EFTA00227225

C. (USAFLS) 
From: 
Brad Edwards (be@bradedwardslaw.com] 
Sent: 
lit 
at, 
2008 9:33 AM 
To: 
C. (USAFLS) 
Subject: 
RE: 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 like to see it today if at all possible. Thanks 
Brad Edwards, Esquire 
Law Office of Brad Edwards & Associates 
2028 Harrison Street 
Suite 202 
Hollywood, Florida 33020 
Telephone: 
954-414-8033 (Broward) 
305-935-2011 (Miami-Dade) 
Facsimile: 
954-924-I 530(Broward) 
305/935-4227 (Miami-Dade) 
e-mail: 
be@bradedwardslaw.coin 
PRIVILEGED AND CONFIDENTIAL: The information 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. 
From: 
MI C. (USAFLS) [malt.° 
Sent: Wednesday, August 27, 2008 6:47 PM 
To: Brad Edwards 
Subject Epstein 
Hi Brad —I haven't received a signed protective order from you yet, so I haven't sent over the agreement. Can 
you fax it to me and then I will get the agreement out to you? I will be out of the office in the morning but back 
in the afternoon. 
Thanks. 
A. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
106 
08-80736-CV_MARRA 
002171 
EFTA00227285

Fax 561 820-8777 
107 
08-80736-CV_MARRA 
002172 
EFTA00227286

C. (USAFLS) 
From: 
Brad Edwards (be@bradedwardslaw.com) 
Sent: 
ilitithill 
27, 2008 6:59 PM 
To: 
C (USAFLS) 
Subject: 
RE. Epstein 
Hi 
I did not know you needed that from me first. The last email I received from Mr. Lee indicated that you do not need the 
acknowledgement from us prior to disclosure of the agreement, or at least that is how I understood it. So I have just 
been waiting to receive it. We must have gotten our wires crossed. Either way, no big deal. I have signed it, and I just 
sent an email to my secretary to fax it to you first thing tomorrow. If you get an opportunity to call me tomorrow 
afternoon, I would appreciate it. Thanks 
Sincerely, 
Brad Edwards, Esquire 
Law Office of Brad Edwards & Associates 
2028 Harrison Street 
Suite 202 
Hollywood, Florida 33020 
Telephone: 
954-414-8033 (Broward) 
305-935-2011 (Miami-Dade) 
Facsimile: 
954-924-1530(Broward) 
305/935-4227 (Miami-Dade) 
e-mail: 
beta bradedwa rdslaw.com 
PRIVILEGED AND CONFIDENTIAL: The information 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. 
From: S 
• 
C. (USAFLS) [mailto 
Sent: Wednesday, August 27, 2008 5:47 PM 
To: Brad Edwards 
Subject: Epstein 
Ili Brad — I haven't received a signed protective order from you yet. so I haven't sent over the agreement. Can 
you fax it to me and then I will get the agreement out to you? I will be out of the office in the morning but back 
in the afternoon. 
Thanks. 
108 
08-80736-CV MARRA 
002173 
EFTA00227287

A. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
109 
08-80736-CV_MARRA 
002174 
EFTA00227288

•
C. (USAFLS) 
From: 
,M 
C. (USAFLS) 
Sent: 
Wednesday, August 27, 2008 6:47 PM 
To: 
be@bradedwardslaw.com 
Subject: 
Epstein 
Hi Brad — I haven't received a signed protective order from you yet, so I haven't sent over the agreement. Can 
you fax it to me and then I will get the agreement out to you? I will be out of the office in the morning but back 
in the afternoon. 
Thanks. 
A. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
110 
08-80736-CV_MARRA 
002175 
EFTA00227289

S
 •
C. (USAFLS) 
From: 
■ 
C. (USAFLS) 
Sent: 
Wednesday, August 27, 2008 6:36 PM 
To: 
be@bradedwards.com 
Subject: 
Epstein 
Hi Brad — I haven't received a signed protective order from you yet, so I haven't sent over the agreement. Can 
you fax it to me and then I will get the agreement out to you? I will be out of the office in the morning but back 
in the afternoon. 
Thanks. 
A. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
111 
08-80736-CV_MARRA 
002176 
EFTA00227290

C. (USAFLS) 
From: 
. M 
C. (USAFLS)
Sent: 
tes., 
August 
, 2008 1.26 PM 
To: 
I fkowi z I i 
- 
oy BLACK 
Cc: 
Subject: 
Je rey Epstein 
Lefkowi z 
08082600 .pdf 
A. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
%Vest Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
112 
08-80736-CV_MARRA 
002177 
EFTA00227291

•
C. (USAFLS) 
From: 
In 
C. (USAFLS) 
Sent: 
Thursday, August 21, 2008 5:32 PM 
To: 
iiiry 
BLACK 
Cc: 
Subject: 
Jeffrey Epstein 
Dear Jay and Roy —1 have attached a letter in response to Jay's letter of August 18, 2008, and an Order we 
received today in the Jane Doe'. United States litigation. 
)80821 
Itr to Lefkow... 
DE26 080821 P 
Dtective Order.p. 
A. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
136 
08-80736-CV_MARRA 
002178 
EFTA00227292

C. (USAFLS) 
From: 
, 
C. (USAFLS) 
Sent: 
May, 
August 20, 2008 3:19 PM 
To: 
bertpatton©podhurst.com 
Subject: 
Epstein Civil Cases 
Hi Bert — Here is a chart with all of the information. Please let Mr. Josefsberg know that Mr. Epstein has to 
answer all of the Complaints in the Jeffrey Herman cases by September 4th• Thank you. 
ro 
EPSTEIN CIVIL 
rIGATION CASES 
A. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
159 
08-80736-CV_MARRA 
002179 
EFTA00227293

C. (USAFLS) 
From: 
Jay Letkowdz (JLelkowitz©kirkland.com) 
Sent: 
20, 2008 9:35 AM 
To: 
SAFLS) 
Cc: 
Subject: 
Re: Yourfax 
Thanks MI. 
We arc working on something and will share it with you. 
Good luck with the weather. 
From: 1=, 
C. (USAFLS)" 
Sent: 08/20/2008 09:28 AM AST 
To: Ja Leflcowitz 
Cc: 
r <Karen.Atkinson@usdoj.goy> 
Subject: RE: Your fax 
gold 
P.S. In the meanwhile, if you would like to propose language for our joint submission, 1 am happy to look that 
over. 
A. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: 
C. (USAFLS) 
Sent: Wednesday, August 20, 2008 9:26 AM 
To: la Lefl
o i
ow12 
Cc: 
Subject: Your fax 
Good morning, Jay. 
Our office has been closed since Monday afternoon due to the Tropical Storm, so I just received your fax. I 
have to be in Court this morning, but I will turn my attention to your response upon my return and will get back 
to you later today or tomorrow morning. 
156 
08-80736-CV_MARRA 
002180 
EFTA00227294

Thank you. 
A. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
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 postmasterfakirkland.com, and 
destroy this communication and all copies thereof, 
including all attachments. 
157 
08-80736-CV_MARRA 
002181 
EFTA00227295

C. (USAFLS) 
From: 
Sent: 
To: 
Cc: 
Subject: 
C. (USAFLS) 
Wednesday, August 20, 2008 9:28 AM 
P.S. In the meanwhile, if you would like to propose language for our joint submission, I am happy to look that 
over. 
A. 
Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: 
C. (USAFLS) 
Sent: Wednesday, August 20, 2008 9:26 AM 
To: 
Cc: 
Subject: Your fax 
Good morning, Jay. 
Our office has been closed since Monday afternoon due to the Tropical Storm, so I just received your fax. I 
have to be in Court this morning, but I will turn my attention to your response upon my return and will get back 
to you later today or tomorrow morning. 
Thank you. 
A. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
158 
08-80736-CV_MARRA 
002182 
EFTA00227296

, • 
C. (USAFLS) 
20, 2008 9:26 AM 
From: 
MUM 
C. (USAFLS) 
Ser
To: 
Cc: 
Subject: 
Your fax 
Good morning, Jay. 
Our office has been closed since Monday afternoon due to the Tropical Storm, so I just received your fax. I 
have to be in Court this morning, but I will turn my attention to your response upon my return and will get back 
to you later today or tomorrow morning. 
Thank you. 
A. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
159 
08-80736-CV_MARRA 
002183 
EFTA00227297

•
C. (USAFLS) 
From: 
Brad Edwards [be@bradedwardslaw.com] 
Sent: 
8 2:49 PM 
To: 
); Paul Cassell 
Cc: 
(USAFLS) 
Subject: 
RE: Draft Protective Order - slight tweak 
It looks ok. Go ahead and submit it. While we would disagree with your statement that our proposed order goes well 
beyond what is at issue, since it actually covers very thoroughly the ruling by Judge Marra yesterday, at this point we feel 
that time is of the essence and we will agree with you submitting your proposed order as is. I think we all heard Judge 
Marra and are thus all clear as to the terms of the protective order and what is required. 
I would prefer that there is some language that the protective order is entered without prejudice to petitioners (seems like 
it would go in paragraph b), but if you are unable to incorporate it in your order, then I am sure there is a record from 
yesterday that could be used to help us get relief from the protective order at a later hearing. Anyway, thanks for 
preparing the order. We will look out for the "agreement". Thanks 
From: a 
[mailto:Dexter.Lee@usdoj.gov] 
Sent: Friday, August 15, 2008 1:24 PM 
To: Paul CassL,_II. Brad Edwards 
Cc: a 
MI C. (USAFLS) 
Subject: RE: Draft Protective Order - slight tweak 
Judge Cassell and Brad, 
I have incorporated the change suggested by Judge Cassell to paragraph (c). I also added language in paragraph (e), 
referring to other victims, which also provides for petitioners' counsel to promptly provide a copy of the 
acknowledgment to the U.S. Attorney's Office. 
The government has no doubts that counsel for petitioners will ensure 
the authorized recipients are aware of the protective order and agree to abide by it, prior to disclosure. We do not 
require the acknowledgment in writing prior to the non-prosecution agreement being disclosed to an authorized 
recipient. 
We believe the petitioners' proposed protective order goes well beyond what is at issue, the government's disclosure of 
the non-prosecution agreement, conditioned on limited dissemination of the document upon receipt by petitioners. 
Consequently, we believe the attached proposed order, incorporating your revisions, is appropriate for the task at 
hand. Thanks. 
From: Paul Cassell (mailto:cassellp@LAW.UTAKEDU1 
Sent: Friday, August 15 2008 12:21 PM 
To: Brad Edwards; 
Cc: S 
C. (USAFLS) 
Subject: RE: Draft Protective Order - slight tweak 
Hello 
and■ 
First, I don't know if we've been formally introduced. Nice to meet you ... electronically at least. 
171 
08-80736-CV MARRA 
002184 
EFTA00227298

Second, on the language -- As Brad mentioned, we need to see this document quite quickly in view of 
the Government's representations yesterday that Epstein is trying to ignore the agreement. As a result -
- and in view of the difficulty of making immediate contact with our clients -- I propose one change. 
Instead of this: 
Prior to producing the documents to Petitioners' counsel, a copy of this Order must be provided to 
counsel and their clients, who must review and acknowledge their receipt of and agreement to abide by 
the terms of this Order, and who must provide a copy of that acknowledgment to the USAO. 
How about this: 
Before counsel for Petitioner's show the agreement to their clients or discuss the specific terms with 
them, they must provide a copy of this Order to Petitioners, who must review and acknowledge their 
receipt of and agreement to abide by the terms of this Order. Counsel for Petitioner's must promptly 
provide a copy of that acknowledgment to the USAO. 
I assume that the USAO is not concerned about us as attorneys somehow ignoring the Court's 
protective order, so this change would focus in on the non-law trained clients. 
Paul G. Cassell 
Professor of Law 
172 
08-80736-CV_MARRA 
002185 
EFTA00227299

C. (USAFLS) 
From: 
Sent: 
Friday, I.
...ist 
1 , 
08 2:24 PM 
To: 
ligifisi dcw.mas) 
Cc: 
Subject: 
RE: Draft Protective Order - slight tweak 
Attachments: 
Protective Order_v2 doc 
Judge Cassell and Brad, 
I have incorporated the change suggested by Judge Cassell to paragraph (c). I also added language in paragraph (e), 
referring to other victims, which also provides for petitioners' counsel to promptly provide a copy of the 
acknowledgment to the U.S. Attorney's Office. 
The government has no doubts that counsel for petitioners will ensure 
the authorized recipients are aware of the protective order and agree to abide by it, prior to disclosure. We do not 
require the acknowledgment in writing prior to the non-prosecution agreement being disclosed to an authorized 
recipient. 
We believe the petitioners' proposed protective order goes well beyond what is at issue, the government's disclosure of 
the non-prosecution agreement, conditioned on limited dissemination of the document upon receipt by petitioners. 
Consequently, we believe the attached proposed order, incorporating your revisions, is appropriate for the task at 
hand. Thanks. 
From: Paul Cassell [mailto:cassellp(c3lAW.UTAH.EDU1 
Sent: Friday, Augu t 15 
12:21 PM 
To: Brad Edwards;_____________________
Cc: 
IN 
C. (USAFLS) 
Subject: RE: Draft Protective Order - slight tweak 
Hello 
and 
First, I don't know if we've been formally introduced. Nice to meet you ... electronically at least. 
Second, on the language -- As Brad mentioned, we need to see this document quite quickly in view of 
the Government's representations yesterday that Epstein is trying to ignore the agreement. As a result -
- and in view of the difficulty of making immediate contact with our clients -- I propose one change. 
Instead of this: 
Prior to producing the documents to Petitioners' counsel, a copy of this Order must be provided to 
counsel and their clients, who must review and acknowledge their receipt of and agreement to abide by 
the terms of this Order, and who must provide a copy of that acknowledgment to the USAO. 
How about this: 
Before counsel for Petitioner's show the agreement to their clients or discuss the specific terms with 
them, they must provide a copy of this Order to Petitioners, who must review and acknowledge their 
173 
08-80736-CV_MARRA 
002186 
EFTA00227300

receipt of and agreement to abide by the terms of this Order. Counsel for Petitioner% must promptly 
provide a copy of that acknowledgment to the USAO. 
I assume that the USAO is not concerned about us as attorneys somehow ignoring the Court's 
protective order, so this change would focus in on the non-law trained clients. 
Paul a Cassell 
Ronald M. Boyce Presidential Professor of Law 
of Law 
174 
08-80736-CV_MARRA 
002187 
EFTA00227301

C. (USAFLS) 
From: 
. 
= 
C. (USAFLS) 
Sent: 
Friday, August 15, 2008 2.12 PM 
To:
oy BLACK 
Cc:
Subject: 
Response to your e-rnail 
Dear Jay and Roy: 
Please see the attached. Thank you. 
)80815 
lir to Lefkow... 
A. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
175 
08-80736-CV_MARRA 
002188 
EFTA00227302

C. (USAFLS) 
From: 
Paul Cassell [casselip@LAW UTAH EDU] 
Sent: 
Friday, August 
To: 
Cc: 
Brad Edw.: 
AFLS) 
Subject: 
RE: Draft Protective Order - slight tweak 
Hello 
and ■ 
First, I don't know if we've been formally introduced. Nice to meet you ... electronically at least. 
Second, on the language — As Brad mentioned, we need to see this document quite quickly in view of 
the Government's representations yesterday that Epstein is trying to ignore the agreement. As a result -
- and in view of the difficulty of making immediate contact with our clients -- I propose one change. 
Instead of this: 
Prior to producing the documents to Petitioners' counsel, a copy of this Order must be provided to 
counsel and their clients, who must review and acknowledge their receipt of and agreement to abide by 
the terms of this Order, and who must provide a copy of that acknowledgment to the USAO. 
How about this: 
Before counsel for Petitioner's show the agreement to their clients or discuss the specific terms with 
them, they must provide a copy of this Order to Petitioners, who must review and acknowledge their 
receipt of and agreement to abide by the terms of this Order. Counsel for Petitioner's must promptly 
provide a copy of that acknowledgment to the USAO. 
I assume that the USAO is not concerned about us as attorneys somehow ignoring the Court's 
protective order, so this change would focus in on the non-law trained clients. 
Paul G. Cassell 
Ronald M. Boyce Presidential Professor of Law 
198 
08-80736-CV_MARRA 
002189 
EFTA00227303

C. (USAFLS) 
From: 
Sent: 
Friday, August 15. 2008 11:41 AM 
To: 
b 
Br d 
w r 
w.com 
Cc:
C (USAFLS) 
Subject: 
ra Protective Order 
Brad, 
Attached please find a draft protective order regarding the disclosure of the non-prosecution agreement to you and Jane 
Does 1 and 2. Please let us know if there are any changes you wish to make. Thanks. 
Protective 
Order.doc 
207 
08-80736-CV_MARRA 
002190 
EFTA00227304