5, 2019)]
On December 5, 2019 -- four months after Epstein's death in custody -- Assistant United States Attorneys in the Southern District of New York prepared a privileged memorandum addressed to U.S. Attorney Geoffrey S. Berman:
Subject: "Analysis of Possible Corporate Prosecution"
The memo analyzes "the feasibility of bringing criminal charges against one or more Epstein-controlled corporate entities that formally owned properties at which he abused" victims. This document confirms that federal prosecutors were actively considering charging the corporate structures themselves -- not just individuals -- for facilitating Epstein's crimes.
This is relevant to GOY-16 because:
WHAT THIS SHOWS AND DOES NOT SHOW: The memo establishes that the DOJ considered the corporate structures around Epstein's properties as potential criminal targets, not just passive holding vehicles. The 71st Street property chain -- which includes the entity that sold Lutnick his home -- was among the structures under scrutiny. This does NOT implicate Lutnick in the corporate prosecution analysis, as 11 East 71st Street (Lutnick's address) is adjacent to but distinct from 9 East 71st Street (Epstein's mansion). However, the shared property chain origins (Wexner/Epstein trusts) and the FBI's interest in the deed records place Lutnick's property acquisition within the investigative scope.