Epstein Secrets

August 4, 2009 VIA ELECTRONIC MAIL Spencer T. Kuvin, Esq. Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 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

ter giving notice of breach. I respectfully submit that the Motion to Dismiss that is referenced therein did not constitute a willful breach of Mr. Epstein's obligations under the non-prosecution agreement. Mr. Epstein's counsel unanimously determined that the filing of this Motion to Dismiss was not a

's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 voswidrkland.com June 15, 2009 Re: Jay Epstein Dear a I am attaching a letter authored by my co-counsel, Robert Critton, on today's date. It represents our agreement with a proposal that Kathy Ez

Atkinson, Esq. EFTA00183762 J. WHAM. BURMAN, PA., GREGORY W.CCU:NAN. PA. ROBERT D. CRITTON. IR., PA., BERNARD LEBEDBKER MARK T. I II/STIER, PA. JEFFREY PEPIN MIOIAEL PIKE HEATHER McNAMARA RUDA I R.ORIDA WARD anima CIVIL TRIAL LAWYER BURMAN, CRITTON, LUTTIER & COLEMAN LLP A LIMITED LIABILITY PARTNER

8 1. JEFFREY EPSTEIN, Plaintiff, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS PLAINTIFF'S COMPLAINT Defend

, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Ms. www.kirklend.com June 12, 200

d therein did not constitute a willful breach of Mr. Epstein's obligations under the non-prosecution agreement

Jur.2d Assault §1. An assault and battery are intentional acts. See generally Spivey I. Battaglia, 258 So.2d 815 (Fla. 1972); and Travelers Indem. PCR, Inc., 889 So.2d 779 (Fla. 2004). On the face of the Complaint, the applicable four year statute of limitations has expired, and accordingly, Count I is

August 4, 2009 VIA ELECTRONIC MAIL Spencer T. Kuvin, Esq. Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 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

ter giving notice of breach. I respectfully submit that the Motion to Dismiss that is referenced therein did not constitute a willful breach of Mr. Epstein's obligations under the non-prosecution agreement. Mr. Epstein's counsel unanimously determined that the filing of this Motion to Dismiss was not a

tatement [DE 29] dated May 26, 2009. Counsel for Defendant EPSTEIN Certificate of Service I HEREBY CERTIFY that a

, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Ms. Villafana, M www.kirkland.com

d therein did not constitute a willful breach of Mr. Epstein's obligations under the non-prosecution agreement

tion against Jeffrey Epstein styled B.B.I. Jeffi-ey Epstein, case no.: 502008CA037319 MB AB. We are hereby r

d Assault §1. An assault and battery are intentional acts. See generally, Spivey'. Battaglia, 258 So.2d 815 (Fla. 1972); and Travelers Indem. Co.'. PCR, Inc., 889 So.2d 779 (Fla. 2004). On the face of the Complaint, the applicable four year statute of limitations has expired, and accordingly, Count I is

lsd Page 1 of 15 LRJ U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80232-KAM Doe No. 3 v. Epstein Assigned to: Judge Kenneth A. Marra Lead case: 2:flasaAhd Member case: (View Member Case) Case: 9:09-cv-80802-KAM Cause: 28:1332 Diversity-Perso

file this document. (Is) (Entered: 05/20/2009) 05/20/2009 2.$ NOTICE by C.M.A. of Filing Withdrawal of Previously Raised Objections to Defendant, Jeffrey Epstein's Motion to Compel And/Or Identify C.M.A. in the Style of This Case and Motion to Identify C.M.A. in Third-Party Subpoenas for Purposes of Discovery,

3/11/2008) 05/22/2008 4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe No. 3. (Herman, Jeffrey) (Entered: 05/22/2008) 05/29/2008 5 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 3. (Attachments: # 1 Exhibi

plicable statute of limitations. WHEREFORE Defendant requests that this Court deny the re ' f sought by Plaintiff. Robert D. C itton, Jr. Attorney f. Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also

.2d Assault §1. An assault and battery are intentional acts. See generally, Spivey. Battaglia 258 So.2d 815 (Fla. 1972); and Travelers Indem. Co... PCR, Inc., 889 So.2d 779 (Fla. 2004). An "assault" is an intentional, unlawful offer of corporal injury to another by force, or exertion of force directed t