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ael Tein, former counsel for Defendant, along with Mr. Jack Goldberger, who still represents Defendant, entered into a verbal agreement at the time AUSA Villafana provided the USAO List to them, whereby neither Defendant, Jeffrey Epstein, nor his agents would have any direct or indirect contact with the victi
e issues raised in this motion, and Defendant's counsel advised that Defendant opposes this motion. Date: May 22, 2009 /s/Robert C. Jose:f;sbe:rg Robert C. Josefsberg, Bar No. 040856 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. City National Bank Building 25 West Flagler Street, Suite 800 Miami, Fl
the USAO List, Defendant's counsel responded that Defendant, Jeffrey Epstein, would not contact any of undersigned counsel's clients as long as Mr. Josefsberg was representing them in connection with settlement discussions. 6. As a result, on April 17, 2009, Plaintiffs' counsel sent defense counsel a let
component was involved in the process. For example, at the end of 2006, former SDFL U.S. Attorney and EOUSA Executive Director Guy Lewis contacted AUSA Villafana when he learned that she was handling the federal investigation of Epstein. He asked to meet with her but she said that she believed such a meeting
Edward B. Davis should be that independent third-party. Ultimately, Judge Davis selected Robert C. Josefsberg of the law firm of Podhurst, Orseck, Josefsberg, et aL During this same time frame, Epstein lawyer Jay Lefkowitz sought to delay the entry of his guilty plea and sentence. After the SDFL accommod
component was involved in the process. For example, at the end of 2006, former SDFL U.S. Attorney and EOUSA Executive Director Guy Lewis contacted AUSA Villafana when he learned that she was handling the federal investigation of Epstein. He asked to meet with her but she said that she believed such a meeting
ourt Judge Edward B. should be that independent third-party. Ultimately, Judge selected Robert C. Josefsberg of the law firm of Podhurst, Orseck, Josefsberg, et aL During this same time frame, Epstein lawyer Jay Lefkowitz sought to delay the entry of his guilty plea and sentence. After the SDFL accommod
r legal positions, the risk of litigation, and the government's desire to minimize damaging impeachment evidence of its witnesses. As summarized by AUSA Villafana, the USAO-SDFL made the decision to enter the NPA out of a desire to obtain a guaranteed sentence of incarceration, the equivalent of uncontested r
strict Judge Edward B. Davis, an esteemed jurist — was assigned the task of selecting and consulting with the Epstein-paid attorney-representative, Robert C. Josefsberg, Esq., to pursue claims on behalf of the victims against Mr. Epstein under 18 U.S.C. §2255. See Letter from FAUSA Jeffrey Sloman to Hon. Edward B.
component was involved in the process. For example, at the end of 2006, former SDFL U.S. Attorney and EOUSA Executive Director Guy Lewis contacted AUSA Villafana when he learned that she was handling the federal investigation of Epstein. He asked to meet with her but she said that she believed such a meeting
court Judge Edward B. should be that independent third-party. Ultimately, Judge selected Robert C. Jose s rg of the law firm of Podhurst, Orseck, Josefsberg, et al. During this same time frame, Epstein lawyer Jay Lefkowitz sought to delay the entry of his guilty plea and sentence. After the SDFL accommo
Entities connected to both AUSA Villafana and Robert C. Josefsberg

Jeffrey Epstein
PERSONJack Goldberger
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Jay Lefkowitz
PERSON
George W. Bush
PERSONSouthern District
LOCATIONJack Scarola
PERSON
A. Marie Villafana
PERSONLeon Black
PERSONStuart S. Mermelstein
PERSONScott Rothstein
PERSON
Alan Dershowitz
PERSONthe Southern District
LOCATION
Podhurst
PERSON