Epstein Secrets

ein was taking a consistent position with the State Attorney's Office, Judge McSorley, and the USAO, so I asked for a 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

H. Willits, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, FL 33461 Re: Jeffrey Epstein/Carolyn NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Willits: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to y

00 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561)820-8711 Facsimile: (561) 820-8777 July 10, 2008 VIA FACSIMILE AND U.S. MAIL Richard H. Willits, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, FL 33461 Re: Jeffrey Epstein/Carolyn NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Willits:

, and #38 B-70 7/21/2008 Valhalla; cc: Senior Sloman Email response to Villafafia's 7/21/08 email regarding Motion for Return of Property in State Court 7/22/2008 Valhalla Kuyrkendall Email chain regarding victim addresses 7/22/2008 Emails between A. M. Villafana, A. Acosta, J. Sloman, R. Senior

Kuyrkendall, Richards Sloman Email regarding proposed response to Goldberger R - 7/10/2008 Victim Notification letters to Individuals #3 (via Richard H. Willits), #8 (via Jeffrey Herman), ##17 (via Theodore J. Leopold), #25 (via Jeffrey Herman), #26 (via Jeffrey Herman), #37 (via Michael E. Dutko), and #44

sta and instructions to direct question to Marie Villafafia and Karen Atkinson 4/8/2008 Sigal Mandelker Starr Letter - 4 pages (CEOS) 4/9/2008 Willits Villafafia Letter in response to 3/28/08 letter from Willits B • 12 4/21/2008 4/21/2008-5/9/2008 Emails between Marie Villafatia, Jeff Sloman, K

n of not only the instant claim, but for other suits filed against Defendant EPSTEIN, including but not limited to the Florida RICO claims filed in State Court. 6. As stated in the certificate, the undersigned has conferred with counsel for EPSTEIN. They take the position that this motion would be moot bec

Defendant Jeffrey Epstein Date Filed: 07/21/2008 Jury Demand: Plaintiff Nature of Suit: 360 P.I.: Other Jurisdiction: Diversity represented by Richard Horace Willits Richard H Willits PA 2290 10th Avenue North Suite 404 Lak o h FL 33461 Fax: Email: LEAD ATTORNEY TO BE NOTICED represented by Bruce Reinhar

1_0-1 10/8/2008 EFTA00175472 CM/ECF - Live Database - flsd Page 4 of 5 08/07/2008 12 r MOTION to Reassign Case TO JUDGE KENNETH MARRA by_.. (Willits, Richard) (Entered: 08/07/2008) 08/07/2008 D r MEMORANDUM in Opposition re 6 Seaainent, 7 Sealed Document TO MOTION TO STAY filed b (Willits, R

y scheduled for November I 0, 2009. 4. The parties have reached an agreement related to Jane Doe's Independent Medical Examination subject to the State Court Order attached hereto as Exhibit A. 5. Therefore, Plaintiff, Jane Doe's, Motion for Order Permitting Legal Counsel to Attend Independent Medical E

Counsel for Plaintifjs In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811

has not heard back from either of the attorneys. Additionally, the undersigned discussed the foregoing with counsel for Jane Doe this morning at a State Court hearing in Palm Beach County, Florida. Rule 7.1 Certification I hereby certify that counsel for the respective parties communicated by letters (e

served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this ~ay of ..Mfil:.., 2009 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff C.M.

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

2009 RDC Conference with JMB and Pike re: status; memo; conference with Pike re: stay 1.40 hr $700.00 03/18/2009 RDC Telephone conference with Willits and JE 0.30 hr $150.00 03/18/2009 BM Conference with ROC: conference with MJP re: adding to chart; update Deadlines 3.20 hr $400.00 Page 6 E

30, #32, and #38 7/21/2008 Villafaiia; cc: Senior Sloman Email response to Vilkfaiia's 7/21/08 email regarding Motion for Return of Property in State Court 7/22/2008 Villafaiia K tz% rkcndall Email chain regarding victim addresses 7/22/2008 Emails between A. M. Vitiate's, A. Acosta, J. Sloman, R. S

ie Villafaila regarding victim representation and filing suit against Epstein in state court 13-42 4/9/2008 Mai is Villafana letter to Richard II. Willits (formatting problem) 13-43 6/18/2008 Marie Villalana handwritten notes re calls with Brad Ed wards and Roy Black B-44 6/23/2008 John Roth letter