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H. Willits, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, FL 33461 Re: Jeffrey Epstein/Carolyn NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Willits: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to y
00 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561)820-8711 Facsimile: (561) 820-8777 July 10, 2008 VIA FACSIMILE AND U.S. MAIL Richard H. Willits, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, FL 33461 Re: Jeffrey Epstein/Carolyn NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Willits:
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
Kuyrkendall, Richards Sloman Email regarding proposed response to Goldberger R - 7/10/2008 Victim Notification letters to Individuals #3 (via Richard H. Willits), #8 (via Jeffrey Herman), ##17 (via Theodore J. Leopold), #25 (via Jeffrey Herman), #26 (via Jeffrey Herman), #37 (via Michael E. Dutko), and #44
sta and instructions to direct question to Marie Villafafia and Karen Atkinson 4/8/2008 Sigal Mandelker Starr Letter - 4 pages (CEOS) 4/9/2008 Willits Villafafia Letter in response to 3/28/08 letter from Willits B • 12 4/21/2008 4/21/2008-5/9/2008 Emails between Marie Villafatia, Jeff Sloman, K
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)
ved this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 7th day of January, 2009: Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 L m k Worth FL 33461 imo s Fax: C unse or ainti Jack Scarola, Esq. Jack P. H
by Judge William J. Zloch on 8/6/2008. (bc) (Entered: 08/06/2008) 08/07/2008 12 I 173 KB MOTION to Reassign Case TO JUDGE KENNETH MARRA by . (Willits, Richard) (Entered: 08/07/2008) 08/07/2008 B r 34.1 KB MEMORANDUM in Opposition re 6 Sealed Document, 7 Sealed Document TO MOTION TO STAY file
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
RCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe II. 12 THE COURT: Good morning. 13 MR. WILLITS: Good morning, Your Honor. Richard 14 Willits, here on behalf of the plaintiff C.M.A.. 15 THE COURT: Good morning. 16 MS. EZELL: Good morning, Your Honor. I'm Katherine 17 Ezell from Podhurs
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
ved this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 7th day of January, 2009: Richard Horace Willits, Esq. Richard H. Willits, P.A. th Lake Worth, FL 33461 Counsel for Plaintiff C.M.A. Jack Scarola, Esq. Jack P. Hill, Esq. Search Denney Scaro
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
ill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected] Richard Horace Willits [email protected] Robert C. Josefsberg [email protected] /s/ Adam D. Horowitz 7 EFTA00222253
rategy. Ms. Robson was named in at least one civil case against Mr. Epstein as a co-defendant. See Jane Doe'. Epstein, case no. 50-2008-CA-0065996, Palm Beach County Circuit Court. Ms. Robson brought multiple underage girls to Epstein in addition to Jane Does 4 and 7. 4 EFTA00222250 Case 9:08-cv-80119-KAM Document 145 En
Richard H. Willits, P.A. Office: (561) 582-7600 • (561) 588-8819 March 28 2008 ac ensant: c rey tpstein Please be advised we have been retained to represent a re
hip with Mr. Epstein. As we understand you are investigating this matter, we wanted you to be aware of our involvement. We have filed a lawsuit in Palm Beach County Circuit Court and We are using the initials to try to keep publicity on this matter limite or s. r nano s ene t. Possibly, you can help us with one of the probl
VIA FACSIMILE Richard H. Willets, Esq. Mr. Michael Danchuk 2290 10th Avenue North, Suite 404 Lake Worth, FL 33461 Re: Carolyn El Dear Messrs. Willits and Danchuk: Thank you for your letter of March 28, 2008, regarding Pursuant to the strict rules of grand jury secrecy, I am not able to prow e you
hip with Mr. Epstein. As we understand you are investigating this matter, we wanted you to be aware of our involvement. We have filed a lawsuit in Palm Beach County Circuit Court under Ms. initials, C.M.A. We are using the initials to try to keep publicity on this matter limited for Ms. Andriano's benefit. Possibly, you can
ie Villafaila regarding victim representation and filing suit against Epstein in state court 13-42 4/9/2008 Mai is Villafana letter to Richard II. Willits (formatting problem) 13-43 6/18/2008 Marie Villalana handwritten notes re calls with Brad Ed wards and Roy Black B-44 6/23/2008 John Roth letter
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)
Entities connected to both Richard Horace Willits and Palm Beach County Circuit Court

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONJack Patrick Hill
PERSONJane Doe
PERSON
Paul Cassell
PERSONMichael J. Pike
PERSONRobert D. Critton
PERSONKatherine W. Ezell
PERSONRobert C. Josefsberg
PERSON
Alan Dershowitz
PERSONJack Scarola
PERSON
Lake Worth
LOCATIONBruce E. Reinhart
PERSONSouthern District
LOCATION
Kenneth Marra
PERSONScott Rothstein
PERSON
Sarah Kellen
PERSON
Salt Lake City
LOCATIONSpencer Kuvin
PERSON