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o sett e civil claims. First. she inappropriately attempted to nominate !lambert "Hen" Oeariz for attorney representative. despite the fact that Mr. Oeariz has a longstanding relationship with friend and law school classmate of from counsel. We also learned from Mr. Ocariz turns out to he a very good
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
IJSAO conceded that it was inappropriate for its attorneys to select the attorney representative, Ms. Villafana continued to impro rly lobby for Mr. Oeariz's appointment. On October 19, 2007, retired Judge Edward B. who was appointed by the parties to select the attorney representative. informed Mr. E
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
13. who was appointed by the parties to select the attorney representative. informe r. Pp s counsel that he received a telephone call from Mr. Oeariz directly requesting that Judge appoint him as the attorney s entative in this matter. Although it is unclear how Mr. cariz even knows that Judge
fendant gives up certain rights to contest liability for a chill mettle specifically. Ms. • ' not believe there wits room for contention given the IJSAO's, and ultimatums that required that we acquiesce to these unprecedented terns. Concerns Iteaardinu Section 2253 Mr Epstein unconditionally re-as
Entities connected to both Oeariz and IJSAO

Jeffrey Epstein
PERSON
United States
LOCATION
Alexander Acosta
PERSON
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSON
Prince Andrew
PERSONLeon Black
PERSON
Jay Lefkowitz
PERSON
Joe Biden
PERSON
Munich
LOCATION
Alan Dershowitz
PERSON
Podhurst
PERSONRoy Black
PERSON
Joi Ito
PERSON
Ken Starr
PERSON
Joe D. Whitley
PERSON
Ocariz
PERSON
Whitley
PERSON
the United States District Court
ORGANIZATION