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no position as to the validity of any such claim under this statute," should be included in any proposed letter. Sixth, your letter states that Mr. Podhurst and Mr. Josefsberg may "represent" the identified individuals. Since we have not yet had the opportunity to speak with Mr. Podhurst or Mr. Josefsbe
nsensual: she lied to Mr.. Epstein about her age: she instructed others to lie about their ages: there was no sexual contact between herself and Mr. Lipstein at any lime; and there was never any inducement over the telephone, computer or through any other means of interstate commerce We ask that you cons
ent and has been sentenced. Upon the execution of this agreement. the United States. in consultation with und subject to the good faith approval of Lipstein's counsel. shall .elect an attorney representative for these persons. who shall be paid fin by Ipsteiti. tostein's counsel may contact the identifie
36-CV-MARRA P-013349 EFTA00230254 JAY P. LEFKOWITZ, ESQ. NOVEMBER 30, 2007 PAGE 7 OF 7 The letter's assertions regarding representation by the Podhurst firm and Mr. Josefsberg are accurate and will not be changed. Judge Davis conferred with Messrs. Podhurst and Josefsberg to insure their willingnes
udge Edward B. Davis should be that independent third-party/special master. Ultimately, Judge Davis selected Robert C. Josefsberg of the law firm of Podhurst, Orseck, Josefsberg, et at 10 During this same time frame, Epstein lawyer Jay Lefkowitz sought to delay the entry of his guilty plea and sentence. A
nsensual: she lied to Mr.. Epstein about her age; she instructed others to lie about their ages: there was no sexual contact between herself and Mr. Lipstein at any time; and them was never any inducement over the telephone, computer or through any other means of interstate commerce We ask that you consi
andle the case pro bono, with no financial benefit even to himself. Furthermore, you were given several other options to choose from, including the Podhurst firm, which was later selected by Judge Davis. You rejected those other options. You also allege that I improperly disclosed information about the
ch and every term of Mr. Epstein's State plea, including the exact state charges to which Mr. Epstein plead guilty; the time-frame within which Mr. Lipstein must enter that state pica and surrender to state olficials; and the amount of time he must spend in county jail. This is particularly true where th
gainst Mr. Epstein. The initial draft victim notification law contained language that confirmed your Office's interpretation and indicated that Mr. Podhurst and Mr. Josershrog, the selected attorney representatives. may "represent" the identified individuals. This language assumes that the selected repre
list of persons who seek reimbursement and make a good faith showing to the Tomei: that they suffered injury as a result of the conduct of Epstein. Lipstein waives his right to contest liability ur damages up to an amount agreed to by Ilse panics for any settlements entered into by the Trustee. Eivaenrs
andle the case pro bono, with no financial benefit even to himself. Furthermore, you were given several other options to choose from, including the Podhurst firm, which was later selected by . You rejected those other options. You also allege that I improperly disclosed information about the case to Mr
and that ease has since been distinguished as well. B. Ms. Prompted An Unduh• Invasive lInvestiention Of Mr. Epstein. Ms. s investigation of Mr. Lipstein raises serious questions. Despite the fact that she was mac aware of the inaccuracies in the P131'lis Probable Cause Affidavit, she chose to includ
ng our meeting last Wednesday, November 21", you and Professor Dershowitz seemed very comfortable, and certainly not surprised, with the selection. Podhurst and Josephsberg are no strangers tuarly the entire Epstein defense team including Guy Lewis, Lill.. Sanchez, Roy Black, and, apparently, Professor
elements of this offense. His assertion raises for me substantial concerns. This Off= will not, and cannot, be a party to an agreement in which, Mr. Lipstein pleads guilty to an offense that he believes he did not commit. We are considering how best to proceed. 2 X1003 US_Atty_Cor_00273 EFTA00235599
g our meeting last Wednesday, November 21th, you and Professor Dershowitz seemed very comfortable, and certainly not surprised, with the selection. Podhurst and Josephsberg are no strangers to nearly the entire Epstein defense team including Guy Lewis, Lili Ann Sanchez, Roy Black, and, apparently, Profe
comnsual; she lied to Mr.. Epstein about her age: she instructed others to lie about their ages: there was no sexual contact between herself and Mr. Lipstein at any lime; and there was never any inducement over the telephone, computer or through any other means of interstate commerce We ask that you cons
Entities connected to both Podhurst and Lipstein

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONRobert C. Josefsberg
PERSON
Department of Justice
ORGANIZATION
Jay Lefkowitz
PERSON
United States
LOCATIONJack Goldberger
PERSONLeon Black
PERSONthe Southern District
LOCATION
Podhurst Orseck
ORGANIZATIONRoy Black
PERSON
A. Marie Villafana
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSON
Jeffrey Sloman
PERSON
Ken Starr
PERSON
Alan Dershowitz
PERSON
Palm Beach County
LOCATIONSandra K. McSorley
PERSONKirkland & Ellis LLP
ORGANIZATION