Epstein Secrets

9:08-cv-80811-KAM Document 35 Entered on FLSD Docket 01/07/2009 Page 7 of 7 C.M.A. v. Epstein, et al. Page 7 By: ROBERT D. RITTON, JR., ESQ. Florida Bar o. 224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 (Counsel for Def

joyment of life. (Plaintiff alleges in her Complaint, ¶2, that she is presently 21 years old. The suit was originally filed in Florida state court, Palm Beach County Circuit Court, on February 21, 2008.) Count I is lacking in sufficient factual allegations to allege the necessary elements to state a cause of action either un

l chain titled Things to do in West Palm 11/4/2008 Villafafia Senior Email thanking Villafatia for her 11/3/08 email advising she spoke with the Florida Bar 11/4/2008 Correspondence from Florida Bar Ethics Counsel regarding Florida Ethics Rules involved in distributing victim notification letters 11/1

etter - 5 pages (CEOS) B-28 3/28/2008 Villafana 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(e)

25 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100 nsor & Associates Reportiny and lranscrirrix, inc Page 48 1 Florida Bar? 2 A. I did not select him. 3 Q. Who did? 4 A. My father. 5 Q. Did you ever meet Mr. Herman? 6 A. Once. 7 Q. Don't don't tell me w

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

00175324 Case 9:08-cv-80811-KAM Document 35 Entered on FLSD Docket 01/07/2009 Page 7 of 7 v. Epstein, et al. By: ROBERT D. RITTON, JR., ESQ. Florida Bar o. 224162 rcrit@bcIcl w.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 moikeebdclaw.com BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive,

joyment of life. (Plaintiff alleges in her Complaint, ¶2, that she is presently 21 years old. The suit was originally filed in Florida state court, Palm Beach County Circuit Court, on February 21, 2008.) Count I is lacking in sufficient factual allegations to allege the necessary elements to state a cause of action either un

e 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100 nsor & Associates ReparlillS and 1.71111Gliptill11. Inc. Page 48 1 Florida Bar? 2 A. I did not select him. 3 Q. Who did? 4 A. My father. 5 6 7 8 with him. Where did you meet him? 9 10 friend's house. 11 12 13

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

06 530 0440 fay P. Issgowitz, ESQ. DaCeectiteitt% 2007 Non 2 0P4 MECUMS Olutica glotta any past or Altura delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney scheduling is not an adequate basis for delay. Three weeks ago/ sts° asked you to provide our Office wItht

position, immaterial to the present litigation, on whether Jeffrey Epstein ("Epstein") committed crimes (other than those to which he pled guilty in Palm Beach County Circuit Court). 'For example, Petitioners were repeatedly advised the Epstein lived in Palm Beach, not West Palm Beach. Even this simple correction was ignored.

intervene to move for sanctions against the victims' attorneys for making baseless allegations against Reinhart for purported violations of DOJ and Florida Bar rules. Black seeks to intervene to prevent the unsealing and use of Epstein's defense attorneys' work product, as referenced in the series of one- s

(1) no formal charge was ever filed against Epstein in the S.D.Fla.; and (2) Epstein entered pleas of guilty to state charges on June 30, 2008, in Palm Beach County Circuit Court. If the court were to find that CVRA rights did attach in the absence of a formal charge against Epstein, the government has asserted that it used

5 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100 sor & Associates [tenoning and Inniscrivinn. Inc. Page 48 1 Florida Bar? 2 A. I did not select him. 3 Q. Who did? 4 A. My father. 5 Q. Did you ever meet Mr. Herman? 6 A. Once. 7 Q. Don't -- don't tell me

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

l chain titled Things to do in West Palm 11/4/2008 Villafafia Senior Email thanking Villafatia for her 11/3/08 email advising she spoke with the Florida Bar 11/4/2008 Correspondence from Florida Bar Ethics Counsel regarding Florida Ethics Rules involved in distributing victim notification letters 11/1

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)

ter, 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 Notification Letters violated the Florida Bar rules against solicitation. He had filed complaints against myself and against Robert

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