Epstein Secrets

ss Hearing on Jane Doe 0.90 hr $270.00 03/26/2009 BM Pull and copy Exhibits to attach to State Court Motions to Stay; fax Motions to counsel in State Court cases; scan and pdf Motion to Stay in Jane Doe case; file 3.25 hr $406.25 Motion electronically with Clerk; e-mail from Clerk; print docketed atta

re: scheduling depositions; calls from Mermelsteln; receipt of fax from Mermelsteln; call from 1.90 hr $237.50 Edwards; calls from Jack Hill and Richard Willits; coordinate dates of availability; conference with RDC; send letters with return envelopes to Judges 03/16/2009 MJP Research and analysis of law

ein was taking I consistent position with the State Attorney's Office, Judge McSorley, and the USAO, so I asked for I copy of what was filed in the State Court. This led to multiple letters with counsel for Epstein before I could finalize the victim notification letters (Exhibits B-57 through B-65). On July

id not receive any victim calls during this time. I did receive communications from two attorneys. In March 2008, I received I letter from attorney Richard Willits, advising me that he represented Individual #3 and that he had filed suit on her behalf against Epstein in Palm Beach County Circuit Court (Exhibit

arties to this litigation Box #2 P-008299 Thru P-008363 File folder entitled "FINAL AGREEMENTS" containing subfolder entitled "Agrmts Filed in State Court" (P-008300-P-008327 [not being withheld as privileged — have been produced to opposing counsel]); signed Non-Prosecution Agreement, Addendum, and

6 criminal prosecution. 7 MR. JOSEFSBERG: I agree, Your Honor. 8 THE COURT: Any other plaintiff's counsel want to 9 chime in? 10 MR. WILLITS: Richard Willits on behalf of C.M.A.. I 11 would join, to weigh in on what Mr. Josefsberg said. 12 MR. JOSEFSBERG: Your Honor, I could not hear. 13 THE COURT: We