EFTA01089193Set 9
2009-06-12174p43,641w
Prosecution Agreement. Our Office
also will review the new pleading in the Jane Doe 101 matter that Mr. Lefkowitz mentioned,
prior to deciding what, if any, remedies we will pursue ... More is required of a plaintiff than to simply allege, as did Jane Doe
101, that she "exclusively seeks civil remedies pursuant to 18 USC 2255." Exhibit 27, Amended
Complaint ... affirmative act
by the plaintiff. No such waiver was filed or even pled. Jane Doe 101 did no more than restate
that her complaint in civil action
https://www.justice.gov/epstein/files/DataSet%209/EFTA01089193.pdf
EFTA00189787Set 9
2009-06-0914p4,999w
liability in those cases where the plaintiff
proceeds exclusively under 18 U.S.C. § 2255. Jane Doe #101 has stated all claims pursuant to 18
U.S.C. § 2255 and is not seeking ... required, but argues that those cases were wrongly decided. In her
Complaint, Jane Doe #101 asserted that Epstein had been convicted of state law crimes and, taking
language directly from ... state charging instrument to show that the state charges do not relate to Jane Doe #101.
Further, he writes, "even if Defendant's state-law pleas did involve state
https://www.justice.gov/epstein/files/DataSet%209/EFTA00189787.pdf
EFTA00722862Set 9
2009-07-0818p4,771w
Podhuret Orseck Josefsberg
25 West Flagler Street
3 Miami, FL 33130
For Jane Doe 101 305.358.2800
4 (Via telephone)
5 KATHERINE W. EZELL, ESQ.
Podhurst Orseck Josefsberg
6 25 West ... Flagler Street
Miami, FL 33130
7 For Jane Doe 101 305.358.2800
8 FOR THE DEFENDANT: ROBERT D. CRITTON, JR., ESQ.
MICHAEL BURMAN, ESQ.
9 Burman Critton, etc.
515 North Flagler
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722862.pdf
EFTA00728842Set 9
2007-12-0622p6,643w
Podhurst Orseck Josefsberg
25 West Flagler Street
3 Miami, FL 33130
For Jane Doe 101 305.358.2800
4 (Via telephone)
5 KATHERINE W. EZELL, ESQ.
Podhurst Orseck Josefsberg
6 25 West ... Flagler Street
Miami, FL 33130
7 For Jane Doe 101 305.358.2800
8 FOR THE DEFENDANT: ROBERT D. CRITTON, JR., ESQ.
MICHAEL BURMAN, ESQ.
9 Burman Critton, etc.
515 North Flagler ... that he filed, the motion
to dismiss the case, I believe it's Jane Doe 101, represented
6 by Mr. Josefsberg, is that that is a case that was filed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728842.pdf
EFTA00726503Set 9
2009-06-1210p2,599w
filed, the motion
5 to dismiss the case, I believe it's Jane Doe 101, represented
6 by Mr. Josefsberg, is that that is a case that was filed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00726503.pdf