EFTA00208970

• 
• 
• 
THE HON. EDWARD B. DAVIS (RET.) 
OCTOBER 
2007 
PAGE 3 OF 4 
signature on this agreement, nor its terms, nor any resulting waivers or 
settlements by Epstein are to be construed as admissions or evidence of 
civil or criminal liability or a waiver of any jurisdictional or other defense 
as to any person, whether or not her name appears on the list provided by 
the United States. 
The most recent version of the statute referenced above, 18 U.S.C. § 2255, 
provides that: 
Any person who, while a minor, was a victim of a violation of section . . . 2422 
or 2423 of this title and who suffers personal injury as a result of such 
violation, regardless of whether the injury occurred while such person was a 
minor, may sue in any appropriate United States District Court and shall 
recover the actual damages such person sustains and the cost of the suit, 
including a reasonable attorney's fee. 
Any person as described in the 
preceding sentence shall be deemed to have sustained damages of no less than 
$150,000 in value.' 
Section 2422 prohibits the use of a facility of interstate commerce to induce minors 
to engage in sexual activity and prostitution, and section 2423 prohibits interstate travel for 
the purpose of engaging in sexual activity or prostitution with minors. The United States has 
identified 34 victims as defined by this statute. The United States takes no position as to the 
validity of any such claim under this statute. 
Due to the circumstances of the case and the number and caliber of the attorneys who 
represent Mr. Epstein, in selecting the victims' attorney representative, the United States 
suggests that you consider the following criteria: 
1. 
Experience doing both plaintiffs' and defense litigation. 
2. 
Experience with state and federal statutory and common law tort claims. 
3. 
The ability to communicate effectively with young women. 
4. 
Experience litigating against large law firms and high profile attorneys who 
' An earlier version of this statute deems that any person described in the preceding 
sentence shall have sustained damages of no less than $50,000 in value. 
RFP MIA 000342 
EFTA00209030

• 
• 
• 
THE HON. EDWARD B. DAVIS (RET.) 
OCTOBER 
2007 
PAGE 4 OF 4 
may test the veracity of the victims' claims. 
5. 
Sensitivity to the nature of the suit and the victims' interest in maintaining 
their privacy. 
6. 
Experience litigating in federal court in the Southern District of Florida. 
7. 
The resources to hire experts and others, while working on a contingency 
fee basis, in order to prepare for trial, if a settlement cannot be reached 
(defense counsel has reserved the right to challenge such litigation). 
8. 
The ability to negotiate effectively. 
Pursuant to this letter, the United States assigns to you the responsibility for consulting 
with and selecting the attorney representative for the individuals. The United States and 
Epstein retain the right to make good faith objections to the attorney representative you select 
prior to the final designation of the attorney representative. In that regard, after you have 
reached a decision regarding the attorney representative, please provide me with his or her 
name and contact information. 
If I can provide you with any further information, please do not hesitate to contact me 
and/or the U.S. Attorne and/or Jay Lefkowitz, Esq. on behalf of Epstein. Mr. Lefkowitz can 
be reached at 
- Kirkland & Ellis LLP, Citigroup Center, 153 East 53rd Street, 
New York, New York 10022-4611. Thank you again for your assistance with this matter. 
cc: 
AUSA A. Marie Villafafla 
By: 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
Jeffrey Sloman 
First Assistant United States Attorney 
RFP MIA 000343 
EFTA00209031

U.S. Department ofJustice 
United States Attorney 
Southern District of Florida 
99 N.E. 4" Street 
Miami. F133132 
Telephone: (303) 961-9299 
Facsimile: (305) 530-6444 
October 25, 2007 
DELIVERY BY FACSIMILE 
The Hon. Edward B. Davis (Ret.) 
Akerman Senterfitt 
One Southeast Third Avenue, 25th Floor 
Miami, Florida 33131 
Re: 
Service as a Special Master 
Dear Judge Davis: 
Thank you for agreeing to serve as a Special Master and for assisting the United States 
Attorney's Office in the selection of an attorney representative to represent a group of 
identified victims. This letter is meant to assist you in performing your duties by providing 
you with background information regarding the agreement between the United States and 
Jeffrey Epstein and the duties that the attorney representative will have to perform. 
The Federal Bureau of Investigation and the U.S. Attorney's Office conducted an 
investigation of Mr. Epstein. As a result of that investigation, the U.S. Attorney's Office and 
Mr. Epstein entered into a Non-Prosecution Agreement and an Addendum that contains, 
inter alia, the following terms: 
7A. The United States has the right to assign to an independent third-party the 
responsibility for consulting with and, subject to the good faith approval of 
Epstein's counsel, selecting the attorney representative for the individuals 
identified under the Agreement. If the United States elects to assign this 
responsibility to an independent third-party, both the United States and Epstein 
retain the right to make good faith objections to the attorney representative 
suggested by the independent third-party prior to the final designation of the 
attorney representative. 
RFP MIA 000344 
EFTA00209032

THE HON. EDWARD B. DAVIS (RET.) 
OCTOBER 25, 2007 
PAGE 2 OF 4 
7B. The parties will jointly prepare a short written submission to the 
independent third-party regarding the role of the attorney representative and 
regarding Epstein's Agreement to pay such attorney representative his or her 
regular customary hourly rate for representing such victims subject to the 
provisions of paragraph 7C, infra. 
7C. Pursuant to additional paragraph 7A, 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, an attorney representative elects to file a contested lawsuit 
pursuant to 18 U.S.C. § 2255 or elects to pursue any other contested remedy, 
the paragraph 7 obligation of the Agreement 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 § 2255 to bear 
the costs of the attorney representative, shall cease. 
8.If any of the individuals referred to [in the paragraphs above] elects to file 
suit pursuant to 18 U.S.C. § 2255, 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 Epstein waives his right to contest 
liability and also waives his right to contest damages up to an amount agreed 
to between Epstein and the identified individual, so long as the identified 
individual elects to proceed exclusively under 18 U.S.C. § 2255, and agrees to 
waive any other claim for damages, whether pursuant to state, federal, or 
common law. Notwithstanding this waiver, with respect to those individuals 
whose names appear on the list provided by the United States, Epstein's 
signature on this agreement, his waivers and failures to contest liability and 
such damages in any suit are not to be construed as an admission of any 
criminal or civil liability. 
9.Epstein's signature on this agreement also is not to be construed 
admission of civil or criminal liability or a waiver of any jurisdictional or 
other defense as to any person whose name does not appear on the list 
provided by the United States. 
10.Except as to those individuals who elect to proceed exclusively under 18 
U.S.C. § 2255, as set forth in [the above paragraphs], neither Epstein's 
RFP MIA 000345 
EFTA00209033

THE HON. EDWARD B. DAVIS (RET.) 
OcroBER 25, 2007 
PAGE 3 OF 4 
signature on this agreement, nor its terms, nor any resulting waivers or 
settlements by Epstein are to be construed as admissions or evidence of 
civil or criminal liability or a waiver of any jurisdictional or other defense 
as to any person, whether or not her name appears on the list provided by 
the United States. 
The most recent version of the statute referenced above, 18 U.S.C. § 2255, 
provides that: 
Any person who, while a minor, was a victim of a violation of section ... 2422 
or 2423 of this title and who suffers personal injury as a result of such 
violation, regardless of whether the injury occurred while such person was a 
minor, may sue in any appropriate United States District Court and shall 
recover the actual damages such person sustains and the cost of the suit, 
including a reasonable attorney's fee. Any person as described in the 
preceding sentence shall be deemed to have sustained damages of no less than 
$150,000 in value.' 
Section 2422 prohibits the use of a facility of interstate commerce to induce minors 
to engage in sexual activity and prostitution, and section 2423 prohibits interstate travel for 
the purpose of engaging in sexual activity or prostitution with minors. The United States has 
identified 34 victims as defined by this statute. The United States takes no position as to the 
validity of any such claim under this statute. 
Due to the circumstances of the case and the number and caliber of the attorneys who 
represent Mr. Epstein, in selecting the victims' attorney representative, the United States 
suggests that you consider the following criteria: 
1. 
Experience doing both plaintiffs' and defense litigation. 
2. 
Experience with state and federal statutory and common law tort claims. 
3. 
The ability to communicate effectively with young women. 
4. 
Experience litigating against large law firms and high profile attorneys who 
' An earlier version of this statute deems that any person described in the preceding 
sentence shall have sustained damages of no less than $50,000 in value. 
RFP MIA 000346 
EFTA00209034

• 
• 
TILE HON. EDWARD B. DAVIS (RET.) 
OCTOBER 25, 2007 
PAGE 4 OF 4 
may test the veracity of the victims' claims. 
5. 
Sensitivity to the nature of the suit and the victims' interest in maintaining 
their privacy. 
6. 
Experience litigating in federal court in the Southern District of Florida. 
7. 
The resources to hire experts and others, while working on a contingency 
fee basis, in order to prepare for trial, if a settlement cannot be reached 
(defense counsel has reserved the right to challenge such litigation). 
8. 
The ability to negotiate effectively. 
Pursuant to this letter, the United States assigns to you the responsibility for consulting 
with and selecting the attorney representative for the individuals. The United States and 
Epstein retain the right to make good faith objections to the attorney representative you select 
prior to the final designation of the attorney representative. In that regard, after you have 
reached a decision regarding the attorney representative, please provide me with his or her 
name and contact information. 
If I can provide you with any further information, please do not hesitate to contact me 
and/or the U.S. Attorney and/or Jay Lefkowitz, Esq. on behalf of Epstein. Mr. Lefkowitz can 
be reached at 
- Kirkland & Ellis LLP, Citigroup Center, 153 East 53rd Street, 
New York, New York 10022-4611. Thank you again for your assistance with this matter. 
cc: 
AUSA A. Marie Villafafia 
By: 
Sincerely, 
R. Alexander Acosta 
United States.Attorney 
Jeffrey Sloman 
First Assistant United States Attorney 
RFP MIA 000347 
EFTA00209035

10/25/07 THU 13:19 FAX 305 530 6440 
EXECUTIVE OFFICE 
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• 
•
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TRANSMISSION OK 
TX REPORT 
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TX/RI NO 
3333 
CONNECTION TEL 
912124464900 
SUBADDRESS 
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U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
UNITED STATES ATTORNEY'S OFFICE 
SOUTHERN DISTRICT OF FLORIDA 
99 NE el STREET 
MIAMI, FLORIDA 33132-2111 
Jeffrey H. Sloman 
First Assistant U.S. Attorney 
305 961 9299 
Cyndce Campos 
Staff Assistant 
305 961 9461 
305 530-6444 fax 
FACSIMILE TRANSMISSION 
COVER SHEET 
DATE: 
October 25, 2007 
TO: 
Jay P. Lefkowitz 
• 
FAX NUMBER: 
SUBJECT: 
Special Master 
RFP MIA 000948 
EFTA00209036

Y 
Campos, Cyndee (USAFLS) 
From: 
Campos, Cyndee (USAFLS) 
lint: 
Thursday, October 25, 2007 12:14 PM 
lefkowitz@kirkland.com' 
bject: 
Scanned Document 
Erm 
specialmaster.pdf 
Sent on behalf of Jeff Sloman, FAUSA 
• 
1 
RFP MIA 000349 
EFTA00209037

Villafana, Ann Marie C. (USAFLS) 
From: 
Sloman, Jeff (USAFLS) 
nt: 
Wednesday, October 31, 2007 11:51 AM 
Jay Lefkowitz 
subject: 
RE: Epstein 
Jay, 
Regarding your statement that "we are beginning to think about what discovery we may need to take to 
verify any claims", I remind you that paragraph 8 of the agreement states that Epstein "waives his right to 
contest liability and also waives his right to contest damages up to an amount as agreed to between the 
identified individual and Epstein, so long as the identified individual elects to proceed exclusively under 18 
USC s 2255 and agrees to waive any other claim for damages ...." That being said, you are correct in 
assuming that we do not want to be copied on anything related to discovery. Monitoring the status of the 
negotiations/litigation by this Office is limited to insuring that the terms and conditions of the Non-Prosecution 
Agreement are not breached. 
Jeff 
From: Jay Lefkowitz fmailt0:JEefkowitz@kirkland.com] 
Sent: Tuesday, October 30, 2007 4:54 PM 
To: Sloman, Jeff (USAFLS) 
Cc: Acosta, Alex (USAFLS) 
ar
ject: Re: Epstein 
Thanks Jeff. 
I haven't heard anything from Judge Davis. I assume he is still willing to take on the role you asked him to take on, but can you please 
let me know if that is not the case? 
Also, we are beginning to think about what discovery we may need to take to verify any claims. I am assuming that your office does 
not want to be copied on any subpoenas or anything related to discovery. But please let me know if that is an incorrect assurnption. 
Thanks - Jay 
 
Original Message — 
From: "Sloman, Jeff (USAFLS)" Lleff.Sloman®usdoj.gov] 
Sent: 10/30/2007 02:42 PM AST 
To: Jay Lefkowitz 
Cc: "Acosta, Alex (USAFLS)" <Alex.AcostaOusdoi.gov>
Subject: Epstein 
r
a
y
,
 
0re is an executed version of the addendum. Please Fed Ex the original signature pages to me. Thanks, 
RIP MIA 000350 
EFTA00209038

Jeff 
• 
epstein addendum 10 30.pdf» 
The information contained in this communication is 
confidential, may be attorney-client privileged, may 
constitute inside information, and is intended only for 
the use of the addressee. It is the property of 
Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 
Unauthorized use, disclosure or copying of this 
communication or any part thereof is strictly prohibited 
and may be unlawful. If you have received this 
communication in emir, please notify us immediately by 
return e-mail or by e-mail to postmaster®kirkland.com, and 
destroy this communication and all copies thereof, 
including all attachments. 
• 
• 
2 
RFP MIA 000351 
EFTA00209039

Sloman, Jeff (USAFLS) 
From: 
Jay Lefkowitz pLefkowitz@kirkland.com] 
ent: 
Thursday, November 08, 2007 1:24 PM 
Sloman, Jeff (USAFLS) 
Jeff - was in court all day yesterday and in chicago today. But I am responding to your 
letter and will get it out to you later today. Please rest assured we have no intention of 
not complying with the agreement. 
Thanks - Jay 
The information contained in this communication is confidential, may be attorney-client 
privileged, may constitute inside information, and is intended only for the use of the 
addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 
Unauthorized use, disclosure or copying of this communication or any part thereof is strictly 
prohibited and may be unlawful. If you have received this communication in error, please 
notify us immediately by return e-mail or by e-mail to postmastemPkirkland.com, and destroy 
this communication and all copies thereof, including all attachments. 
• 
• 
1 
RFP MIA 000352 
EFTA00209040

Slornan, Jeff (USAFLS) 
410ront 
Jay Lefkowitz pLefkowitz@kirkland.com] 
Sent: 
Friday, November 16, 2007 2:00 PM 
To: 
Slomen, Jeff (USAFLS) 
Jeff - Beyond my letter the other day, and your email to me from a few weeks ago, is there 
anything else you need from me regarding the plea and sentencing dates. 
As we discussed, and as we have confirmed, the Court has told us she will handle both at the 
same time (plea before sentencing, obviously), and to the agreed-upon counts, on Jan 4. I 
trust I have cleared up any confusion regarding Jan 7. 
Thx. Jay 
The information contained in this communication is confidential, may be attorney-client 
privileged, may constitute inside information, and is intended only for the use of the 
addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 
Unauthorized use, disclosure or copying of this communication or any part thereof is strictly 
prohibited and may be unlawful. If you have received this communication in error, please 
notify us immediately by return e-mail or by e-mail to postmastenPkirkland.com, and destroy 
this communication and all copies thereof, including all attachments. 
1 
RFP MIA 000353 
EFTA00209041

Sloman, Jeff (USAFLS) 
From: 
Sloman, Jeff (USAFLS) 
nt: 
Tuesday, November 27, 2007 1:55 PM 
Jay Lefkowitz 
c: 
Acosta, Alex (USAFLS) 
Subject: 
Epstein 
Jay, 
Please accept my apologies for not getting back to you sooner but I was a little under the weather yesterday. I hope that 
you enjoyed your Thanksgiving. 
Regarding the issue of due diligence concerning Judge Davis' selection, I'd like to make a few observations. First, Guy 
Lewis has known for some time that Judge Davis was making reasonable efforts to secure Aaron Podhurst and Bob 
Josephsberg for this assignment. In fact, when I told you of Judge Davis's selection during our meeting last Wednesday, 
November 21°, you and Professor Dershowitz seemed very comfortable, and certainly not surprised, with the selection. 
Podhurst and Josephsberg are no strangers to nearly the entire Epstein defense team including Guy Lewis, Lili Ann 
Sanchez, Roy Black, and, apparently, Professor Dershowitz who said he knew Mr. Josephsberg from law school. Second, 
Podhurst and Josephsberg have long-standing stellar reputations for their legal acumen and ethics. It's hard for me to 
imagine how much more vetting needs to be done. 
The United States has a statutory obligation (Justice for All Act of 20O4) to notify the victims of the anticipated 
upcoming events and their rights associated with the agreement entered into by the United States and Mr. Epstein in a 
timely fashion. Tomorrow will make one full week since you were formally notified of the selection. I must insist that the 
vetting process come to an end. Therefore, unless you provide me with a good faith objection to Judge Davis's selection 
• • COB tomorrow, November 28, 2007, I will authorize the notification of the victims. Should you give me the go-ahead 
Podhurst and Josephsberg selection by COB tomorrow, I will simultaneously send you a draft of the letter. I intend to 
notify the victims by letter after COB Thursday, November 2e. Thanks, 
Jeff 
• 
RFP MIA 000354 
EFTA00209042

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December 7, 2007 
Jeffrey Sloman 
First Assistant United States Attorney 
United States Attorney's Office 
Southern District of Florida 
500 South Australian Avenue, Suite 400 
We Palm Beach, Florida 33401 
Re: Jeffrey Epstein 
Dear Jeff: 
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Pursuant to your letter dated December 6, 2007, attached is a signed 
Affirmation of the Non-Prosecution Agreement and Addendum to same dated 
October 30, 2007 (collectively "Agrccnacnt") signed by my client Jeffrey E. Epstein 
(see attached). 
Moreover, pursuant to the terms of the Agreement_ please note that the plea 
and sentencing hearing have been scheduled for January 4, 2008 at 8:30 am. before 
Judge Sandra McSorley (please see attached notice of bearing). In addition, es 
expressed In my voiccmail message to you earlier, I would request that tho Office 
bold off on sending any victim notification letters until we can funher discuss the 
contents therein. Please call me at your earliest convenience. 
Sincerely, 
cc. Alex A. Acosta 
Judge Kenneth Star 
Lilly Ann Sanchez 
pmbillell3X427M17:1-0.041.0111V1-115U 
Fowtest wFirrs Bureirrr PA 
RIP MIA 000355 
EFTA00209043

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Affirmation 
1, Jeffrey B. Epstein do bereby miff= the tion-Prcatognan Agree:nada:3d Addendum to 
llama Sad Oaths 30, 2007. 
RIP MIA 000356 
EFTA00209044

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STATE OP FLORIDA 
vs. 
JEFFREY EPSTEIN, 
Defendant 
IN THE CIRCUIT COURT OF THE FLYIEZKIII 
JUDICIAL CIRCUIT. IN AND FOR PALM BEACH 
COUNTY. FLORIDA 
CASE NO.: 
2006CP0094S4AXX 
NOTICE OF FIE/JUNO 
PLEASE TAKE NOTICE that the undersigned has called up for bearing the following: 
JUDGE: 
Sondra hicSorley 
DATE: 
January 4, 200$ 
TIME: 
$:30 am. 
PLACE: 
Room 11F, PC Beach County Courthouse 
MATTER: 
Plea Confluence 
I HEREBY CERTIFY that s copy of the foregoing boa been faraWsed by malt to Lonna 
Belohltpock, Esquire, Sate Attorney's Office, 401 North Dixie Highway, Wan Palm Etoach, F.ondo 
33401 this 7^ day of Doeembor, 2007, 
ATTERBURY, GOLDBERGER it WEISS, PA 
250 Australian Avenue South 
Suite 1400 
W• Palm Baca Flori• 33401 
(56 
94300 
LDBEROER, ESQUIRE 
Fl• 
Bar No. 262013 
co: The Honorable San to McSorley 
RFP MIA 000357 
EFTA00209045