Epstein Secrets

efforts to communicate with you about any potential problems and hope, in the interest of fairness, you will do the same. Sincerely, 9 :74/1 Jay . Lefkowitz, P.C. Enclosures EFTA00194729 LEOPOLD-KUVIN„ CONSUMER JUSTICE ATTORNEYS July 6, 2009 A. Maria Villafana, Esq. Assistant U.S. Attorney Southe

to your response. Cordially y rs, Robe, D. Critton, Jr. RDC/clz cc by pdf: Jack A. Goldberger, Esq. Martin G. Weinberg, Esq. Roy Black, Esq. Jay Lefkowitz, Esq. EFTA00194734 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CV-80802-MARRA-JOHNSON JANE DOE NO. 8 Plaintiff, JE

lead until the Deputy Attorney General's Office (DAG) completed its review. See Exhibit 9, May 28, 2008 Email from Assistant U.S. Attorney Sloman to J. Lefkowitz. EFTA00194722 • Ms. A. Marie Villafana, Esq. June 19, 2009 Page 4 • A final letter of determination was not issued by the Department of Justic

applicable statute of limitations. As to Count I, which is plead pursuant to state law, it is well settled that this Court is to apply Florida law. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, the statute of limitations for assault and battery is four years, §95.11(3)(o)., Fla. S

or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11 th Cir. 1985), citing Lefkowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege i

intiff's alleged claims in Counts I - Sexual Battery and Counts II - Intentional Infliction of Emotional Distress are also controlled by state law. Erie R.Co. v. Tompkins, 58 S.Ct. 817 (1938). Accordingly, the privileges recognized under state law apply to this action under Rule 501. See, for example, 15

al or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985), citing Lefkowitz v. Turlev 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege is

intiff's alleged claims in Counts I - Sexual Battery and Counts II - Intentional Infliction of Emotional Distress are also controlled by state law. Erie R.Co. v. Tompkins, 58 S.Ct. 817 (1938). Accordingly, the privileges recognized under state law apply to this action under Rule 501. See, for example, 15

at may implicate the NPA. I look forward to your response. RDC/clz cc by pdf: Jack A. Goldberger, Esq. Martin G. Weinberg, Esq. Roy Black, Esq. Jay Lefkowitz, Esq. Cordially y r , Rob D. Critton, Jr. EFTA00183780 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CV-80802-MARRA-J

applicable statute of limitations. As to Count I, which is plead pursuant to state law, it is well settled that this Court is to apply Florida law. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, the statute of limitations for assault and battery is four years, §95.11(3)(o)., Fla. S