Epstein Secrets

xhibit B-91). On September 15, 2008, I sent Notification Letters to Individuals 18 and 32 (Exhibit B-92). Soon thereafter, I received I letter from Jeffrey Herman, one of the civil attorneys who represented I number of victims, notifying me that he had complained to the Florida Bar that the Victim Notificatio

ed 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 B-41). I responded, acknowledging his representation (Exhibit B-42). On June 18, 2008, I received I call from attorney Brad Edwards, who t

I'm assuming Counsel is not 22 asking you to divulge attorney/client 23 MR. TEIN: Of course not. 24 BY MR. TEIN: 25 Q. a are you aware that Jeffrey Herman, Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 3801316 EFTA00234261 Case 9:08-cv-8080

S.O. OF FLA. • MIAMI In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(a)(1), the defendants, Jeffrey Epstein, hereby remove this action' from Palm Beach County Circuit Court to the United States District Court for the Southern District of Florida, and respectfully state as follows: Introduction Six months ago, this pla

I'm assuming Counsel is not 22 asking you to divulge attorney/client 23 MR. TEIN: Of course not. 24 BY MR. TEIN: 25 Q. a are you aware that Jeffrey Herman, Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Sulte 500 - West Palm Beach, FL 33401 MI of 311 EFTA00180444 Case 9:08-cv-80

FLA. • MIAMI In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(a)(1), the defendants, Jeffrey Epstein, , and hereby remove this action) from Palm Beach County Circuit Court to the United States District Court for the Southern District of Florida, and respectfully state as follows: Introduction Six months ago, this pla

ney/client privilege. 21 22 asking you to divulge attorney/client -- 23 MR. TEIN: Of course not. 24 BY MR. TEIN: 25 Q. a are you aware that Jeffrey Herman, Any conversations that you and I have had MR. LEOPOLD: I'm assuming Counsel is not Ph. Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm

OTICE OF REMOVAL In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(e), the defendants, Jeffrey Epstein, , and hereby remove this action' from Palm Beach County Circuit Court to the United States District Court for the Southern District of Florida, and respectfully state as follows: Introduction Six months ago, this pla

m assuming Counsel is not 22 asking you to divulge attorney/client -- 23 MR. TEIN: Of course not. 24 BY MR. TEIN: 25 Q. a are you aware that Jeffrey Herman, Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 31 d711 EFTA00232170 Case 9:08-cv-80804-KAKI ent 1 Entered on

TICE OF REMOVAL In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(aX1), the defendants, Jeffrey Epstein, and hereby remove this action ) from Palm Beach County Circuit Court to the United States District Court for the Southern District of Florida, and respectfully state as follows: Introduction Six months ago, this pla

n Email regarding proposed response to Goldberger B 65 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 (via Jeffrey Herman) B-6

tter - 5 pages (CEOS) B-28 3/28/2008 Villafalia Danchuk Letter advising of representation of Individual #3 and that a lawsuit has been filed in Palm Beach County Circuit Court B-41 4/1/2008 Jay Lefkowitz Jeffrey Sloman Draft letter regarding termination of agreement Privileged Confidential Page 32 of 51 Contains 6(c)

xhibit B-91). On September 15, 2008, I sent Notification Letters to Individuals 18 and 32 (Exhibit B-92). Soon thereafter, I received a letter from Jeffrey Herman, one of the civil attorneys who represented a number of victims, notifying me that he had complained to the Florida Bar that the Victim Notificatio

ed a 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 B-41). I responded, acknowledging his representation (Exhibit B-42). On June 18, 2008, I liv received a call from attorney Brad ards, who