but based on the belief that a guardian ad litem would not be appropriate lbr adults that are capable of making their own decisions. Ilowever. the IJSAO included into the Agreement that we pay Ibr the attorney representative -- when originally Ms. Villafana stated that the representative could he paid

shall produce the Non-Prosecution Agreement, including any modifications and addenda thereto, in accordance with the following procedures: (a) The IJSAO shall produce a copy of the Non-Prosecution Agreement, including any modifications and addenda thereto (collectively referred to as the "Agreement")

d. Needless to say. we were elisi alarmed that Ms. would attempt to influence the settlement process on such improper grounds. And even alter the IJSAO conceded that it was inappropriate for its attorneys to select the attorney representative. Ms. Villafana continued to improperly lobby for Mr. Ocar

k of suppo Mt. E ein's offer of $50,000 to resolve claims that are not time-barred (as we believe claim to be), without any On several occasions, IJSAO representatives have asserted that the government takes no position as to the claims of the individuals identified as alleged victims. For the sake

tified individuals, raises cause Ibr concern as to the nature of all conununications that are made to the 'victims.' You previously stated that the IJSAO's main objective with respect to the Section 2255 component of the Agreement was to -place the victims in the same position as they would have been

ports to prohibit any further cantata between Mr. lipskirrk defense learn and U.S. Attorney Acosta. and instead requires us to communicate with the IJSAO only though Mr. Sloman's subordinatcx. While it pains us to say this, this misguided proscouion lion, the ukase! gives (he appearance that il may h

vestigation into allegations of improper sti 2006 Thomson/West. No Claim to Orig. U.S. Govt. Works. EFTA01699660 09/06/2006 20:43 FAX 5618021787 IJSAO ¶VFB FL tN06 832 F.2d 554 (Cite as: 832 F.2d 554, 955) influence peddling by certain public officials of the City of Jacksonville. Witnesses ap

utgrowth of the fact that civil settlement. as opposed to restitution. is considered in the Agreement, A. Rule of the Attorney Representative The IJSAO has improperly emphasised that the chosen Bonney representative should be able to litigate the claims of individuals, which violates the terms, and

fendant gives up certain rights to contest liability for a chill mettle specifically. Ms. • ' not believe there wits room for contention given the IJSAO's, and ultimatums that required that we acquiesce to these unprecedented terns. Concerns Iteaardinu Section 2253 Mr Epstein unconditionally re-as