EFTA00184224

Case 9:08-cv-80736-KAM Document 362-61 Entered on FLSD Docket 02/10/2016 Page 3 of 4 
KIRKLAND & ELLIS LLP 
AM. Millinfill PARINIteithr% 
Jay P. Lolkowilz. 
To 
Wnlor Dhotily 
)446.4970 
lalkowils(Okoklancl.con) 
CiUgroup CAME 
163 Eart G9t0 SVool 
Now York. Now York 10022.4011 
VIA FACSIMILE 
X20-4777 
A. Marie Villalam 
United States Attorney's Office 
West Palm Beach, Florida 33401 
Dear 
(212)440.4000 
wWWJWICIOnd Win 
August I R, 2008 
Re: deity Epstein 
nestrtolu: 
) 4A13.4900 
I write in response to your letter dated August 15. 2008 regarding the civil restitution 
portion of the Deferred Prosecution Agreement (the "Agreement"). Thank you for tumlIrmIng 
our position that 
ember modification proposal is not port of the Agreement. As expressed 
by U.S. Attorney 
in his December I 0. 2007 letter, the unorthodox use of a civil restitution 
'statute in a federal plea agreement. which resulted in state charges against Mr. Epstein. has 
caused several miscommunications with respect to the implementation of the terms of that 
Agreement. In order to avoid any further miscommunications and to ensure that the 18 U.S.C. 
2255 aspects of the Agreement are carried out in a proper manner. it would he useful to come 
to an agreement us to the implementation of the civil restitution portion of the Agreement, As 
we have previously stated. Mr. Epstein %Hy intends to chide by the terms of the Agreement, and 
we hope you appreciate that our efforts to resolve any misunderstandings between Mr. Epstein 
and the government about the terms of the Agreement are intended only to ensure that it is 
carried out 'tiny and fairly. 
In an effort to avoid having either party unintentionally breach the Agreement. we 
suggest that steps he taken to clarify the meaning of paragraphs 7-10. It would he extremely 
helpful to both sides to have an independent third patty consider the Agreement and offer the 
final word on how certain clauses should be interpreted and satisfied. Because the government 
has already enlisted Judge 
to select the attorney representative under the Agreement. we 
would be amenable to his serving in this role. 
In order to come to un agreement on the exact procedure by which the identifitxl 
individuals will obtain restitution. 1 am providing you with our thoughts on three issues below, 
Cnagn 
Hong Kong 
London 
08-80846siOil&MAIIRRtunica 
son ramose* RFP 
EFTA00185164

Case 9:08-cv-80736-KAM Document 362-61 Entered on FLSD Docket 02/10/2016 Page 4 of 4 
III 10%001 uuu 
KIRKLAND & ELLIS LLP 
A. 
V il lama 
Aueust 18.2008 
Page 2 
Once we come to an agreement on the fallowing and you provide a complete and final list of 
identified individuals, it will be appropriate to notify them. 
First. 1 am concerned by your suggestion that you might want to increase the number of 
individuals on the government's list. 1 had expected the number to have become smaller, 
because when we spoke prior to signing the agreement you told me that the government already 
had a list. and we were informed thereafter that the September 2k 2007 list had been narrowed. 
Cenninly. anyone who was not on the list prior to September 24. 2007 cannot permissibly he 
added to the list. 
Second. we will cooperate with the government to reach to an agreement as to substance 
of the notification to be sent to the government's list of individuals. Based on the Agreement. 
the information contained in the notification should he limited to (1) the language provided hi the 
Agreement dealing with civil restitution (paragraphs 7-10) and (2) the contact ink:inflation of the 
selected attorney representative. We object to the inclusion of additional information about the 
investigation of Mr. Epstein, the terms of the Agreement other than paragraphs 7-10, and the 
identity of other identified individuals. 
Third, as you are aware, the Addendum requires that "the parties will jointly prepare a 
short written submission to the independent third-puny regarding the role of the attorney 
representative and regarding Epstein7s Agreement to pay such, attorney representative his or her 
customary hourly rate for representing such victims subject to the provisions of Paragraph C. 
infra: We will certainly cooperate with the government to drat% such a joint submission and 
would he pleased to submit droll language to you for such a joint submission. 
I look forward to working with you to resolve these matters. I believe we have a mutual 
• interest in moving past all of these issues so that the civil restitution aspects of the Agreement 
can be fulfilled. 
Sincerely. te
1.elkowuz 
cc: 
Karen Atkinson. Chief. Northern Division 
08-80736-CV-MARRA 
RFP WPB 000583 
EFTA00185165

Case 9:08-cv-80736-KAM Document 362-62 Entered on FLSD Docket 02/10/2016 Page 1 of 3 
EXHIBIT 
132 
EFTA00185166

Case 9:08-cv-80736-KAM Document 362-62 Entered on FLSD Docket 02/10/2016 Page 2 of 3 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, Ste 400 
ch. FL 33401 
Facsimile: 
August 21, 2008 
DELIVERY BY ELECTRON C MAIL 
Jay P. Lefkowitz, Esq. 
Kirkland & Ellis LLP 
Citi rou Cen 
New York, New York 10022-4675 
Roy Black, Esq. 
Black Srebnick Kornsiiiiipf 
P.A. 
201 S. Bisca ne Blvd, 
Re: 
Jeffrey Epstein 
Dear Jay and Roy: 
Thank you for your response to my earlier letter. The U.S. Attorney's Office shares 
in your desire to implement all of the terms of the N
i llosecution Agreement. As you arc 
aware, the jointly-approved Special Master, Judge 
, has already selected an attorney 
representative, Robert Josefsberg, who was accepted by both parties. The Office has 
conferred with Mr. Josefsberg, who has agreed to continue in that role. In October 2007, Mr. 
Josefsberg expended time, effort, and funds in preparing to serve as the attorney 
representative, and he will need a written confirmation from you that his future fees and 
expenses will be paid in accordance with the terms of the Non-Prosecution Agreement. 
Please provide me with a copy of that correspondence for my file. 
With that matter settled, I believe that the requirement for a joint written submission 
to the Special Master has been extinguished. Nonetheless, I have no objection to attempting 
to create a joint statement to atilt Mr. Josefsberg in serving his duties. Regarding your 
suggestion that we ask Judge 
to "offer the final word on how certain clauses should 
be interpreted and satisfied," I believe that the Agreement speaks for itself. 
08-80736-CV-MARRA 
REP WPB 000587 
EFTA00185167

Case 9:08-cv-80736-KAM Document 362-62 Entered on FLSD Docket 02/10/2016 Page 3 of 3 
JAY P. Lupsowra, Eso. 
ROY BLACK, ESQ. 
Auoun 2I, 2008 
PAon 2 or 2 
Pursuant to the terms of the Agreement, following Mr. Epstein's sentencing, the U.S. 
Attorney's Office provided Mr. Epstein's counsel with a list of the individuals whom it was 
prepared to name in an indictment as victims of an offense enumerated in 18 U.S.C. § 2255, 
and none of those names will be deleted. By his agreement, Mr. Epstein sought to resolve 
liability for all criminal activity known to the United States as of the time of his plea and 
sentencing, and he is responsible for damages to all victims of that criminal activity. 
Copies of the victim notifications will continue to be provided to counsel for Mr. 
Epstein. Please let me know whether I should continue to list Mr. Goldberger as the point 
of contact for the civil litigation. Regarding your suggestion on the content of the 
notification letters, I intend to use the same format that was used in the letters previously 
approved by Messrs. Goldberger and Tein, except that I will include the language from the 
September and October agreements. I have enclosed a draft herewith. Because I previously 
provided the victims with incorrect information—albeit with the approval of Mr. Epstein's 
counsel—it is imperative that I correct the error promptly. Accordingly, if' you have any 
substantive objections to the letter, please advise me by tomorrow afternoon, 
By: 
Sincerely, 
United States Attorney 
tiAge
tfr
e—
Assistant United States Attorney 
cc: 
Karen Atkinson, Chief. Northern Division 
08-80736-CV-MARRA 
RFP WPB 000588 
EFTA00185168

Case 9:08-cv-80736-KAM Document 362-63 Entered on FLSD Docket 02/10/2016 Page 1 of 3 
EXHIBIT 
133 
EFTA00185169

Case 9;08-cv-80736-KAM Document 362-63 Entered on FLSD Docket 02/10/2016 Page 2 of 3 
U.S. Department of,lustice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, Ste 400 
West Palm Reach. Fl. 33401 
August 26, 2008 
DELIVERY BY ELECTRONIC MAIL 
Jay P. Leflcowitz, Esq. 
Kirkland & Ellis LLP 
Citi ou Center 
New York, New York I0022-4675 
Roy Black, F4sq. 
Black Srebnick Kornspan & Stumpf P.A. 
201 SB 
Blvd, 
Re: 
Jeffrey Epstein 
Dear Jay and Roy: 
Thank you for your letter of August 22nd. 1 write to follow up on some of the points 
that you raised. 
The list of thirty-two victims that was provided to Mr. Goldberger via certified mail 
on July 10, 2008 is the final list. As I mentioned, copies of the notification letters to each 
victim will be carbon-copied to an attorney for Mr. Epstein and Mr. Josefsberg. I asked you 
to advise me whether Mr. Goldberger should continue to be listed as the contact person for 
the civil litigation in the amended victim notification letters and whether he should receive 
the carbon copies of' those letters as they are sent. 
I also asked you to provide me with written confirmation of your agreement to pay Mr. 
Josefsberg's fees. Please provide that confirmation to Mr. Josefsberg so that he can begin 
his representation, and provide me with a copy for my file. 
1 have conferred with the lead AUSA in the case of Jane Doe 1 and 21 United States, 
08-80736-CV-MARRA 
RFP WPB 000603 
EFTA00185170

Case 9:08-cv-80736-KAM Document 362-63 Entered on FLSD Docket 02/10/2016 Page 3 of 3 
JAY P. LEITKOW117., ESQ. 
Roy BLACK, ESQ, 
Aucusr 26, 2008 
PAGE 2 OF 2 
and he agrees that, based upon the discussion with Judge Marra during the hearing on the 
plaintiffs' motion, a notification of the judge's ruling is required. I will, however, change 
the language slightly to direct the victims to discuss the matter with Mr. Josefsberg. 
With regard to your concerns with my "open-ended description of Mr. Epstein's 
responsibilities regarding civil restitution," I agree that the resolution of civil damages claims 
is as stated in paragraphs 7 and 8 of the Agreement and Addendum. That is why the 
language in the notification is taken verbatim from paragraphs 7, 8, and 7C of the Agreement 
and Addendum, except that the victim's name is used in place of "identi fled individual." As 
I mentioned in my earlier letter, if you have any proposed substantive changes, please provide 
them to me. 
Mr. Goldberger and Mr. Tein explicitly approved the language in my earlier victim 
notification letter, even though they apparently were taking the position that the December 
19, 2007 letter was not part of the Agreement, so that misinformation was provided to the 
victims with the approval of Mr. Epstein's attorneys. 
With regard to your sixth and seventh points, I reiterate that it is the Office's position 
that the Agreement and Addendum speak for themselves. Let me also reiterate that, while 
the Office does not intend to involve itself in any civil negotiations or litigation, if it comes 
to our attention that Mr. Epstein has breached the terms of the Agreement, the Office intends 
to enforce its right pursuant to the Agreement. 
I would appreciate a prompt response to the question regarding which of Mr. Epstein's 
attorneys should be named in and receive copies of the notification letters, as well as 
documentation of your commitment to paying Mr. Josefsberg's fees so that I may begin 
distributing the revised victim notifications on Wednesday morning. 
Sincerely, 
tin' 
By: 
States Attorney 
A. 
ane 
Assistant United States Attorney 
cc: 
Karen Atkinson, Chief, Northern Division 
08-80736-CV-MARRA 
RIP WPB 000604 
EFTA00185171

Case 9:08-cv-80736-KAM Document 362-64 Entered on FLSD Docket 02/10/2016 Page 1 of 2 
EXHIBIT 
134 
EFTA00185172

Case 9:08-cv-80736-KAM Document 362-64 Entered on PLED Docket 02/10/2016 Page 2 of 2 
(USAFLS) 
From: 
pippr i (USAFLS) 
Sent: 
ur 
y, ugus 
, 008 3.51 PM 
To: 
Brad Edwards 
Cc: 
Lee, Dexter (USAFLS) 
Subject: 
RE: Epstein 
Attachments: 
Epstein NonProsecution Agrrnt w Addendumpdf 
Ili Brad - I received your fax with the signed Protective Order, so I have attached the Non-Prosecution 
Agreement. Please give me u call when you reecho. And please send or fax over copies of the signed 
Protective Order us )ou receive them from your clients and co-counsel. 
Thank you. 
Assistant U.S. Attorney 
Phone 
lax 
From: Brad Edwards [mailto:be@bradedwardslaw.com] 
Sen 
8,2008 9:33 AM 
To: 
. (USAF'S) 
Sub 
: 
: Epstein 
It has already been faxed to you. Please let me know if you do not receive it. Also, I would appreciate it if you could fax it 
to me as well as mail it. as I would really Ilke to see It today if at all possible Thanks 
Brad Edwards, Esquire 
Law Office of Brad Edwards & Associates 
2028 I larrison Street 
Suite 202 
Hollywood, Florida 33020 
Telephone: 
954-414-8033 (I3roward) 
305-935-2011 (Miami-Dade) 
Facsimile: 
954-924-1530(Broward) 
305/935-4227 (Miami-Dade) 
e-mail: 
bcra)bradedwartIslaw.com 
PRIVILEGED AND CONFIDENTIAL: The intbrination contained in this e-mail message is intended for the 
use of the individual or entity to which it is 
addressed and may contain information that is proprietary. privileged, confidential, and exempt from disclosure 
under applicable laws. If the reader of this 
message is not the intended recipient, or the employee or agent responsible for delivery to the intended 
recipient, you are hereby notified that any use, printing, 
reproduction. disclosure or dissemination of this communication may be subject to legal restriction or sanction. 
103 
08-80736-CV-MARRA 
REP WPB-001776 
EFTA00185173

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EXHIBIT 
135 
EFTA00185174

Case 9:08-cv-80736-KAM Document 362-65 Entered on FLSD Docket 02/10/2016 Page 2 of 2 
(USAFLS) 
From: 
Ann Marie C. (USAFLS) 
Sent: 
May, September 02. 2008 1.16 PM 
To: 
letkowitz©kirkland.coms: 'Roy BLACK' 
Cc: 
Atkonson. Karen (USAFLS) 
Subject: 
Thank you for your tax 
Dear Jay and Roy: 
I have received your fax. I will start sending out the victim notifications today. In accordance with your 
request. I have changed the language regarding the victims' right to receive a copy of the Agreement. 
Mr. Goldberger will he receiving copies as the letters go out. 
Thank you. 
Assistant U.S. Attornc 
Tracking: 
08-80736-CV-MARRA 
RFP WPB-001775 
EFTA00185175

Case 9:08-cv-80736-KAM Document 362-66 Entered on FLSD Docket 02/10/2016 Page 1 of 5 
( 
/ 
I, 
EXHIBIT 
136 
EFTA00185176

Case 9:08-cv-80736-KAM - Document 362-66 Entered on FLSD Docket 02/10/2016 Page 2 of 5 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 33401 
Facsimile: 
September 3, 2008 
NOTIFICATION OF IDENTIFIED VICTIM 
NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED 
STATES CODE, SECTION 3509(d) AND FLORIDA LAW, 
THE ATTACHED DOCUMENT IS TO BE TREATED AS 
CONFIDENTIAL AND SHALL NOT BE DISCLOSED 
EXCEPT IN CONNECTION WITH 
A 
LEGAL 
PROCEEDING. 
08-80736-CIV-MARRA 
000926 
EFTA00185177

Case 9:08-cv-80736-KAM Document 362-66 Entered on FLSD Docket 02/10/2016 Page 3 of 5 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Palm Beach. FL 33401 
Facsimile: 
September 3, 2008 
VIA UNITED STATES MAIL 
Brad Edwards, Esq. 
2028 Harrison Street, Suite 202 
Hollywood, Florida 33020 
Re: 
Jeffrey Epstein/I 
AMENDED NOTIFICATION 
OF IDENTIFIEDIllaM
 mm
Dear Mr: Edwards: 
By virtue of this letter, the United States Attorney's Office for the Southern District 
of Florida asks that you provide the following amended notice to your client, 
Some of the information contained in the July 9, 2008 letter to Ms. Wild was inaccurate, so 
please advise her of the following changes. 
As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter 
referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 
796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in 
prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
009454AXXXMB and 2008-cf-00938IAXXXMB) and was sentenced to a term of twelve 
months' imprisonment to be followed by an additional six months' imprisonment, followed 
by twelve months of Community Control I, with conditions of community confinement 
imposed by the Court. 
In light of the entry of the guilty plea and sentence, the United States has agreed to 
defer federal prosecution in favor of this state plea and sentence, subject to certain 
conditions, including the following: 
1. 
An independent Special Master was assigned the task of selecting an 
attorney representative to represent the victims in connection with civil 
08-80736-CIV-MARRA 
000927 
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—Case-S08 cv 807-2.6-kAlvl—Drasament-362-66—Enterea-en-g689-43eeket-02/10/2016 Page 4-of-5---
BRAD EDWARDS, ESQ. 
AMENDED NOTIFICATION OF IDENTIFIED VICTIM 
SEPTEMBER 3, 2008 
PAGE 2 OF 3 
litigation between the victims and Mr. Epstein. The Special Master 
selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., a 
highly-respected and experienced attorney. Ms. ms's 
not obligated 
to use Mr. Josefsberg as her civil attorney, but, as explained in greater 
detail below, Mr. Josefsberg's services will be provided at no cost to 
Ms. glibecause Mr. Epstein is obligated to pay the costs and fees of 
the attorney-representative. Also, Mr. Epstein and his attorneys can 
only contact Ms. 'ElEvia Mr. Josefsberg, assuming that she would like 
Mr. Jose fsberg to serve as her attorney. 
2. 
If Ms...IFleets 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 
Ill
damages up to an amount as agreed to between Ms. NI and Mr. 
Epstein, so long as Ms.ftWlects to proceed exclusive ? y under 18 
U.S.C. § 2255, and she waives 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, Ms.Mill and Mr. Josefsberg elect to file a 
contested lawsuit pursuant to 18 U.S.C. § 2255 or she elects 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. 
Mr. Josefsberg will be contacting you within the next two weeks to explain these 
terms and to determine if he may contact Ms. IMI_Jiiirectly. If you would like to contact Mr. 
Josefsberg directly, he can be reached at 305 358-2800. 
08-80736-C1V-MARRA 
000928 
EFTA00185179

Case 9:08-cv-80736-KAM Document 362-66 Entered on FLSD Docket 02/10/2016 Page 5 of 5 
BRAD EDWARDS, ESQ. 
AMENDED NOTIFICATION OF IDENTIFIED VICTIM 
SEPTEMBER 3, 2008 
PAGE 3 OF 3 
If Ms. MI/13S selected other counsel to represent her, or i f she does so in the future, 
and she decides to pursue a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack 
Goldberger, asks that he be contacted at Atterbury Goldberger and Weiss, 250 Australian 
Avenue South, Suite 1400, West Palm Beach, FL 33401. 
As I stated in my earlier notification, please understand that neither the U.S. 
Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist 
in civil litigation, but we again thank you and your client for all of her assistance during the 
course of this investigation. 
UNITED STATES ATTORNEY 
By: 
dilegt60 14—
A. 
ASSISTANT U.S. ATTORNEY 
cc: 
Robert Josefsberg, Esq. 
Jack Goldberger, Esq. 
08-80736-CIV-MARRA 
000929 
EFTA00185180

Case 9:08-cv-80736-KAM Document 362-67 Entered on FLSD Docket 02/10/2016 Page 1 of 3 
EXHIBIT 
137 
EFTA00185181

Case 9:08-cv-80736-KAM Document 362-67 Entered on F LSD Docket 02/10/2016 Page 2 of 3 
305-9312200 
Norman Stetermelsteln,P 
10:48:28 a.m. 
16-09-2008 
2/3 
HERMAN & MERMELSTEIN PA 
ATTORNEYS AT LAW 
September 16, 2008 
Vla Fax and Re 
ar 
ail 
Esq. 
Assistant U.S. Homey 
500 Australian Ave., Fourth Floor 
West Palm Beach, FL 33401 
Re: 
Jeffrey Epstein 
Dear Ms. Villafaxia: 
Jeffrey M. Herman 
Tel 305.931.2200 • 
Fax 305,931.0877 
lhermanehermardaw.com 
18205 Biscayne Blvd. 
Suite 2218 
Mlaml, Florida 33180 
wymnermenlaw.com 
This concerns your letters to us and to sexual assault victims of Mr. Epstein dated September 
2, 2008. Please be advised that we strenuously object to your letters on various grounds, and believe 
that they are in violation of the Florida Bar Rules. 
First, your letters attempt to steer the victims to a particular attorney, Mr. Josefsberg, and 
advise them that Mr. Jose fsberg will be making an unsolicited contact to them in the next two weeks. 
This contact with prospective clients and solicitation reflected in your letters is contrary to Fla. Bar. 
Rule 4.7.4. Additionally, your letters are misleading in the following respects: (I) the action 
advocated to the victims in paragraph 2 refers generally to thevictims' waiver of "any other claim for 
damages", failing to advise them that this waiver may include a valuable claim to punitive damages 
against an alleged billionaire; and (2) the letters Imply in paragraph 3 that Mr. Epstein's agreement to 
pay attorney fees is a significant concession, when In fact a victim is entitled to reasonable attorneys' 
fees under the Statute upon proof of a violation, irrespective of Mr. Epsteiu's agreement. 
We accordingly demand that the U.S. Attorneys' office immediately cease and desist from 
directing unrepresented victims into unsolicited attorney contacts and misleading them about their 
rights in claims against Mr. Epstein. We demand that you instruct Mr. losefsberg not to solicit 
victims, and to send letters to unrepresented victims correcting the misleading statements contained 
in your September 2, 2008 letters. 
08-80736-CV-MARRA 
002343 
EFTA00185182

Case 9:08-cv-80736-KAM Document 362-67 Entered on FLSD Docket 02/10/2016 Page 3 of 3 
305-9312200 
Horman Iulerme%stern, P 
10:48:58 a.m. 
16-09-2008 
313 
A. 
Villafafia, Esq. 
September 16, 2008 
Page 2 
Finally, we demand that you make no contact with our clients directly, and contact them only 
through our office. Our clients incite 
Sincerely, 
JMH/lr 
effrey M. Herman 
08-80736-CV-MARRA 
002344 
EFTA00185183