EFTA01154516.pdf

I am in receipt of your letter dated June 15. I am sorry to read it as I sense your frustration with the entire matter, however, I write to try to set the record straight. Your letter is filled with misstated facts , miscahreceratizaions, and misrepresentations . in many instance that directly contradicts the written record, IN each instance where you have suggested a breach in the past I have attached ,the releveant correspondence or documents, that clearly refute some of your statements. I would remind you that mr Epstein has almost completed his couty jail sentence. Of 18 months. A sentence of incarceration that he took only as a result of your deferring prosecution. He plead guilty to a registrable offense as your required and has already registered as a sex offendfer. He has paid over 10k thousand dollars in fees to the attoruny reperesnt ive and have paid out 150 thoussand dollars in settlements to victims on your lislt„ in one case to someone , he had no recolecction of meeting, and who was not challeneged to provide any evience to test the veracity of her claim. To begin you suggest that Mr Epstein did not use hid best efforts to enter his guilty plea, as I am sure you reember this was done with the personal consent of alex accost the us attorney, whose e mail to that regard is attached. The nine month delay was dictated by the justie depatanets time frame. When in late June, when the last appeal was exhausted , we had only one week to plead,. We sent the state plea to you , as soon as we received it. It had only been prepared by the state the day before. When you sent your first notice, you may have forgotten, that jack Goldberger and you had agreed „in fact that the language was correct. And only at your insistince did you want tl insert the word jail sentence, this was done , and the state plea agreement was drafted by the state prosecutor not Mr epstiens attorneys. So I find your claim of breach inaccurate. 2. you then clai that mr Epstein attorney obstructed your ability to notify victims s. we took issue with your procedure but that was reflected in coorespondence from months before. (JACK WE Need of provide letters compling about the victim noifaction procedure. JAY). 3. If you recall you presented my Goldberger and tein with a fete comple, they at the time eithr approved or disapproved .. corresondence attached. 4. as soon as the operative provision for attny rep was confirmed, if you recall you suggested that mr acostas paragraph , re as if convicted no more no less was the operative languge. As soon as it was agreed that the attorney rep was now the way to go, we immediately contacted mr jos bur who had conversatonwws with both mr black and mr lefcourt. I reiterate , that he has been paid over 160 I k thousand dollars to date, for only two cases that settled. Each for 50 thousand dollars. And has billed and addtionla 230k which we have decided to have a third party resolve. 5. with regard the outstanding motion to quash , you are 100% right, and it was an administarvie oversight, that was cleared up , when we were notified that it had not been done previously. ( Mr Epstein was alreadly incarcerated, and played no role whatsoever in that oversight )> 6. in novermber if you recall mr black met with you and in Miami , and reviewed the work release issue. We presented you with your own e amil that acknowledged the sheriffs discretion in the matter. WE were EFTA01154516 under no pbligation to notify you, and as you had had previous contact with the office over the exact matter at hand. As to your requirments and obligation s to your victims , the state was never given their names, and to the best of our knowledge it was there obligation not ours in any way to notify you. ( e mail attached ) the sheriff reviewed his documents . and found no problems.. your allegation that Mr Epstein made threaeting stateents to the sheriffs office. Is just not true. We can document this , if you so prefer. There was nothing out of the oridinary , he was treated like any other inmate, and if any different at all , it was he was kept in jail longer than he would would have otherwise been. 7. I am surprised to see you once again suugest that the judges order correcting her clearks scrivner error, as somehow an Epstein didrected breach. We had nothing to do with this whatsoever. The non prescutin agreement called for community control and the plea agreement called for community control 1. In advertantly the clerk, checked the wrong box, the plea agreement was always clear. It was nothing more that a clearks error, to suggst otherwise, can only be as a result of the lack of the actual facts. To suggest that by askin g the clerk to change the error to the right bax is a meaningless cure, makes little sense. 8. mr Epstein does not work at his attorneys office. I believe we have corrected you on that fact more than onve.. 9. We have sent you a separate letter that describeds the motion to dismss. A document that we can review together. This document was never signed off on by mr epstinbut was in fact vetted by many of his coucsel, It waw s drafted by myself and the Kirkland and elllis team. WE took the lead as there would be we thought no better firm to do so as we had negotiated the agreement with you. As I mentioned on the phone , the waiver that mr Epstein agreed to was not triggered due to an incompet filing in jane de 101. We only waive liality , when there is a waiver of all other state and common law claims . in addtion we were asking the court, to opine on the applicability of the statute to this particular women. 9. you suggest that mr esptein is working on nothing but his litiagation but that is also not true. 10. mr Epstein , who has almost completed hi s incarecetaive sentecen , and as registered as a sex offender hs already been predgjcided.. he would have never plead guilty to a registrable offeenc e . or as you recall the statue to which he was indicted carried no jail time . 3 of your vicims have already been compensated, and we have been in negoatioation to settle more cases. The pattern of behavior that you refer to , as you can see from the above , shows no willful breach, at all. Many misunderstanding , confirmed by the attachments, and we would hope that we could have the oppottunity forastall 1 any future misundetaings by being able to present to you before filing anything we think you might find as a breachj. EFTA01154517