Epstein Secrets

17/2009 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOB NO. 2, Plaintiff I JEFFREY B. EPSTEIN, Defendant. Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80581, 09-80656, 09-80802, 09-8109

deo deposition creates logistical problems. 4. On August 27, 2009, the undersigned wrote a letter to counsel for the Plaintiff indicating that Mr. Epstein would be present at the deposition. A copy of that letter is attached as Exhibit 1. 5. Some 13 days later, counsel for Jane Doe No. 4 filed a moti

been justified, however, under these circumstances, it was grandstanding and improper. In that the Plaintiff has stated that she voluntary went to JE's home 50 plus times without trauma until she filed a lawsuit, this brief visual encounter from a distance should not have resulted in the unilater

ths and take acknowledgments, personally appeared Jeffrey E. Epstein known to me to be the person described

d to me and I agree by them. ep/07-02-08 Defendant aeir 7-D-3- 6 7 reitS* al +k 6-5 taINS Page 7 of 8 Form Revised 03-18-08 EFTA00182102 :TREY EPSTEIN CASEN502008CF009381AXXXMB COURT ORDERED PAYMENTS CHECK ALL THAT ARE ORDERED: FINES K K K S Total of fines assessed in sentence, pursuant to

t fib. Critton, Jr. Mic 1J. Pike Attorneys for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a

ths and take acknowledgments, personally appeared Jeffrey E. Epstein known to me to be the person described i

ter to counsel for the Plaintiff indicating that Mr. Epstein would be present at the deposition. A copy of tha

oma kmumo TO HACK= m Daum MID CCEDPA0O Sent by E.Mall and U.S, Mail Stuart S. Mermelstein, Esq. PA. Suite 2218 Miami, FL 33160 BURMAN. CRITTON LUTTIER&COLEMAN.LLP YOUR. TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP August 27, 2009 Re: Jane Doe No. 4 v. Epstein Dear Stuart ADE/OWE BEPUNItin mmUGAVINv

been justified, however, under these circumstances, it was grandstanding and improper. In that the Plaintiff has stated that she voluntary went to JE's home 50 plus times without trauma until she filed a lawsuit, this brief visual encounter from a distance should not have resulted in the unilater

09/17/2009 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOB NO. 2, Plaintiff JEFFREY B. EPSTEIN, Defendant. Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80581, 09-80656, 09-80802, 09-8109

deo deposition creates logistical problems. 4. On August 27, 2009, the undersigned wrote a letter to counsel for the Plaintiff indicating that Mr. Epstein would be present at the deposition. A copy of that letter is attached as Exhibit 1. 5. Some 13 days later, counsel for Jane Doe No. 4 filed a moti

d to me and I agree by them. ep/07-02-08 Defendant aeir 7-D-3- 6 7 reitS* al +k 6-5 taINS Page 7 of 8 Form Revised 03-18-08 EFTA01625733 :TREY EPSTEIN CASEN502008CF009381AXXXMB COURT ORDERED PAYMENTS CHECK ALL THAT ARE ORDERED: FINES K K K S Total of fines assessed in sentence, pursuant to

t fib. Critton, Jr. Mic 1J. Pike Attorneys for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a

ths and take acknowledgments, personally appeared Jeffrey E. Epstein known to me to be the person described

ths and take acknowledgments, personally appeared Jeffrey E. Epstein known to me to be the person described i

ter to counsel for the Plaintiff indicating that Mr. Epstein would be present at the deposition. A copy of tha

efendant Jeffrey Epstein) 8 EFTA01625672 Case 9:08-cv-80119-KAM Document 305-2 Entered on FLSD Docket 09/17/2009 Page 1 of 1 BURMAN. CRITTON LUTTIER&COLEMAN.LLP YOUR. TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN. PA" GREGORY W. COLEMAN. PA. ItOURT D. DUTTON. X. PA' SIMARD WEDEKEE.

cc: William Richey, Esq. Jack Goldberger, Esq. Jeffrey E. Epstein Lilly Ann Sanchez, Esq. Jerry Lefcourt,

and understand my ongoing obligation to maintain Mr. Epstein's personal items inviolate until all terms of th

TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP September 9, 2010 PERSONAL AND CONFIDENTIAL Sent by E-Mail and U.S. Mail William Riley Re: Epstein Matter Dear Bill: ADELE/VI J. BENAVENTE PARALEGAL/INVESTIGATOR JESSICA CADWELL BOBBIE M. MCKENNA ASHLIE STOREN-BARING BETTY STOW PAML (GALS

bert e. Critton, Jr. PHONE: • FAX: WWW. BC LC LAW.COM EFTA00724323 September 9, 2010 Page 2 cc: William Richey, Esq. Jack Goldberger, Esq. Jeffrey E. Epstein Lilly Ann Sanchez, Esq. Jerry Lefcourt, Esq. I have read the above letter and its enclosures and agreed and understand my ongoing obligation to m

cc: William Richey, Esq. Jack Goldberger, Esq. Jeffrey E. Epstein Lilly Ann Sanchez, Esq. Jerry Lefcourt

TheUnited States has Melted to assign to an independent third-party the responsibility for consulting with anktmbject to the good faith approval of Epsttin's counsel, sc./toting the attorney representative for the badivIdasals identified andtribe Agreement. If tic United States elects to assign this re

SCHEVE DEAN T. XENICK DAVID A YAREMA 'FLORIDA BOARD CULTIFJID CIVIL -TRIAL LAWYER ;ADMITTED TO PRACTICE IN FLORIDA AND COLORADO BURMAN. CRITTON LUTTIER&COLEMAN.LLP YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP September 9, 2010 PERSONAL AND CONFIDENTIAL Sent by E-Mail and U.S. Mail William Riley

fic to the individuals. We agreed that you would join us (agree that the court has jurisdiction to consider the action, but not necessarily concede Jeffrey Epstein is correct as to points which might be plead) in any declaratory action that is filed. These issues may include: 1. Whether the minimum amount of d

n be plead, whether a plaintiff is entitled to only a single recovery; whether Jeffrey Epstein can test the veracity of a plaintiff and whether Mr. Epstein can assert statutes of limitation as an affirmative defense. We had also ould not represent any additional females who are on the list, other tha

can test the veracity of a plaintiff and whether Mr. Epstein can assert statutes of limitation as an affirmati

PA' BERNARD A. LEBEDEKER MARK T. LUTTI EEL PA JEFFREY C. PENN MICHAEL I. PIKE HEATHER MCNAMARA RUDA

RUDA DAVID A. YAREMA 'FLORIDA BOARD CERTIFIED CIVIL TRIAL LAWYER 2ADMITTE Sent ACTICE IN EMICy. Aar, C/VIDRADO by E-Mail only BURMAN. CRITTON LUTTIER&COLEMAN.LLP YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP October 19, 2009 Re: Settlement Negotiations Dear Bob: ADELOYI J. BENAVENTE PARALEGA

ng since they are in the possession of so many different attorneys. Attached is a small sample (19 pages). We have objected to the production on Mr. Epstein's behalf believing they are irrelevant to the civil litigation, certainly inadmissible, and that their production chills the candor of plea negotiat

(19 pages). We have objected to the production on Mr. Epstein's behalf believing they are irrelevant to the ci

)M To: US S Subject: RE: E-mail to Sure, is it in the flagler tower bldg on the intrcoastal where jones and foster's office is? BURMAN. CRITTON LUTTIER&COLEMAN.LLP YOUR TRUSTED ADVOCATES Robert D Critton Jr. - Attorney at Law 303 Ban an Boulevard I Suite 400 West Palm Beach I FL 33401 Phone: I Fax: Di