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portions of the Agreement. As I previously observed, our intent has been to place the victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less. From our meeting, it appears that the defense agrees that this was the intent. During the course of nego
lm Beach, FL 33401 (561) 820-8711 Facsimile: (56!) 820-8777 August 4, 2009 VIA ELECTRONIC MAIL Spencer T. Kuvin, Esq. Leopold—Kuvin, P.A. Re: Jeffrey Epstein/B.B. — Requested Disclosure of Non-Prosecution Agreement Dear Mr. Kuvin: Thank you for your letter regarding the disclosure of the Non-Prosecution Agree
ORTH. FL 334614 Page 2 of 8 Form Revised 01.18-08 EFTA00233452 11/25/2008 15:28 3553626 elKt.LII I LICIMINAL STATE OF FLORIDA Plaintiff -vs- JEFFREY E. EPSTEM Defendant IN THE FIFTEENTH JUDICIAL CIRCUIT COURT, IN AND FOR PALM BEACH COUNTY CASE NUMBER DIVISION DC NUMBER CIRCUITNUMBER: zalitcavawanua
E Disposition Amount: Docket Text: AGREED ORDER CONTINUING CASE DISPO 13 AGOR - AGREED ORDER Filing Date: 05-MAR-2007 Filing Party: EPSTEIN, JEFFREY E IRisposition Amount: Docket Text: I(JUDGE MCSORLEY) CONTINUING CASE DISPO PREVIOUSLY- 1 SET FOR 08-MAR-2007 AND RESETTING FOR CASE DISPO ON 16-MAY
mmissioner CASE DISPOSITION MAIN BRANCH COURTROOM 11F COLBATH, JUDGE JEFFREY CASE DISPOSITION MAIN BRANCH COURTROOM] 11F COLBATH, JUDGE JEFFREY Case Parties Expn Date Type ID Name DEFENDANT 24167391 EPSTEIN, JEFFREY E. Aliases: none 3 1 22-AUG- ATTORNEY ATTY MALINSKI, NORMAN 2006 Alia
FREY CASE DISPOSITION MAIN BRANCH COURTROOM] 11F COLBATH, JUDGE JEFFREY Case Parties Expn Date Type ID Name DEFENDANT 24167391 EPSTEIN, JEFFREY E. Aliases: none 3 1 22-AUG- ATTORNEY ATTY MALINSKI, NORMAN 2006 Aliases: none hup://courtcon.co.palm-beach.flais/p1s/jiwp/ek_public_qry_docup_dkt
24 FAHIS - HISTORY FELONY/MISD ARRAIGN Filing Date: 06-OCT-2006 Filing Party: Disposition Amount: Docket Text: X/JIFA FELONY-MISDEMEANOR IS EPSTEIN JEFFREY E LEGACY 41673917332767 PRAECIPE AND 082206 DATE: JUDGE: COURT: DEFENDANT PRESENT: PLEA: ARRAIGNMENT PASSED TO: DATE: RELEASED, FAILURE OF STATE
, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS, & FOR MORE DEFINITE STATEME
in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less. From
ed, molested, and/or exploited these girls, and then gave them money. Podhurst Orseck, P.A. 2 25 West Flagler Street. Suite 800. Miami, FL 33130, Miami 305.358.2800 Fax 305358.2382 • Fat Lauderdale 954.463.4316 www.podhurst.com EFTA00233472 Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page
sts the legitimate concern that the agreement could be so used and the reality that any concern about such use significantly and unfairly burdens Mr Epstein's right to resort to the courts to resolve outstanding legal Issues regarding the criteria for payment and the amount of payment owed. I hope this
Jane Doe No. 103 1 0 - 80 (b) County of Residency of First Listed Plaintiff West Palm Beach (EXCEPT IN U.S. PLAINTIPP CASES) S int. NTS 0 it Fey stein (c) Attorney's (Tina Nam, Address. nod Telephone Hornbill) Robert C..losefsbag, Esq./Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 W. Flag' e
, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS, & FOR MORE DEFINITE STATEME
Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Mr. Black: Thank you for meeting w
it a breach of the Non- Prosecution Agreement for Mr. Epstein to file suit against the victim's attorney-repres
ed, molested, and/or exploited these girls, and then gave them money. Podhurat Orseck, P.A. 2 25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.35&2382 Fort Lauderdale 954.463.4346 www.podhurst.corn EFTA00194775 ' Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Pa
742, 754 (M.D. Pa. 2007); and the recent cases in front of this court on Defendant's Motions to Dismiss and For More Definite Statement — Doe No. 2 I. Epstein, 2009 WL 383332 (S.D. Fla. Feb. 12, 2009); Doe No. 3'. Epstein 2009 WL 383330 (S.D. Fla. Feb. 12, 2009); Doe No. 4'. Epstein 2009 WL 383286 (S.D. Fl
sts the legitimate concern that the agreement could be so used and the reality that any concern about such use significantly and unfairly burdens Mr Epstein's right to resort to the courts to resolve outstanding legal issues regarding the criteria for payment and the amount of payment owed. I hope this
, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS. & FOR MORE DEFINITE STATEME
Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Mr. Black: Thank you for meeting w
it a breach of the Non- Prosecution Agreement for Mr. Epstein to file suit against the victim's attorney-repres
tered pleas of "guilty" to one count of solicitation of prostitution, in Podhurst Orseck, P.A. 8 25 West Flagler Street, Suite ea Miami, FL 33130, Miami 305.358.2800 Fax 305359.2382 • Fort Lauderdale 954.4634346 I www.;xxlituraleom EFTA00183827 Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Pa
Podhurst Dern Of Counsel Re: Jeffrey Epstein - Issue that Arose At Today's Meeting Our File No.: 30608 Dear Bob and Michael: At today's meeting Jeffery Epstein raised an issue of my breaking my word. In response I am attaching a copy of your letter of October 19, 2009. Since my integrity appears to be at is
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 a reed that ou would not represent any additional females who are on the
ckham, Jr. Karen Podhurst Dern Of Counsel Re: Jeffrey Epstein - Issue that Arose At Today's Meeting Ou
an test the veracity of a plaintiff; and whether Mr. Epstein can assert statutes of limitation as an affirmati
urs, RCJ/bp Robert C. J sefsberg Enclosure cc: J. Michael Burman, Esq. Podhurst Orseck, PA. 25 West Flagier Street, Suite 800, Miami, FL 33130 Miami 305.358.2800 Fax 305358.2382 • Fort Lauderdale 954.463.4346 www.podhurstcom EFTA00598938 A\ we-2 fri71/4 e-rn et BURMAN, CRITTON C 1/44-0 LUTTIER&COLEMAN, LL
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
service of this Complaint via mail. Very truly yours, Robert C. Josefsberg Podhurst Orseck, P.A. 25 West Hagler Street Suite 800, Miami, FL 33130 Miami 305.358.2800 Fax 305358.2382 • Fort Lauderdale 954.463.4346 vnew.podhurstoom EFTA00601094 AO 440 (Rev. 10/2002) Summate in a Civil Case UNITED STATES DISTRICT C
. JOSEFSBERG Sent: Tuesday, February 03, 2009 2:16 PM To: '[email protected]' Subject: Re: Epstein Roy - I need to go on record regarding Mr Epsteins message that without any settlements there will be a "push back" on any future payments. First, Mr Epstein has no authority to "push back" on payme
We intend to comply fully with the agreement and Mr. Epstein will pay Mr. Josfsberg's usual and customary hou
d a check went out today. I am also told there will be push back on further expenses without a settlement. So we need to discuss settling the cases. Jeffrey will not pay more for the fees and expenses without the start of settlement negotiations. So let's discuss. Roy 1 EFTA00194693 KIRKLAND & ELLIS
illafans United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re.: Jeffrey Epstein Dear Marie: , . In response to your letter dated August 26, 2008, I am confirming that Mr. Goldberger should continue to be listed as the contact
the United States in consultation with and with the good faith approval of Podhurst Orseck, P.A. 25 West Plaster Street, Suite 800, Miami, F1.33130 Miami 305.358.2800 Fax 305.388.2382 • Fort Lauderdale 954.463.4546 EFTA00194701 Robert Critton, Esq. June 8, 2009 Page 2 Epstein's counsel. Judge in turn and in acco
NO.: 09-CV-80591-MARRAJJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF JANE DOE NO. 101'
9 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 101, CASE NO.: 09-CV-80591-MARRAJJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF JANE DOE NO. 101'S RESPONSE TO DEFENDANT'S MOTION TO DISMISS PLAINTIFF'S FIRST AMENDED COMPLAINT AS MODIFIED BY DEFENDANT'S
ever been allowed is misplaced; this case involved only a single violation of a predicate statute. Moreover, Defendant's reliance on its own Doe vs. Epstein line of cases is, at a minimum, premature. Accordingly, in the instant case, not only was it proper for Plaintiff to plead multiple counts in the
e offenses of Section 2255 of Title 18 of the U.S. Code as set forth in the Podhorst Orsecic, P.A. 25 West Flagkr Steel, Suite 800. Mamie FL 33130, Miami 305.358.2800 Fax 305358.2382 • Fort Lauderdale 954463.4346 www.podhurst.crea EFTA00725633 Case 9:09-cv-80591-KAM Document 56 Entered on FLSD Docket 06/26/2009
s District. STATEMENT OF FACTS 8. At all relevant times, Defendant, Jeffrey Epstein, was an adult male, spanning the ages of 45 and 55 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. 102, Plaintiff, vs. JEFFREY EPSTEIN, Civil Action No 09-80656 CIV-RYSKAMP
ly exploitative behavior. Government Exhibit B Podhurst Orseck, P.A. Case No 4-80716-CIV-MARRA 25 West Hagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.3502382 • Fort Lauderdale 954.463.4346 I vrww.pocIlmrst.com EFTA00210860 Case 9:08-cv-80656-KAM M000feet1290-2 EEteeideloorfESSODDoisat00/1
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.
d enticed impressionable, vulnerable, and relatively economically less Podhurst Orseck, P.A. 2 25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort lauderdak 954.463.4346 www.podhonst.com EFTA00212930 Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 P
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.
d enticed impressionable, vulnerable, and relatively economically less Podhurst Orseck, P.A. 2 25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort lauderdak 954.463.4346 www.podhonst.com EFTA00212997 Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 P
Entities connected to both Jeffrey Epstein and Miami 305.358.2800 Fax
Leon Black
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Stephen Hawking
PERSONJack Goldberger
PERSONSouthern District
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSON
Alexander Acosta
PERSON
U.S. Virgin Islands
LOCATIONFBI
ORGANIZATION
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSON