Case Document Entered on FLSD Docket Page of EXHIBITB to Plaintiffs Jane Doe and Jane Doe Motion for No-Contact Order Case Document Entered on FLSD Docket Page of Podhurst Orseck TRIAL APPELLATE LAWYERS Aaron Podhurst Robert Josefsberg Joel Eaton Steven Marks Victor Diaz Jr Katherine Ezell Stephen Rosenthal Ricardo Martinez-Cid Ramon A Rasco AlexanderT.Rundlet John Gravante ill Carolina Maharbiz David Spicer Esq I Prosperity Farms Road Suite Palm Beach Gardens FL Robert Critton Esq April VIA FACSIMILE Burman Critton Luttier Coleman LLP North Flagler Drive Suite West Palm Beach FL Jack Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Gentlemen Robert Orseck Walter Beckham Jr Karen Podhurst Dern Of Counsel During our recent meeting with Mr Black we were told that it is your clients position that the no-contact order agreed to during the state plea colloquy does not apply to any of our clients except for those victims who were part ofMr Epsteins state plea Our understanding is that A USA Villafana and Messrs fein and Goldberger entered a verbal agreement at the time that the list of victims was provided to those defense counsel.that Mr Epstein including his agents would have no direct or indirect contact with the victims named on this list In addiditon under applicable Florida Bar Rules governing contact by attomeys and their agents with persons represented by counsel any contact with any of our clients or their family members by Mr Epstein his counsel and/or his agents must strictly be through us Mr Lefkowitz had previously reassured us that Mr Epstein would not contact any of our clients as long as I am representing them in connection with settlement discussions Due to our differences regarding the retroactivity issue and the per plaintiff per incident/count issue we have apparently reached a dead end regarding settlement Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhwst.com Case Document Entered on FLSD Docket Page of We are concerned that Mr Epstein could misconstrue our impasse in conjunction with Mr Lefkowitz e-mail to mean that now that we are no longer representing them in connection with settlement discussions he may contact them Please be assured that itis ourposition that regardless of whether we are representing our clients during settlement discussions and/or trial preparation we and the rules of professional conduct prohibit contact In order to be crystal clear as to whom we represent we have attached a list of our present clients We expect each member of Mr Epsteins defense team to abide by the applicable rules of professional conduct We request written confirmation from Mr Epstein that neither he nor his agents will contact any of the victims represented by us If this correspondence is in any way unclear please contact us Sincerely Robert C.-Jo 247efsberg cc Roy Black Esq enclosures Jay Lefkowitz Esq enclosures Case Document Entered on FLSD Docket Page of List of Clients Represented by Poclhurst Orseck P.A as of April We will supplemenJ:this list as necessary
3,113 characters
