Epstein Secrets

and federal attorneys or agents. We have no objection to sending the letters through the mail' but we will not remove the language about contacting AUSA Villafafia or Special Agent Kuyrkendall with questions or concerns. Again, federal law requires that victims have the "reasonable right to confer with the att

ng suit. A violation of this provision, by contesting jurisdiction or otherwise, will be considered a material breach. It had been my suggestion to AUSA Villafafia that we simply quote the terms of the Agreement directly into the Notification Letter or include a photocopy of the relevant sections. If you would

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

hment, not the civil litigation. Those questions are appropriately directed to law enforcement. If questions arise related to the civil litigation, AUSA Villafafia and Special Agent ICuyrkendall will recommend that the victims direct those questions to Mr. Josefsberg. I have attached a revised letter incorpora

t. Next, you assert that our letter mischaractcrizes Mr. Epstein's obligation to pay damages to the victims. To avoid that suggestion, I have asked AUSA Villafafia to simply quote the terms of the Agreement directly into the Notification Letter. We also have no objection to referring to Mr. Epstein as a "sexua

377I(a)(8). We will not include any language that demeans the harm they may have suffered. The letter's assertions regarding representation by the Podhurst firm and Mr. Josefsberg are accurate. Judge Davis conferred with Messrs. Podhurst and Josefsberg to insure their willingness to undertake this assi

urt. Next, you asSert that our lefteriniStharactenzes1C1rEpstein's obligation to pay damages to the victims. To avoid that suggestion, I have asked AUSA Villafafia to simply quote the terms of the Agreement directly into the Notification Letter. We also have no objection to referring to Mr. Epstein as a "sexua

IN, Defendant. PLAINTIFF'S RESPONSE TO DEFENDANT'S AMENDED NOTICE AND MOTION FOR LEAVE TO DEPOSIT FUNDS INTO THE REGISTRY OF THE COURT Plaintiff, Podhurst, Orseck, P.A., submits this Response to the Amended Notice and Motion For Leave to Deposit Funds Into the Registry of the Court filed by Defendant,

urt. Next, you asSert that our lefteriniStharactenzes1C1rEpstein's obligation to pay damages to the victims. To avoid that suggestion, I have asked AUSA Villafafia to simply quote the terms of the Agreement directly into the Notification Letter. We also have no objection to referring to Mr. Epstein as a "sexua

IN, Defendant. PLAINTIFF'S RESPONSE TO DEFENDANT'S AMENDED NOTICE AND MOTION FOR LEAVE TO DEPOSIT FUNDS INTO THE REGISTRY OF THE COURT Plaintiff, Podhurst, Orseck, P.A., submits this Response to the Amended Notice and Motion For Leave to Deposit Funds Into the Registry of the Court filed by Defendant,

hment, not the civil litigation. Those questions are appropriately directed to law enforcement. If questions arise related to the civil litigation, AUSA Villafafia and Special Agent Kuyrkendall will recommend that the victims direct those questions to Mr. Josefsberg. I have attached a revised letter incorporat

3771(a)(8). We will not include any language that demeans the harm they may have suffered. The letter's assertions regarding representation by the Podhurst firm and Mr. Josefsberg are accurate. Judge conferred with Messrs. Podhurst and Josefsberg to insure their willingness to undertake this assignmen

ng suit. A violation of this provision, by contesting jurisdiction or otherwise, will be considered a material breach. It had been my suggestion to AUSA Villafafia that we simply quote the terms of the Agreement directly into the Notification Letter or include a photocopy of the relevant sections. If you would

to create a false impression that we do not believe in the validity of the victims' claims. 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

meet with her but she said that she believed such a meeting would be premature. In December, Lilly Ann Sanchez and Gerald Lefcourt again contacted AUSA Villafafia to set a meeting. In advance of such a meeting, AUSA Villafafia requested documents but that request was refused. Ms. Sanchez then contacted AUSA L

t Court Judge Edward B. should be that independent third-party/special master. Ultimately, Judge selected Robert C. Josefsberg of the law firm of Podhurst, Orseck, Josefsberg, et all During this same time frame, Epstein lawyer Jay Lefkowitz sought to delay the entry of his guilty plea and sentence. Af

e S. Fisher, as well as the Criminal Division's Appellate Section and the Office of Enforcement Operations regarding the petit policy. By May 2007, AUSA Villafafia began seeking approval from her supervisors to indict Epstein. Her immediate supervisor was Andrew Lourie. Mr. Lourie had served as the Chief of the

rict Court Jude Edward B. should be that independent third-party/special master. Ultimately, Judge selected Ro rt . Josefsberg of the law finn of Podhurst, Orseck, Josefsberg, et a l° During is same time frame, Epstein lawyer Jay Lefkowitz sought to delay the entry of his guilty plea and sentence. Afte

the meeting was put o ff until September 7, 2007, despite the fact that the indictment was ready for presentation to the grand jury. In the interim, AUSA Villafafia and the investigators met with the Chief of the Child Exploitation Section, Drew Oosterbaan, to review, yet again, the evidence and legal theories

rding timing suggest that I have been sitting on my hands for days. You should know that the first time I learned about Judge Davis's selection of Podhurst and Josephsberg, and indeed the first time I ever heard their names, was in our meeting with you on Wednesday of last week. Nevertheless, I have now

The Section 2255 provision issue was first discussed at a July 31, 2007, meeting between FAU SA , Criminal Chief_, West Palm Beach Chief Lourie, AUSA Villafafia, and two FBI agents who met with Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. On that date, the prosecutors presented a written, four-bullet-

g our meeting last Wednesday, November 21th, 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, Profe