Epstein Secrets

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

of the offense (e.g., 2004-5) govern the minimum statutory damage amount (t50,000 rather than $150,000) under ex post facto laws, see United States I. Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)? Black,

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

009); Doe No. 4'. Epstein 2009 WL 383286 (S.D. Fla. Feb. 12, 2009); and Poe No. 51. Epstein 2009 WL 383383 (S.D. Fla. Feb. 12, 2009); see also U.S. I. Scheidt, Slip Copy, 2010 WL 144837, fn. 1 (E.D.Cal. Jan. 11, 2010); U.S. I. Rain, 2009 WL 2579103, fn. 1 (ED. Cal. Aug. 19, 2009); U.S. I. Ferenci, 2009 WL

33132 BLACK SREBNICK KORNSPAN & STUMPF =PA.= March 5, 2010 , Esq. Assistant United States Attorney 99 N.E. 4i° Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: JESSIC.A ForisEC-A-NADER ICATEazur P. PHILLIPS AARON AMMON MARCOS BEATON, JR. MATTHEW P. OBRIEN JEPHPER J. SOUUKULS NOAH Fox R

Attorney 99 N.E. 4th Street Miami, FL 33132 We write this letter to renew our request that the United States Attorney's Office provide us, as Mr. Epstein's counsel in the federal NPA matter, with clarity as to what legal issues we can advise his civil counsel can be litigated without causing you to c

torney 99 N.E. 4i° Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: JESSIC.A ForisEC-A-NADER

e United States Attorney's Office provide us, as Mr. Epstein's counsel in the federal NPA matter, with clarity

could 'agree" to the occurrence of a predicate pursuant to his NPA obligations but still contest that the plaintiff was injured, see United States I. Scheidt, supra (finding each to be a separate element) and the letter from Mr. Acosta to Mr. Starr, supra December 4, 2007 letter at p.2 which agrees that