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ded message From: Martin Weinberg <1 Date: Wed, Apr 15, 2009 at 4:39 PM Subject: CMA v JE - ATTORNEY WORK PRODUCT To: "Robert D. Critton Jr." Cc: Jeffery Edwards <[email protected]>, Bob Read the Responsive Memo sent by your office regarding the CMA litigation Several points for possible consideration:
From: Jeffrey Epstein <[email protected]> To: David Spicer <1 Subject: Fwd: CMA v JE - ATTORNEY WORK PRODUCT Date: Wed, 15 Apr 2009 20:52:40 +0000 Forwarded mess
MA litigation Several points for possible consideration: 1. The Memo is saturated with internal conflict where they gravitate from an argument that JE opposition to multiple counts is in conflict with the "clear wording of the statute", Pg 9, and that "the clear wording of the statute" creates a s
From: Jeffrey Epstein <[email protected]> To: David Spicer <1 Sub
From: Jeffrey Epstein <[email protected]> To: David Spicer
From: Jeffrey Epstein <[email protected]> To: David Spicer <1 Subject: Fwd: CMA v JE - ATTORNEY WORK PRODUCT Date: Wed, 15 Apr 2009 20:52:40 +0000 Forwarded message From: Martin Weinberg <1 Date: Wed,
. Mail Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 April 15. 2009 Re: . v. Jeffrey Epstein Re No. 502008CA028051XXXXMB AD Jane Doe (S.R.) v. Jeffrey Epstein Case No. 08-CV-80893-MarralJohnson Dear Brad: ADELQUI J. BENAVENTE PARALEGAL/
oduction were served on March 20th, therefore with 5 days for mailing in state court including the 30 days allowed by the Rule, the response by Mr. Epstein will be due on April 25, 2009. With the 20-day extension you granted to Mr. Epstein, the "new" due date is May 15, 2009. L•A•W•Y•E•R•S 515 N. FLA
.. PA.' BERNARD LEBEDEKER MARK T. LUTITER. PA. JEFFREY C. PEPIN MICHAEL J. PIKE HEATHER McNA.MARA RUDA
the 30 days allowed by the Rule, the response by Mr. Epstein will be due on April 25, 2009. With the 20-day e
, FLORIDA 33401 TELEPHONE (561) 842-2820 FAX (561) 844-6929 EFTA00722734 April 15, 2009 Page 2 Thank you for your courtesies. As I advised you, David Spicer will be substituting as counsel for Mr. Epstein in all of your cases. Cordially Robegf D. Critton, Jr. RDC/clz cc: Jack Goldberger, Esq. David
t 113 Entered on FLSD Docket O5/22/2009 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 013CV80119-MARRA/JOHNSON JANE DOE NO. 3, Plaintiff vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CV-80232-MARRA/JOHNSON
that the no-contact order agreed to during the state plea colloquy does not apply to any of ow clients except for those victims who were part ofMr. Epstein's state plea. Ourtmdastanding is that AUSA Villafana and Messrs. Twin and Goldberger entered a verbal agreement at the time that the list of victim
ICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 013CV80119-MARRA/
victims was provided to those defense counselthat Mr. Epstein, including his agents, would have' no direct or
en F. Roanchal Ricardo M. Martinez-ad itiunon A. Raisin Alexander T. Ittmdlet John Quante, III Carolina Maharbiz April 17, 2009 VIA FACSIMILE David Spicer, Esq. 11000 Prosperity Pains Road Suite 104 Palm Beach Garda FL 33410 Robert Cann, Esq. Burman, Critton, Luther & Coleman LLP 515 North Flagla
From: Jeffrey Epstein <[email protected]> Sent: Saturday, April 18, 2009 9:29 PM To: David Spicer Subject: Fwd: we should prepare a letter for each girl to be d
be delivered to josephburg„ th=t says we have been informed that the josephburg , represents you and has =hreatened litigation on your behalf. Mr . Epstein has instructed us to fig=t this litigation for as long as it takes.. Please acknowledge that mr. jo=pehburg , due to his threats is now authorized t
From: Jeffrey Epstein <[email protected]> Sent: Saturday,
From: Jeffrey Epstein <[email protected]> Sent: Saturday, April 18, 2009 9:29 PM To: David Spicer Subject: Fwd: we should prepare a letter for each girl to be delivered to josephburg„ th=t says we have been informed that the josephburg , repre
position that the no-contact order agreed to during the state plea colloquy does not apply to any of our clients those victims who were part of Mr. Epstcin's state plea. Our understanding is that AUSA and Messrs. Tein and Goldberger entered a verbal agreement at the time that the list of victims was pr
ictims was provided to those defense counsel that Mr. Epstein, including his agents, would have no direct or i
n F. Rosenthal Ricardo M. Martinez-Gd Ramon A. Rasco Alexander T. Rurallet John Gravante, DI Carolina iVlaharbiz April 17, 2009 VIA FACSIMILE David Spicer, Esq. 11000 Prosperity Farms Road Suite 104 Palm Beach Gardens, FL 33410 Robert Critton, Esq. Burman, Critton, Luttier & Coleman LLP 515 North
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Stephen Hawking
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