DocumentCloud_Epstein_Docs_p01495.png

Case 18-2868, Document 283, 08/09/2019, 2628241, Page528 of 883 MS. VIRGINIA ROBERTS a NOTIFICATION OF IDENTIFIED VICTIM SEPTEMBER 3, 2008 PAGE 2. OF 3 Special Master selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., ahighly-respected and experienced attorney. You are not obligated to use Mr. Josefsberg as your civil attorney, but, as explained in greater detail below, Mr, Josefsberg’s services will be provided atno | cost to you because Mr. Epstein is obligated to pay the costs and fees of the attorney-representative. Also, Mr. Epstein and his attorneys can only contact you via Mr, Josefsberg, assuming that you would like Mr. Josefsberg to serve as your attorficy. 2. If you elect to file suit against Mr, Epstein pursuant to Title 18, United States Code, Section 2255, Mr. Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Mr. Epstein waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between you and Mr. Epstein, so long as you elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any. other claim for damages, whether pursuant to state, federal, or common _law. Notwithstanding this waiver, Epstein’s agreement with the United " States, his waivers and failure to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability. 3. ‘As stated above, Mr. Epstein has agreed to pay the fees of the attorney representative selected by the independent third party. This provision, _ however, shall not obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, if after consideration of potential settlements, you and Mr. Josefsberg elect to file a contested lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other contested remedy, the obligation to pay the costs of the attorney representative, as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs such as those contained in Section 2255, shall cease. Please contact either myself at ann.marie.c.villafana@usdoj.goy, or Justice Department Victim- Witness Specialist Twiler Smith at Twiler, Smith@ic.fbi.gov with a good telephone number and/or e-mail address, so that we may provide Mr, Josefsberg with a timely means of communicating with you, If you would like to contact Mr. J osefsberg een