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that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the N
ve of the $526,466 already paid by Mr. Epstein - meet the criteria set forth by the NPA. We assure you that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the NPA language, and Mr. Critton, each strongly believe that significant amounts of the fees and costs
belief, ROTHSTEIN and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff an
naming additional Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Bamett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about th
ly Grail" (Ex. F), a "journal" assertedly taken from Epstein's computer and cited by Edwards inn 16-18; correspondence between the U.S. Attorney and Jay Leflcowitz, Esq. (Exs. C and D and 9fq 6, 20, 25) and Lilly Ann Sanchez, Esq. (Ex. L andl 28); a book receipt (Ex. I and 1 22), message pads (Ex. A. 1 24) and
ricken. Finally, inadmissible and improper triple hearsay forms the basis of the "facts" set forth in ¶ 80, in which Edwards cites the affidavit of Michael Fisten (Ex. QQ), an investigator who recounted what George Rush, a New York Daily News reporter, told Fisten what Epstein had said in an interview with Ru
n which Edwards cites the affidavit of Michael Fisten (Ex. QQ), an investigator who recounted what George Rush, a New York Daily News reporter, told Fisten what Epstein had said in an interview with Rush. EDWARDS' "FACTS" PERTAINING TO OTHER PURPORTED ACTS OR WRONGS ARE NOT PROBATIVE AND ARE HIGH
PIKE: Form. And move to strike. THE WITNESS: Mr. Roy Black. BY MR. SCAROLA: Q. Okay. Who else? A. Mr. Marty Weinberger. Mr. Alan Dershowitz. Mr. Jay Lefkowitz. The firm of Burman Critton Luttier. That's it for the moment. Q. How much have you paid the law firm of Burman Critton and Luttier which you clai
r words, a party cannot be found liable solely upon the basis of reliance on Fifth Amendment; there must be other evidence. Baxter, 425 U.S. at 318; Lefkowitz, 431 U.S. at 808, n. 5;Lasalle Banks Lake View v. Seguban, 54 F.3d 387 (7th Cir. 1995); National Acceptance Co.of America v. Bathalter, 705 F.2d 92
f illegal activities, wire taps, and methods by the Rothstein firm while Mr. Edwards had basically been bringing these cases. The investigator, Mr. Fisten, who's mentioned in the Complaint, represented himself as an FBI agent, falsely represented himself as an FBI agent. BY MR. SCAROLA: Q. Do you ha
al mseimien-ef-that-investigatienr Edwards-Deelaratien-at--11-147 33. On about February 25, 2008, Assistant U.S. Attorney Sloman sent an e-mail to Jay Leflcowitz„ a copy of which is attached hereto as Exhibit _.Bpsteinls—eriminal—defense eeunselr explaining that the Justice Department's Child Exploitation Obsc
ter Relantionulso-is-felling-Chief Reiier-not4O-diselose the-eufeente-fe-anyene 4-2, On about September 25, 2007, AUSA Villafafia sent an e-mail to Lefkowitz, a copy of which is attached hereto as Exhibit stating.-11And-ean-we-itaye-a-eenferenee-edi-te-disesss what-I-may-diselese-to,the-gek-regarding-th
ay. Michael Fitters. tut Investigator worlong for Doe, discovered the ultimo, of the tape in fall 2009. An author who had listened to the tape told Fisten that Rush had a tape retorting of Epstein 'discussing the sexual ribose of minor gins' According to a sworn affidavit by Ratan. he cared Rush. who
mpelled in any Criminal Case to be a witness against himself" (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 ( 1 1 th Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in favor of the right and extends not only to answers that would
ld this court order production of same after an in camera inspection) must be redacted to secure the names of unsuspecting third-parties. Moreover, Michael Fisten (formerly an employee of RRA and now an employee/independent contractor of Mr. Edwards' firm) acted, upon information and belief, as a broker or mid
compelled in any Criminal Case to be a witness against himself." (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley. 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in favor of the right and extends not only to answers that would
ld this court order production of same after an in camera inspection) must be redacted to secure the names of unsuspecting third-parties. Moreover, Michael Fisten (formerly an employee of RRA and now an employee/independent contractor of Mr. Edwards' firm) acted, upon information and belief, as a broker or mid
Epstein's civil exposure. For example, on October 3, 2007, Assistant U.S. Attorney Marie Villafafia sent an email (attached hereto as Exhibit “D”) to Jay Lefkowitz, counsel for Epstein, with attached proposed letter to special master regarding handling numerous expected civil claims against Epstein. The letter r
Page: HOUSE_OVERSIGHT_010570 →s Attorney's Office prepared negotiated plea agreements containing these charges. For example, in a September 18, 2007, email from AUSA Villafafia to Lefkowitz (attached hereto as Exhibit “H”), she attached the proposed plea agreement describing Epstein’s witness tampering as follows: "UNITED STATES vs. JE
Page: HOUSE_OVERSIGHT_010575 →ther harassing actions against Jane Doe also followed. See Motion for Contempt filed by Edwards in Jane Doe v. Epstein detailing the event, including Fisten Affidavit attached to Motion, Composite Exhibit “RR.” Epstein Settlement of Civil Claims Against Him for Sexual Abuse of Children 84. The civil cas
Page: HOUSE_OVERSIGHT_010601 →pstein's civil exposure. For example, on October 3, 2007, Assistant U.S. Attorney Marie Villafafia sent an email (attached hereto as Exhibit “D’’) to Jay Lefkowitz, counsel for Epstein, with attached proposed letter to special master regarding handling numerous expected civil claims against Epstein. The letter r
Page: HOUSE_OVERSIGHT_013323 →es Attorney's Office prepared negotiated lea agreements containing these charges. For example, in a September 18, 2007, email from AUSA Villafafia to Lefkowitz (attached hereto as Exhibit “H’), she attached the proposed plea agreement describing Epstein’s witness tampering as follows: "UNITED STATES vs. JE
Page: HOUSE_OVERSIGHT_013328 →ther harassing actions against Jane Doe also followed. See Motion for Contempt filed by Edwards in Jane Doe v. Epstein detailing the event, including Fisten Affidavit attached to Motion, Composite Exhibit “RR.” Epstein Settlement of Civil Claims Against Him for Sexual Abuse of Children 84. The civil case
Page: HOUSE_OVERSIGHT_013354 →Entities connected to both Jay Lefkowitz and Michael Fisten

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONLeon Black
PERSONJack Goldberger
PERSONRoy Black
PERSON
A. Marie Villafana
PERSON
Kenneth Marra
PERSON
United States
LOCATIONJane Doe
PERSON
Jeffrey Sloman
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSONMartin Weinberg
PERSONthe Southern District
LOCATION
Alan Dershowitz
PERSON
George W. Bush
PERSONRobert C. Josefsberg
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
Paul Cassell
PERSON