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Y EPSTEIN RALD LEFCO r RT ESQ. COUNSEL TO JEFFR Y EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EP
in the woe position as they would have been had Mr. Epstein been convicted al trial. No more; no less. From
hearing shall be limited to the issue of whether Defendant Epstein's defense of the civil actions filed against him
of Breach USAO No. 2006R0 181 June 9, 2009 To Jeffrey H. Sloman Acting United States Attorney Robert
TATES ATTORNEY Dated: By: Dated: Dated: Dated: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY JEFFREY EPSTEIN RALD LEFCO r RT ESQ. COUNSEL TO JEFFR Y EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Case No. 08-80736-CV-MARRA P-011815 EFTA00192861 By signing this Addendum, Epstein assert
in, knowingly mailed, transported, or shipped in interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252A(a)(1). Podhurst Orsecic, P.A. 14 ZS West Meer Street. Suite 800, MWµ P1.13130. Ittlen0 305.1582800 Pax 305358.2382 • Port Lauderdale 951.463.8346 .podhuntcom Case No. 08
at the no-contact order agreed to during the state plea colloquy does not apply to any of our clients except for those victims who were part of Mr. Epstein's state plea. Our understanding is that AUSA Villafana and Messrs. Tein and Goldberger entered a verbal agreement at the time that the list of vict
brought to Defendant's mansion in or about the spring of 2003, when she was merely 17 years old and in high school. Epstein's procurer drove her to Jeffrey Epstein's mansion. Plaintiff was led up a flight of stairs by a blonde woman to a spa room with a shower and a massage table, where she was left alone. A wom
bu Goldber er & Weis P.A. Re: Jane Doe 101 vs. Jeffrey Epstein Case No. 09-80591-Civ-Marra Gentlemen:
lients except for those victims who were part of Mr. Epstein's state plea. Our understanding is that AUSA Vil
h other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Podhurst Orsecic, P.A. 15 Fax • Fat Lauderdale www.podhurataim EFTA00722794 COUNT SEVEN (Cause of Action for Engazina in a Child Exploitation Enterprise pursu
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
rated use of his wealth, power, and influence has the immediate effect of intimidating young women who have already been traumatized by 7 Podhurat Orsecic, P.A. 25 Wea Flagler Sflet, seat MO, MLad, 51.33130, items • PorMaktdde www.padhussecom EFTA00779781 Case 9:08-cv-80119-KAM Document 113 Ente
at the no-contact order agreed to during the state plea colloquy does not apply to any of our clients except for those victims who were part of Mr. Epstein's state plea. Our understanding is that AUSA Villafana and Messrs. Tein and Goldberger entered a verbal agreement at the time that the list of vict
brought to Defendant's mansion in or about the spring of 2003, when she was merely 17 years old and in high school. Epstein's procurer drove her to Jeffrey Epstein's mansion. Plaintiff was led up a flight of stairs by a blonde woman to a spa room with a shower and a massage table, where she was left alone. A wom
West Palm Beach, FL 33401 Re: Jane Doe 101 vs. Jeffrey Epstein Case No. 09-80591-Civ-Marra Gentlemen:
lients except for those victims who were part of Mr. Epstein's state plea. Our understanding is that AUSA Vil
h other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Podhurst Orsecic, P.A. 15 25 Welt Flagler Street Suite 800, MLitt* FL 33130, //Rama 305358.2800 Fax 305.350382 • Fort Lauderdale 954.4634346 t www.podhurstsrom EF
ccurred in this District. STATEMENT OF FACTS 8. At all relevant times, Defendant, Jeffrey Epstein, was an adult male, approximately 50 years old. Epstein is known as a billionaire financier and money manager with a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth,
T OF FLORIDA JANE DOE No. 101, Plaintiff, VS. JEFFREY EPSTEIN, Defendant. 09-80591 Civil Action No.
of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. Podhurst Orsecic, P.A. 8 25 West Hagler Street Suite 800, Misrule FL 33130, Miami 305.358.2800 Fax 305-358Z82 • Fort Lauderdale 954.463.4346 www.podhunt com EFTA0
ccurred in this District. STATEMENT OF FACTS 8. At all relevant times, Defendant, Jeffrey Epstein, was an adult male, approximately 50 years old. Epstein is known as a billionaire financier and money manager with a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth,
T OF FLORIDA JANE DOE No. 101, Plaintiff, VS. JEFFREY EPSTEIN, Defendant. 09-80591 Civil Action No.
of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. Podhurst Orsecic, P.A. 8 25 West Hagler Street Suite 800, Misrule FL 33130, Miami 305.358.2800 Fax 305-358Z82 • Fort Lauderdale 954.463.4346 www.podhunt com EFTA0
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