Epstein Secrets

West Palm Beach, FL 33401 561-202-6360 Fax: 561-828-0983 [email protected] Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 561-684-6500 Fax: 561-515-2610 Counsel for Plaintiff in Relate

rah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite

ets to establish a fund with which to satisfy a potential judgment for money damages is not an appropriate exercise of a federal district court's 1 The Eleventh Circuit in Rosen "rejected appellees' suggestion that they successfully invoked the district court's equitable jurisdiction through their requests for any a

whether he had an "egg- shaped" penis became a youtube.com sensation. It first appeared on The Palm Beach Post Web site. Craton blamed attorney Spencer Kuvin for releas- ing it. Kuvin said it was public record. The civil suits began mounting after Epstein agreed to plead guilty to two state charges: p

enis became a youtube.com sensation. It first appeared on The Palm Beach Post Web site. Craton blamed attorney Spencer Kuvin for releas- ing it. Kuvin said it was public record. The civil suits began mounting after Epstein agreed to plead guilty to two state charges: procur- ing a minor for pro

ur Office prevails on that issue, the victims would obviously have no claim under the CVRA. The victims would then pursue their appellate rights in the Eleventh Circuit. If, however, the victims prevail on that issue, then your Office would take "no position" on the remedy sought by the victims for the violation of

To: Co: Subject: Ann Merle our two client names ere. 2. Ted Leopold tTleopokkanechaw.00mi Thuriutny, Jul.008 4:28 PM Villafana, Ann (USAPL8) Spencer Kuvin RØ; Epstein Investigation If you need any other trtformstion please lel me know. Ted i € -,---Ortglnal Message— From: VIllefena, Ann C. (UgAR

ul.008 4:28 PM Villafana, Ann (USAPL8) Spencer Kuvin RØ; Epstein Investigation If you need any other

tions to the victims — and having induced reliance by the victims — the Government is stopped from taking a different position now. As explained by the Eleventh Circuit, to make out a claim of estoppel against the Government, a party must adduce evidence of the following: (1) words, conduct, or acquiescence that in

hether he had an "egg- shaped" penis became a youttibe.com sensation. It first appeared on The Palm Beath Post Web site. Critton blamed attorney Spencer Kuvin for releas- ing it. Kuvin said it was public record. The civil suits began mounting after Epstein agreed to plead guilty to two state charges: p

is became a youttibe.com sensation. It first appeared on The Palm Beath Post Web site. Critton blamed attorney Spencer Kuvin for releas- ing it. Kuvin said it was public record. The civil suits began mounting after Epstein agreed to plead guilty to two state charges: procur- ing a minor for pro

ur Office prevails on that issue, the victims would obviously have no claim under the CVRA. The victims would then pursue their appellate rights in the Eleventh Circuit. If, however, the victims prevail on that issue, then your Office would take "no position" on the remedy sought by the victims for the violation of

ida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (56!) 820-8777 August 4, 2009 VIA ELECTRONIC MAIL Spencer T. Kuvin, Esq. Leopold—Kuvin, P.A. Re: Jeffrey Epstein/B.B. — Requested Disclosure of Non-Prosecution Agreement Dear Mr. Kuvin: Thank you for your letter

ELECTRONIC MAIL Spencer T. Kuvin, Esq. Leopold—Kuvin, P.A. Re: Jeffrey Epstein/B.B. — Requested Disclosure of Non-Prosecution Agreement Dear Mr. Kuvin: Thank you for your letter regarding the disclosure of the Non-Prosecution Agreement signed by Jeffrey Epstein. I understand that you are asking fo

009 WL 2567831, fn. I (E.D. Cal. Aug. 18, 2009). U.S.' Zane, 2009 WL 2567832, fn.l (E.D. Cal. Aug. 18 2009). As to the meaning of "actual damages," the Eleventh Circuit in McMillian i t F.D.I.C., 81 F.3d 1041, 1055 (I I th Cir.1996)3, succinctly explained: 3 In McMillian the I 1th Circuit was faced with the task of

2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 Re: Jeffrey Epstein/B.B. — Requested Disclosure of Non-Prosecution Agreement Dear Mr. Kuvin: Thank you for your letter regarding the disclosure of the Non-Prosecution Agreement signed by Jeffrey Epstein. I understand that you are asking fo

L/slm I Decisions of the United States Court of Appeals for the Fifth Circuit handed down prior to September 30, 1981, are binding as precedent in the Eleventh Circuit, Sag Bonner v. City of Prichard, Ala., 661 F.2d 1206, 1207 (11th Cir. 1981). K&E 19439748.2 EFTA00193952 EFTA00193953