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he reason for the rejection of a Fund was because it would place an upper limit on Chicago Hang K(Ing Lgldun Los Angeles Multldl Son Francisco Washinglon,O.C. EFTA00176134 12/11/2007 11:45 FAX W/1025/099 KIRKLAND & ELLIS LLP R. Alexander Acosta December II. 2007 Page 2 the victims recovery, we
ond settlement and include litigating claims for individuals. In Ms. Villalima's Victims Notification letter, she states that Mr. I'odhurst and Mr. Josefsberg. the selected attorney representatives, may -represent- the identified individuals. This language assumes that the selected representatives will agr
nt Mr. EFTA00725563 Page 6 Sloman, was pursuing his right to review the Agreement through meetings and filings with the Department of Justice in Washington IU, a review process that did not end until June 23, 2008 just 7 days before Mr. Epstein entered his state plea. b) Plaintiff further alleges that Eps
l times informed the Plaintiffs that he reserves the right to submit disputed bills to a neutral third party, see, e.g., letter of Jay Lefkowitz to Robert Josefsberg, September 8, 2009. 4. The claims of Plaintiff contained in his Response that defendant Epstein has violated the NPA are inaccurate, irrelevant and
costa and First Assistant Mr. Sloman, was pursuing his right to review the Agreement through meetings and filings with the Department of Justice in Washington M., a review process that did not end until June 23, 2008 just 7 days before Mr. Epstein entered his state plea. b) Paintiff further alleges that Eps
l times informed the Plaintiffs that he reserves the right to submit disputed bills to a neutral third party, see, e.g., letter of Jay Lefkowitz to Robert Josefsberg, September 8, 2009. 4. The claims of Plaintiff contained in his Response that defendant Epstein has violated the NPA are inaccurate, irrelevant and
a and First Assistant Jeffrey Sloman, was pursuing his right to review the Agreement through meetings and filings with the Department of Justice in Washington M., a review process that did not end until June 23, 2008 just 7 days before Mr. Epstein entered his state plea, see eg letter of US Attorney Acosta t
l times informed the Plaintiffs that he reserves the right to submit disputed bills to a neutral third party, see, e.g., letter of Jay Lefkowitz to Robert Josefsberg, September 8, 2009. EFTA00729080 4. The claims of Plaintiff contained in his Response that defendant Epstein has violated the NPA are inaccurate,
ed States Attorney Alexander Acosta, was pursuing his right to review the Agreement through meetings and filings with the Department of Justice in Washington M., see letter appended hereto as Exhibit "A"; b) Plaintiff further alleges that Epstein was in "clear breach of the NPA" by filing a Motion to Dism
t all times informed the Plaintiffs that he reserves the right to submit disputed bills to a neutral third party, see eg letter of Jay Lefkowitz to Robert Josefsberg, September 8, 2009 4. The claims of Plaintiff contained in his Response that defendant Epstein has violated the NPA are inaccurate, irrelevant and
costa and First Assistant Mr. Sloman, was pursuing his right to review the Agreement through meetings and filings with the Department of Justice in Washington M., a review process that did not end until June 23, 2008 just 7 days before Mr. Epstein entered his state plea. b) Paintiff further alleges that Eps
l times informed the Plaintiffs that he reserves the right to submit disputed bills to a neutral third party, see, e.g., letter of Jay Lefkowitz to Robert Josefsberg, September 8, 2009. 4. The claims of Plaintiff contained in his Response that defendant Epstein has violated the NPA are inaccurate, irrelevant and
costa and First Assistant Mr. Sloman, was pursuing his right to review the Agreement through meetings and filings with the Department of Justice in Washington M., a review process that did not end until June 23, 2008 just 7 days before Mr. Epstein entered his state plea. b) Paintiff further alleges that Eps
l times informed the Plaintiffs that he reserves the right to submit disputed bills to a neutral third party, see, e.g., letter of Jay Lefkowitz to Robert Josefsberg, September 8, 2009. 4. The claims of Plaintiff contained in his Response that defendant Epstein has violated the NPA are inaccurate, irrelevant and
a and First Assistant Jeffrey Sloman, was pursuing his right to review the Agreement through meetings and filings with the Department of Justice in Washington M., a review process that did not end until June 23, 2008 just 7 days before Mr. Epstein entered his state plea, see eg letter of US Attorney Acosta t
l times informed the Plaintiffs that he reserves the right to submit disputed bills to a neutral third party, see, e.g., letter of Jay Lefkowitz to Robert Josefsberg, September 8, 2009. EFTA00729072 4. The claims of Plaintiff contained in his Response that defendant Epstein has violated the NPA are inaccurate,
costa and First Assistant Mr. Sloman, was pursuing his right to review the Agreement through meetings and filings with the Department of Justice in Washington M., a review process that did not end until June 23, 2008 just 7 days before Mr. Epstein entered his state plea. b) Paintiff further alleges that Eps
l times informed the Plaintiffs that he reserves the right to submit disputed bills to a neutral third party, see, e.g., letter of Jay Lefkowitz to Robert Josefsberg, September 8, 2009. 4. The claims of Plaintiff contained in his Response that defendant Epstein has violated the NPA are inaccurate, irrelevant and
the sex-tourism statute). within * 2255 of ide I R. Although we have been denied the Chicago Hong Kong London Los Angelus Munich San Francisco Washinglon, 0 C. RFP MIA 000041 EFTA00209087 12/21/2007 11:55 FAX v1003/008 • # . KIRKI AND & ELLIS LLP • • • R. Alexander Acosta December 21.2007
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. Josefsberg (though we hope
Entities connected to both Washington, D.C. and Robert C. Josefsberg

Jeffrey Epstein
PERSONJack Goldberger
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSONMichael J. Pike
PERSONRobert D. Critton
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSON
Podhurst Orseck
ORGANIZATION
Department of Justice
ORGANIZATION
United States
LOCATION
Jay Lefkowitz
PERSONSouthern District
LOCATIONLeon Black
PERSON
Alan Dershowitz
PERSONJack Scarola
PERSON
Salt Lake City
LOCATIONScott Rothstein
PERSON