EFTA00723762.pdf

11:08 POWURST.ORSECK 4 9624130606015618446929# NO.641 9002 10/22/2009 BuRtvimi..CRrrrom W LUTTIE A YOUR R&COLEMAK LLP TRUSTED ADVOCATES A tune tummy PASONEEOHIP ADELQiii J. liet4AVEini ). MICHAEL MIRIAM. PA.I2 PAMLIcaLlitivtrnalaDO. OnaoKe W Cosmos. PA Moat 0.Dwiii. BMW D. CRITTON. JP- PA' Scull 14. McMinn BERNARD A. UMEDIVC,Ut AStitni STOnti-duumo WART. Eurnia PA BETTY STOKES linty C. Pflug ba4KA4 sucHAEL). PIKE MA H. StioNYK Roans. mCI4MAARA RUM 2009 Or Kahan DAVID A YAILDAA October 19, Imo= M. Rica 'ROW DA 1O41O =IMO OM num. *a1Q. RAOEKte lAcv4.4:1O To PracricE Av ittirlDh ANO COLORADO Sent by Eat! Only Robert Josefsberg, Esq. Re: Settlement Negotiations Dear Bob: your e-mail and my e-mail, As per our discussion on September 25th followed by s, except for g Jane Doe 101, Jane Doe 102 and all of your other client certain additional terms, We have also agreed as part of the above settlement to In that the releases and/or although it will not be in any of the settlement documents settlement agreements are specific tothe individuals. has Jurisdiction to We agreed that you would join us (agree that the court Epstein is correct as to points consider the action, but not necessarily concede Jeffrey These issues may include: which might be plead) in any declaratory Action that is Bled. d on the facts alleged; 1. Which version (year) of §2255 Is applicable base §225 5 is $50,000 versus whether the minimum amount of damages under whether multiple $150,000; whether multiple predicate acts can be pleadis; entitle d to only a occurrences (violations) can be plead, whether a plaintiff veracity of a plaintiff; single recovery;,whether Jeffrey Epstein can test the as an affirmative and whether Mr. Epstein can assort statutes of limitation defense. We had also a ould not represent any additional females who are on the list, other than whom your firm currently represents. In hindsight, this appears to be an unreasonable request, and t is no longer a condition. We expect that you :Will continue to represent and may represent other • FAX: P*It)bM WWW.13CLCLAW.COM EFTA00723762  10/22/2009 11:00 PODHURST.OPSECKi 9624e32200415610446929e. NO.641 0083 0CT-21-2009 WED 04:31 RI TISBURY PRINTER FP.X NO. 50889370S8 P. 02 No.535 VeAm 379e.ett 10/21,2029 16343 FamuneT.OeXck 4 9624 W.99244.5e269 October 'Is, 2009 Pass 2 Wo also would agree b imtel St ipraivlousty conctod. individuals whom you ind nt for a further toillog agreeme y way -ect , tha t yo u wo uld not tun out and in an We would however ac dente are yo u no r an y °th at lawyers or otaff would sh ct that nelther RSV, t Would expe llons or settlements, agree d? any detas of our negolka ct • as e =in fir m In wr itin g In that these terms Were Pa If the above I acceptarSa ble, ple resoluffon. rne mt ite ric tlo rts an d we re and are owlerial to of cur overact suthe 1:2DCICIZ co: by e-mail Jack Goldbergcr, Esc- Katherine Ezell, Esc, au thc eit jr to de tTe rni ne wh at constinites a breach ofthe ve no . Agreetl, tempt td note that we ha is the province of the United States Atticeuers Office. nt, wh ich Nog-Prosecution Agreeme Dzted: In r c).O Ir ij •• • EFTA00723763