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irls m Florida, New York and on his private island, known as Little St. James, in St. Thomas, 12. An integral player in Epstein’s Florida scheme was Haley Robson, a Palm Beach HERMAN & MERMELSTEIN, P, A. www.hermaniaw.com HOUSE_OVERSIGHT_012638 Comnmnity College student from Loxahatchee, Florida. She recmit
Florida. She recmited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein’s plan, Ms. Robson would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or someone on his behalf d
ring our meeting last Wednesday, November 21°, you and Professor Dershowitz seemed very comfortable, and certainly not surprised, with the selection. Podhurst and Josephsberg are no strangers to nearly the entire Epstein defense team including Guy Lewis, Lili Ann Sanchez, Roy Black, and, apparently, Profess
o have it recopied to have an original in evidence and a working copy with the file. Upon researching the file, it was discovered that the suspect, Haley Robson's cellular calls wer sub oenaed incorrectly. The suspect telephone number was and the original request was for . I requeste t e information through
lalliehinitially denied anything had happened, only admitting to going with Haley (later identif ed as Haley Robson) to Palm Beach to pick up money Robson was owed. identified Haley Robson as the cousin of her former boyfriend She ultimately admitted to knowing that Robson worked for a wealthy man an
ands regarding timing suggest that I have been sitting on my hands for days. You should know that the first time I learned about Judge selection of Podhurst and Josephsberg, and indeed the first time I ever eard their names, was in our meeting with you on Wednesday of last week. Nevertheless, I have now
telephone. computer or any other facility of interstate commerce, hut rather in a nate-to-face discussion with a third party who was her friend (Ms. Robson) and who told her to lie to Mr. Epstein about her age. As such, it is simply impassible to shoehorn this conduct into any of the above-discussed fe
36-CV-MARRA P-013349 EFTA00230254 JAY P. LEFKOWITZ, ESQ. NOVEMBER 30, 2007 PAGE 7 OF 7 The letter's assertions regarding representation by the Podhurst firm and Mr. Josefsberg are accurate and will not be changed. Judge Davis conferred with Messrs. Podhurst and Josefsberg to insure their willingnes
udge Edward B. Davis should be that independent third-party/special master. Ultimately, Judge Davis selected Robert C. Josefsberg of the law firm of Podhurst, Orseck, Josefsberg, et at 10 During this same time frame, Epstein lawyer Jay Lefkowitz sought to delay the entry of his guilty plea and sentence. A
were 18. Q: Who told you that, to say that? A: . (Sworn Statement of 11/8/05). Italey A: I told him I was 18. (Sworn Statement of 10/3/05). • Robson concerning Serina Figueroa: Well with Serina [Figueroa, I don't know how old she is because she lied about her age. She lied to me when I first met
nst Mr. Epstein. The initial draft victim notification letter contained language that confirmed your Office's interpretation and indicated that Mr. Podhurst and Mr. Josefsberg, the selected attorney representatives. may "represent" the identified individuals. This language assumes that the selected repre
Florida asks that you provide the following amended notice to your client, HIOR Some of the information contained in the July 10, 2008 letter to Ms. Robson was inaccurate, so please advise her of the following changes. As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter refe
ncluding you, in connection with civil actions between the victims and Mr. Epstein. The Special Master selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., a highly-respected and experienced attorney. You are not 08-80736-CIV-MARRA 000872 EFTA00189627 MS. NOTIM9IIIIIED VICTIM SEPTEM
diction. (b) There is no ossibili that the plaintiff can establish a cause of action against under Florida law. (i) The conspiracy claim against Robson must fail. As a general rule, "[a]n actionable conspiracy [under Florida law] requires an actionable underlying tort or wrong." Wright v. Yurko, 44
CRIPTION EFTA00180305 Case 0:08-cv 1 2 3 80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 2 of 51 ROBERT C. JOSEFSBERG, ESQ. Podhurst Orseck Josefsberg 25 West Flagler Street Miami, FL 33130 4 For Jane Doe 101 (Via telephone) 5 KATHERINE W. EZELL, ESQ. 6 Podhurst Orseck Jos
Florida asks that you provide the following amended notice to your client, HIOR Some of the information contained in the July 10, 2008 letter to Ms. Robson was inaccurate, so please advise her of the following changes. As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter refe
ncluding you, in connection with civil actions between the victims and Mr. Epstein. The Special Master selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., a highly-respected and experienced attorney. You are not 08-80736-CIV-MARRA 000872 EFTA00210404 MS. NOTIM9IIIIIED VICTIM SEPTEM
telephone, computer or any other facility of interstate commerce, but rather in a face-to-face discussion with a third party who was her friend (Ms. Robson) and who told her to lie to Mr. Epstein about her age. As such, it is simply impossible to shoehorn this conduct into any of the above-discussed fe
no position as to the validity of any such claim under this statute," should be included in any proposed letter. Sixth, your letter states that Mr. Podhurst and Mr. Josefsberg may "represent" the identified individuals. Since we have not yet had the opportunity to speak with Mr. Podhurst or Mr. Josefsbe
Entities connected to both Haley Robson and Podhurst

Jeffrey Epstein
PERSON
United States
LOCATIONLeon Black
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONJack Goldberger
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSONRobert C. Josefsberg
PERSON
Jay Lefkowitz
PERSON
Kenneth Marra
PERSONthe Southern District
LOCATION
Prince Andrew
PERSONRoy Black
PERSONJane Doe
PERSON
A. Marie Villafana
PERSON
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Donald Trump
PERSON
Joe Biden
PERSON