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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
wever, at least when Defendant was in Palm Beach, Florida, such acts occurred usually on a daily basis and, in most instances, several times a day. Podhurst Orsecic P.A. 4 23 West Flagler Sate, Suite 800, Miami. FL 33130, Mad X6.35511300 Pax 3(59582342 • Port Lauderdale 954.461.4346 veww.podlturattom Case No. 08-8
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
osecution Agreement from denying the acts alleged in this Complaint and must effectively admit liability to Plaintiff, Jane Doe No. 103. COUNT ONE Podhurst Orsecic P.A. 9 25 West Plagler Street, Suite 800, Miami, FL 33330, Miami 305.358.2800 Fax 305268.2382 • Fort Lauderdale 954.463.4346 1 www.podhuratcom EFTA001
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 ClV-RYSKAMP
7, Defendant used his resources and his influence over vulnerable minor girls to engage in a systematic pattern of sexually exploitative behavior. Podhurst Orsecic P.A. EFTA00210922 Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 3 of 27 II. Defendant's plan and scheme reflected a par
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, 09-80656 Civil Action No CIV-RYSKAMP
ill in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 16 Podhurst Orsecic P.A. 25 West Ragler Street, Suite 800, Miami, FL 33130, Miami 305.3582800 Fax 305.3582382 • Fort Lauderdak 954.463.4346 vnvw.podhurst.com EFTA00221629
Entities connected to both Jeffrey Epstein and Podhurst Orsecic P.A.
Leon Black
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Alan Dershowitz
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George W. Bush
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Bradley Edwards
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United States
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Alexander Acosta
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