Epstein Secrets

vised Mr. Josefsberg in writing that he and Mr. Epstein would meet with Mr. Josefsberg on two occasions between now and March 1, 2010 to review Mr. Josefsberg's outstanding bills on a line-by-line basis and attempt to reach a non- adversarial resolution of all outstanding fee issues. Mr. Critton also transm

costs properly owed to him by Mr. Epstein pursuant to the NPA. On February 16, 2010 Mr. Epstein's principal civil counsel Bob Critton advised Mr. Josefsberg in writing that he and Mr. Epstein would meet with Mr. Josefsberg on two occasions between now and March 1, 2010 to review Mr. Josefsberg's outstan

ot be a breach of the Non-Prosecution Agreement. Furthermore, as to the first item, your colleagues admitted that efforts to reach an agreement with Robert Josefsberg regarding the amount of fees owed have not been completed. Similarly, as to the second itur colleagues admitted that there are no currently pendin

Plaintiff's action should be dismissed and she should be required to plead her action under the applicable version of 18 §2255. 22 EFTA00183862 Motion For More Definite Statement and To Strike, Rule 12(e) and (f), As noted above, Plaintiff alleges that she was 17 year old high school student as of January, 2004, and that the

being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this day of , 2010. Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 Counsel for Plaintiff Jack Alan Goldberg

iff's action should be dismissed and she should be required to plead her action under the applicable version of 18 U.S.C. §2255. 22 EFTA00207745 Motion For More Definite Statement and To Strike. Rule 12(e) and (f). F.R.C.P. As noted above, Plaintiff alleges that she was 17 year old high school student as of January, 2004, and

pley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Counsel for Plaintiff, Counsel for Plaintiff in Related Case No. 08- 80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Hagler Street, Suite 800 130 EFTA00182754 Case 9:08-cv-80119-KAM Document 152 E

nt between the parties is properly the subject of Defendant's Motion to Dismiss First Amended Complaint For Failure to State a Cause of Action, and Motion For More Definite Statement; Motion to Strike, and Supporting Memorandum of Law (D.E. 47) which is currently pending before this Court. 5. In the event that the Court rules t