10/22/2009

10/22/2009 11:08 POWURST.ORSECK 4 9624130606015618446929# NO.641 9002 'ROW DA 1O41O =IMO OM num. *a1Q. lAcv4.4:1O To PracricE Av ittirlDh ANO COLORADO Sent by Eat! Only Robert Josefsberg, Esq. Re: Settlement Negotiations Dear Bob: WA BuRtvimi..CRrrrom LUTTIER&COLEMAK LLP YOUR TRUSTED ADVOCATES A tune tummy PASONEEOHIP ). MICHAEL MIRIAM. PA.I2 ADELQiii J. liet4AVEini OnaoKe W Cosmos. PA PAMLIcaLlitivtrnalaDO. BMW D. CRITTON. JP- PA' Moat 0.Dwiii. BERNARD A. UMEDIVC,Ut Scull 14. McMinn WART. Eurnia PA AStitni STOnti-duumo linty C. Pflug BETTY STOKES sucHAEL). PIKE ba4KA4 Roans. mCI4MAARA RUM MA H. StioNYK October 19, 2009 Or Kahan DAVID A YAILDAA Imo= M. Rica RAOEKte As per our discussion on September 25th followed by your e-mail and my e-mail, g Jane Doe 101, Jane Doe 102 and all of your other clients, except for We have also agreed as part of the above settlement to certain additional terms, although it will not be in any of the settlement documents In that the releases and/or settlement agreements are specific to the individuals. We agreed that you would join us (agree that the court has Jurisdiction to consider the action, but not necessarily concede Jeffrey Epstein is correct as to points which might be plead) in any declaratory Action that is Bled. These issues may include: 1. Which version (year) of §2255 Is applicable based on the facts alleged; whether the minimum amount of damages under §2255 is $50,000 versus $150,000; whether multiple predicate acts can be plead; whether multiple occurrences (violations) can be plead, whether a plaintiff is entitled to only a single recovery;, whether Jeffrey Epstein can test the veracity of a plaintiff; and whether Mr. Epstein can assort statutes of limitation as an affirmative 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 P*It)bM WWW.13CLCLAW.COM • FAX: EFTA00723762 ij Ir 10/22/2009 11:00 PODHURST.OPSECKi 9624e32200415610446929e. 0CT-21-2009 WED 04:31 RI TISBURY PRINTER NO.641 0083 FP.X NO. 50889370S8 P. 02 10/21,2029 16343 FamuneT.OeXck 4 9624W.99244.5e269379e.ett No.535 VeAm October 'Is, 2009 Pass 2 individuals whom you indimtelSt ipraivlousty conctod. Wo also would agree b a further toillog agreement for We would however ac-ect, that you would not tun out and in any way dente • RSV, t Would expect that nelther you nor any °that lawyers or otaff would share any detas of our negolkallons or settlements, agreed? If the above I acceptable, please =infirm In writing In that these terms Were Pact of cur overact suthernemt itericrSatlorts and were and are owlerial to resoluffon. 1:2DCICIZ co: by e-mail Jack Goldbergcr, Esc- Katherine Ezell, Esc, Agreetl, tempt td note that we have no authceitjr to detTerninewhat constinites a breach ofthe Nog-Prosecution Agreement, which is the province of the United States Atticeuers Office. . Dzted: In rc).O •• • EFTA00723763