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ty or a waiver of any jurisdictional or other defense as to any person, whether or not her name appears on the list provided by the United States. I. Epstein shall use his best efforts to enter his guilty plea and be Page 4 of 7 EFTA00207419 Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05
them. R. ALEXANDER ACOSTA Dated: it) / 3 DA '7 Da& Dated: ifraffi" ASSISTANT U.S. ATTORNEY JEFFREY EPSTEDI GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTED4 LILLY ATfORNEY YOR JEFFREY EPSTEIN EFTA00207428 Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05/17/2010 Page 15 of 15 tar-tr-01
15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted en investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Office has charged Epstein by indictnxt with solicitation of prostitution, in viola
firm has concentrated its practice exclusively in trial and appellate litigation in both federal and state COUR. 2. Defendant, Jeffrey Epstein ("Epstein" or "Defendant', is fifty-seven years old and is a convicted sexual offender who is a citizen of the Territory of the United States Virgin Islands,
CASE NO. PODHURST ORSECK, P.A. Plaintiff, vs. JEFFREY EPSTEIN, Defendant. COMPLAINT Plaintiff, Podhu
umber and caliber of the attorneys who represent Mr. Epstein, in selecting the victims' attorney representativ
ntiff' City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382 By: /s/ Peter Prieto Steven C. Marks (FBN 516414) [email protected] Peter Prieto (FBN 501492) [email protected] John Gravante, Rl (FBN 617113) • v t igeton/ 17
ty or a waiver of any jurisdictional or other defense as to any person, whether or not her name appears on the list provided by the United States. I. Epstein shall use his best efforts to enter his guilty plea and be Page 4 of 7 EFTA00727912 Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Docket 05
is meant to assist you in perfbrming your duties by providing you with background information regarding the agreement between the United States and JeffreyEpstein and the duties that the attorney representative will have to perform. The Federal Bureau of Investigation and the U.S. Attorney's Office conducted a
15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted en investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Office has charged Epstein by indictnxt with solicitation of prostitution, in viola
firm has concentrated its practice exclusively in trial and appellate litigation in both federal and state COUR. 2. Defendant, Jeffrey Epstein ("Epstein" or "Defendant', is fifty-seven years old and is a convicted sexual offender who is a citizen of the Territory of the United States Virgin Islands,
CASE NO. PODHURST ORSECK, P.A. Plaintiff, vs. JEFFREY EPSTEIN, Defendant. COMPLAINT Plaintiff, Podhu
umber and caliber of the attorneys who represent Mr. Epstein, in selecting the victims' attorney representativ
et, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382 By: ir ter Prieto C. Marks (FBN 516414) [email protected] Peter Prieto (FBN 501492) ii to(a)oodhurstcom Gravante, Rl (FBN 617113) * vr igetora 17 EFTA00727907 Case 1:10-cv-21586-ASG Document 1-3 Entered on FLSD Do
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
. Flagler Drive, Suite 400 West Palm Beach, FL 33401 ax (Counsel for Defendant Jeffrey Epstein) Service List Steven C. Marks, Esq. (FBN 516414) Peter Prieto, Esq. (FBN 501492 John Gravante, Esq. FBN 617113) PODHURST ORSECK, Attorneys for Plaintiff City National bank Building 25 W. Flagler Street, Sui
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
e, Suite 400 West Palm Beach, FL 33401 561/515-3148 Fax (Counsel for Defendant Jeffrey Epstein) Service List Steven C. Marks, Esq. (FBN 516414) Peter Prieto, Esq. (FBN 501492 John Gravante, Esq. FBN 617113) PODHURST ORSECK, Attorneys for Plaintiff City National bank Building 25 W. Flagler Street, Sui
05/26/2010 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 10-CV-21586-ASO PODHURST ORSECK, P.A. Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S RESPONSE TO DEFENDANT'S AMENDED NOTICE AND MOTION FOR LEAVE TO DEPOSIT FUNDS INTO THE REGISTRY OF THE COURT Plaintiff, Po
ered on FLSD Docket 05/26/2010 Page 2 of 3 United States Attorney's Office informed him in a letter to his counsel that it was "concerned about Mr. Epstein's non-performance," and that the "delayed guilty plea and sentencing...[was] unacceptable to the [United States Attorney's] Office." See Letter date
hich must occur no later than December 14, 2007. There must be closure in this matter. Sincerely, R. Alexander Acosta United States Ajtomay By: Jeffrey . Sloman First Assistant United States Attorney Enclosure cc: R. Alexander Acosta, U.S. Attorney AUSA A. Marie Villafana 2This is contingent, h
tter to his counsel that it was "concerned about Mr. Epstein's non-performance," and that the "delayed guilty
Attorneys for Plaintiff 25 West Flagler Street, Suite 800 Miami, Florida 33130 (305) 358-2800 / Fax (305) 358-2382 purietoeoodhursteom By: /s/ Peter Prieto Steven C. Marks (FB# 516414) Peter Prieto (FB# 501492) John Gravante, 111 (FB# 617113) CERTIFICATE OF SERVICE, I HEREBY CERTIFY that on May 26, 20
05/26/2010 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 10-CV-21586-ASO PODHURST ORSECK, P.A. Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S RESPONSE TO DEFENDANT'S AMENDED NOTICE AND MOTION FOR LEAVE TO DEPOSIT FUNDS INTO THE REGISTRY OF THE COURT Plaintiff, Po
ered on FLSD Docket 05/26/2010 Page 2 of 3 United States Attorney's Office informed him in a letter to his counsel that it was "concerned about Mr. Epstein's non-performance," and that the "delayed guilty plea and sentencing...[was] unacceptable to the [United States Attorney's] Office." See Letter date
hich must occur no later than December 14, 2007. There must be closure in this matter. Sincerely, R. Alexander Acosta United States Ajtomay By: Jeffrey . Sloman First Assistant United States Attorney Enclosure cc: R. Alexander Acosta, U.S. Attorney AUSA A. Marie Villafana 2This is contingent, h
tter to his counsel that it was "concerned about Mr. Epstein's non-performance," and that the "delayed guilty
Dated: May 26, 2010 Respectfully Submitted, PODHURST ORSECK, P.A. Attorneys for Plaintiff 25 West Flagler Street, Suite 800 3313 • By: /s/ Peter Prieto Steven C. Marks (FB# 516414) Peter Prieto (FB# 501492) John Gravante, 111 (FB# 617113) CERTIFICATE OF SERVICE, I HEREBY CERTIFY that on May 26, 20
5/26/2010 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 10-CV-21586-ASG PODI{URST ORSECK, P.A. Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S RESPONSE TO DEFENDANT'S AMENDED NOTICE AND MOTION FOR LEAVE TO DEPOSIT FUNDS INTO THE REGISTRY OF THE COURT Plaintiff, Po
ered on FLSD Docket 05/26/2010 Page 2 of 3 United States Attorney's Office informed him in a letter to his counsel that it was "concerned about Mr. Epstein's non-performance," and that the "delayed guilty plea and sentencing...[was] unacceptable to the [United States Attorney's] Office." See Letter date
586-ASG PODI{URST ORSECK, P.A. Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S RESPONSE TO DEF
tter to his counsel that it was "concerned about Mr. Epstein's non-performance," and that the "delayed guilty
Dated: Mary 26, 2010 Respectfully Submitted, PODHURST ORSECK, PA. Attorneys for Plaintiff 25 West Flagier Street Suite 800 3313 / Fax By: w Peter Prieto Steven C. Marks (FB# 516414) Peter Prieto (FB# 501492) John Gravante, lII (FB# 617113) CERTIFICATE OF SERVICE I HEIREBYCERTIFY thaton May 26,2010,
ed.pdf Who sent this to the reporter? Sent from my iPhone Begin forwarded message: From: "Jay Leflcowite Date: May 18, 2010 5:13:36 PM EDT To: "Jeffrey Epstein" Subject: Fw: Fyi. Pls advise. From: "Smith, Stephanie" Sent: 05/18/2010 05:11 PM AST To: Jay Lefkowitz Hi Jay, Stephanie Smith from Page Six a
a copy of a complaint filed here by Podhurst Orseck, the law firm that represented 16 victims in the Jeffrey Epstein case. The complaing claims that Epstein owes them $2 million in fees and is in breach of his non-prosection agreeement, where he agreed to pay the victims' legal fees. Wanted to see if you
ecution, now believes that he can simply ignore — without consequence — the obligations imposed. Put simply, Epstein believes he is above the law." Jeff Epstein's failure to pay these bills puts him in material violation of his Non Prosecution Agreement and could give way to the federal prosecution of him and
flcowite Date: May 18, 2010 5:13:36 PM EDT To: "Jeffrey Epstein" Subject: Fw: Fyi. Pls advise. From: "S
say its upwards of $50 million. Many believe his net worth to be in the billions. Today's lawsuit, filed in Miami federal court by Steve Marks and Peter Prieto of Podhurst Orseck claims that "it has become abundantly clear that Epstein, having obtained the benefits of the NPA and escaped federal criminal p
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 10-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT'S NOTICE AND MOTION FOR LEAVE TO DEPOSIT FUNDS INTO THE REGISTRY OF THE COURT WITH INCORPORATED MEMORANDUM OF LAW Defendan
AND MOTION FOR LEAVE TO DEPOSIT FUNDS INTO THE REGISTRY OF THE COURT WITH INCORPORATED MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN, (hereinafter "Epstein") by and through his undersigned attorneys and pursuant to Federal Rule 67 and Local Rule 67.1, hereby files his Notice and Motion for Leave to Dep
0-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT'S NOTICE AND MOTI
R & COLEMAN 515 N. Flagler Drive, Suite 400 ach, FL 33401 Phone Fax efendant Jeffrey Epstein) Service List Steven C. Marks, Esq. (FBN 516414) Peter Prieto, Esq. (FBN 501492 John Gravante, Es . FBN 617113) PODHURST ORSECK, . Attorneys for Plaintiff City National bank Building 25 W. Flagler Street,
ative appointed by you as Special Master in September of 2008, and as agreed upon by both the United States Attorney's Office ("USAO") and Defendant Jeffrey Epstein ("Defendant"), pursuant to the Non-Prosecution Agreement ("NM") between the USAO and the Defendant, I am writing to inform you of the following: My
nue Floor 28 Miami, FL 33131-1715 Re: Jeffrey Epstein May 21, 2010 Robert Orseck (1934-1978) Walter
hird Avenue Floor 28 Miami, FL 33131-1715 Re: Jeffrey Epstein May 21, 2010 Robert Orseck (1934-1978)
Podhurst Orseck TRIAL & APPELLATE LAWYERS Aaron S. Podhurst Robert C Joeefsberg Joel D. Eaton Steven C Marks Victor M. Diaz, Jr. Peter Prieto Katherine W. Ezell Stephen F. Rosenthal Ricardo M. Martinez-Cid Ramon A. Rasco Alexander T. Rundlet John Gravante, III Honorable Edward B. Davis
Entities connected to both Jeffrey Epstein and Peter Prieto
Leon Black
PERSON
Alan Dershowitz
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George W. Bush
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Bradley Edwards
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United States
LOCATION
Stephen Hawking
PERSONJack Goldberger
PERSONSouthern District
LOCATIONJane Doe
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Barry Diller
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Department of Justice
ORGANIZATIONMartin Weinberg
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Kenneth Marra
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Alexander Acosta
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
A. Marie Villafana
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Virginia Giuffre
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Jay Lefkowitz
PERSONRoy Black
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