Epstein Secrets

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 305 358-2800 Fax: 305 58-2382 josefsber

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

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

of the offense (e.g., 2004-5) govern the minimum statutory damage amount (t50,000 rather than $150,000) under ex post facto laws, see United States I. Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)? Black,

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

009); Doe No. 4'. Epstein 2009 WL 383286 (S.D. Fla. Feb. 12, 2009); and Poe No. 51. Epstein 2009 WL 383383 (S.D. Fla. Feb. 12, 2009); see also U.S. I. Scheidt, Slip Copy, 2010 WL 144837, fn. 1 (E.D.Cal. Jan. 11, 2010); U.S. I. Rain, 2009 WL 2579103, fn. 1 (ED. Cal. Aug. 19, 2009); U.S. I. Ferenci, 2009 WL

This letter represents my thoughts on issues concerning the NPA and my ability to fully defend Mr. Epstein in the civil case recently filed by Mr. Josefsberg. Based on a State criminal court ruling last summer, the Non-Prosecution Agreement ("NPA") was made available to the public. With regard to the civ

could 'agree" to the occurrence of a predicate pursuant to his NPA obligations but still contest that the plaintiff was injured, see United States I. Scheidt, supra (finding each to be a separate element) and the letter from Mr. Acosta to Mr. Starr, supra December 4, 2007 letter at p.2 which agrees that