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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 10-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaintiff's Response to Defendant's Amended Notice and Motion for Leave to Deposit Funds into the Registry of the
0 into the Court and regarding the history and nature of the fee dispute that is at the core of the current litigation. 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the United States Attorney's Office ("USAO") on September 24, 2007 (hereinafter "Agreement"). The Agreeme
ore of the current litigation. 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the Un
0-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaint
icitly limit the fees and costs being charged to Mr. Epstein so that they were reasonable and not unnecessaril
secution Agreement. Given this unorthodoxy, there is even greater need that the charges to Epstein must be reasonable, see, e.g., Red Bull GMBH v. Spacefuel Corp (1:06cv20948-AJ)(SD Fla).(Court reduces rates charged to losing party in litigation as being unreasonable) e) Although all of the clients who selec
DRAFT ONLY UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:10-CV-21586 PODHURST ORSECK v. JEFFREY EPSTEIN Defendant's Reply to Plaintiff's Response to Defendant's Amended Notice and Motion for Leave to Deposit Funds into the Registry of the Court The d
0 into the Court and regarding the history and nature of the fee dispute that is at the core of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the United States Attorney's Office ("USAO") on September 24, 2007 (hereinafter "Agreement"). The Agreeme
ore of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the Un
ORIDA CASE NO.:10-CV-21586 PODHURST ORSECK v. JEFFREY EPSTEIN Defendant's Reply to Plaintiff's Respons
itly limited the fees and costs being charged to Mr. Epstein so that they were reasonable and not unnecessari
rosecution Agreement. Given this unorthodoxy, there is even greater need that the charges to Epstein must be reasonable, see, e.g. Red Bull GMBH v. Spacefuel Corp (1:06cv20948-AJ)(SD Fla)(Court reduces rates charged to losing party in litigation as being unreasonable)(CITE TO OTHER CASES); e) Although all of
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 10-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaintiff's Response to Defendant's Amended Notice and Motion for Leave to Deposit Funds into the Registry of the
0 into the Court and regarding the history and nature of the fee dispute that is at the core of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the United States Attorney's Office ("USAO") on September 24, 2007 (hereinafter "Agreement"). The Agreeme
ore of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the Un
0-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaint
citly limited the fees and costs being charged to Mr. Epstein so that they were reasonable and not unnecessari
secution Agreement. Given this unorthodoxy, there is even greater need that the charges to Epstein must be reasonable, see, e.g., Red Bull GMBH v. Spacefuel Corp (1:06cv20948-AJ)(SD Fla)(Court reduces rates charged to losing party in litigation as being unreasonable) e) Although all of the clients who select
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 10-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaintiff's Response to Defendant's Amended Notice and Motion for Leave to Deposit Funds into the Registry of the
0 into the Court and regarding the history and nature of the fee dispute that is at the core of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the United States Attorney's Office ("USAO") on September 24, 2007 (hereinafter "Agreement"). The Agreeme
ore of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the Un
0-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaint
citly limited the fees and costs being charged to Mr. Epstein so that they were reasonable and not unnecessari
secution Agreement. Given this unorthodoxy, there is even greater need that the charges to Epstein must be reasonable, see, e.g., Red Bull GMBH v. Spacefuel Corp (1:06cv20948-AJ)(SD Fla)(Court reduces rates charged to losing party in litigation as being unreasonable) e) Although all of the clients who select
DRAFT ONLY UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:10-CV-21586 PODHURST ORSECK v. JEFFREY EPSTEIN Defendant's Reply to Plaintiff's Response to Defendant's Amended Notice and Motion for Leave to Deposit Funds into the Registry of the Court The d
greement. This provision led to settlements with persons who could not be verified as even having been at Mr. Epstein's residence or having met Mr. Epsteinhe-nevec-recialled-pleetipg. Epstein has thus gone beyond the literal terms of the Agreement and declined to contest liability even as to plaintiffs wh
ore of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the Un
ORIDA CASE NO.:10-CV-21586 PODHURST ORSECK v. JEFFREY EPSTEIN Defendant's Reply to Plaintiff's Respons
itly limited the fees and costs being charged to Mr. Epstein so that they were reasonable and not unnecessari
rosecution Agreement. Given this unorthodoxy, there is even greater need that the charges to Epstein must be reasonable, see, e.g. Red Bull GMBH v. Spacefuel Corp (1:06cv20948-AJ)(SD Fla)(Court reduces rates charged to losing party in litigation as being unreasonable)(GIT-B-TO-O-THER-CASES); EFTA00729088 e
DRAFT ONLY UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:10-CV-21586 PODHURST ORSECK v. JEFFREY EPSTEIN Defendant's Reply to Plaintiff's Response to Defendant's Amended Notice and Motion for Leave to Deposit Funds into the Registry of the Court The d
0 into the Court and regarding the history and nature of the fee dispute that is at the core of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the United States Attorney's Office ("USAO") on September 24, 2007 thereinafter "Agreement"). The Agreeme
ore of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the Un
ORIDA CASE NO.:10-CV-21586 PODHURST ORSECK v. JEFFREY EPSTEIN Defendant's Reply to Plaintiff's Respons
itly limited the fees and costs being charged to Mr. Epstein so that they were reasonable and not unnecessaril
osecution Agreement. Given this unorthodoxy, there is even greater need that the charges to Epstein must be reasonable, see, e.g., Red Bull GMBH v. Spacefuel Corp EFTA00729145 (1:06cv20948-AJ)(SD Fla)(Court reduces rates charged to losing party in litigation as being unreasonable)(CITE TO OTHER-C-ASES)t e)
DRAFT ONLY UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:10-CV-21586 PODHURST ORSECK v. JEFFREY EPSTEIN Defendant's Reply to Plaintiff's Response to Defendant's Amended Notice and Motion for Leave to Deposit Funds into the Registry of the Court The d
0 into the Court and regarding the history and nature of the fee dispute that is at the core of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the United States Attorney's Office ("USAO") on September 24, 2007 (hereinafter "Agreement"). The Agreeme
ore of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the Un
ORIDA CASE NO.:10-CV-21586 PODHURST ORSECK v. JEFFREY EPSTEIN Defendant's Reply to Plaintiff's Respons
itly limited the fees and costs being charged to Mr. Epstein so that they were reasonable and not unnecessari
rosecution Agreement. Given this unorthodoxy, there is even greater need that the charges to Epstein must be reasonable, see, e.g. Red Bull GMBH v. Spacefuel Corp (1:06cv20948-AJ)(SD Fla)(Court reduces rates charged to losing party in litigation as being unreasonable)(CITE TO OTHER CASES); e) Although all of
DRAFT ONLY UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:10-CV-21586 PODHURST ORSECK v. JEFFREY EPSTEIN Defendant's Reply to Plaintiff's Response to Defendant's Amended Notice and Motion for Leave to Deposit Funds into the Registry of the Court The d
greement. This provision led to settlements with persons who could not be verified as even having been at Mr. Epstein's residence or having met Mr. Epsteinhe-nevec-recialled-pleetipg. Epstein has thus gone beyond the literal terms of the Agreement and declined to contest liability even as to plaintiffs wh
ore of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the Un
ORIDA CASE NO.:10-CV-21586 PODHURST ORSECK v. JEFFREY EPSTEIN Defendant's Reply to Plaintiff's Respons
itly limited the fees and costs being charged to Mr. Epstein so that they were reasonable and not unnecessari
rosecution Agreement. Given this unorthodoxy, there is even greater need that the charges to Epstein must be reasonable, see, e.g. Red Bull GMBH v. Spacefuel Corp (1:06cv20948-AJ)(SD Fla)(Court reduces rates charged to losing party in litigation as being unreasonable)(GIT-B-TO-O-THER-CASES); EFTA00729096 e
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 10-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaintiff's Response to Defendant's Amended Notice and Motion for Leave to Deposit Funds into the Registry of the
0 into the Court and regarding the history and nature of the fee dispute that is at the core of the current litigation. 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the United States Attorney's Office ("USAO") on September 24, 2007 (hereinafter "Agreement"). The Agreeme
ore of the current litigation. 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the Un
0-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaint
icitly limit the fees and costs being charged to Mr. Epstein so that they were reasonable and not unnecessaril
secution Agreement. Given this unorthodoxy, there is even greater need that the charges to Epstein must be reasonable, see, e.g., Red Bull GMBH v. Spacefuel Corp (1:06cv20948-AJ)(SD Fla).(Court reduces rates charged to losing party in litigation as being unreasonable) e) Although all of the clients who selec
Entities connected to both Jeffrey Epstein and Spacefuel Corp

George W. Bush
PERSON
United States
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSON
Alexander Acosta
PERSON
Jay Lefkowitz
PERSON
Ken Starr
PERSONRobert D. Critton
PERSONRobert C. Josefsberg
PERSON
Jeffrey Sloman
PERSONMichael J. Pike
PERSONLuttier & Coleman
ORGANIZATION
Washington, D.C.
LOCATIONORSECK
ORGANIZATIONResponse
ORGANIZATIONDade County
LOCATIONJohn Gravante
PERSONthe Registry of the Court
ORGANIZATIONRed Bull GMBH
ORGANIZATION