Epstein Secrets

CSIMILE Robert C. Josefsberg, Esq. Podhurst Orseck, P.A. City National Bank Building 25 West Flagler Street, Suite 800 Miami, FL 33130 Dear Mr. Josefsberg, Ceigroup Center 153 Ent 53rd Street New York. New York 10022-4611 www.lurkland corn Mardi 3, 2009 Confidential For Settlement Purposes Only

ZOO 2/004 KIRKLAND & ELLIS LLP AWft AMUATIO PARTNEIISIKPS Jay P. Lencowitz, P.C. To C I Wiitoa Dirodly: lalkow-itzekilkifindAmtm VIA FACSIMILE Robert C. Josefsberg, Esq. Podhurst Orseck, P.A. City National Bank Building 25 West Flagler Street, Suite 800 Miami, FL 33130 Dear Mr. Josefsberg, Ceigroup Center

k of suppo Mt. E ein's offer of $50,000 to resolve claims that are not time-barred (as we believe claim to be), without any On several occasions, IJSAO representatives have asserted that the government takes no position as to the claims of the individuals identified as alleged victims. For the sake

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

but based on the belief that a guardian ad litem would not be appropriate lbr adults that are capable of making their own decisions. Ilowever. the IJSAO included into the Agreement that we pay Ibr the attorney representative -- when originally Ms. Villafana stated that the representative could he paid

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

d. Needless to say. we were elisi alarmed that Ms. would attempt to influence the settlement process on such improper grounds. And even alter the IJSAO conceded that it was inappropriate for its attorneys to select the attorney representative. Ms. Villafana continued to improperly lobby for Mr. Ocar

'sduties go beyond settlement and include litigating claims for individuals. In Victims Notification lever, she states that Mr. limilturst and Mr. Josefsberg. the selected attorney representatives. may "represent" the identified individuals. This tango a •a • • at the selected representatives will agre

tified individuals, raises cause Ibr concern as to the nature of all conununications that are made to the 'victims.' You previously stated that the IJSAO's main objective with respect to the Section 2255 component of the Agreement was to -place the victims in the same position as they would have been

ies go beyond settlement and inc u elitigating claims for individuals. In Ms. s Victims Notification letter, she slates that Mr. l'odhurst and Mr. Josefsberg, the selected attorney representatives. may "repreatnt" the identified individuals. This language assumes that the selected representatives will agr

utgrowth of the fact that civil settlement. as opposed to restitution. is considered in the Agreement, A. Rule of the Attorney Representative The IJSAO has improperly emphasised that the chosen Bonney representative should be able to litigate the claims of individuals, which violates the terms, and