EFTA00602315

8/18/09 
AGREEMENT FOR SPECIAL MASTER 
TO DETERMINE AMOUNT OF ATTORNEYS' FEES AND COSTS 
This Agreement is made this  
 day of  
, 2009, by and 
between the "First Party," Jeffrey Epstein ("Epstein"), by and through his attorneys, Burman, 
Critton, Luttier & Coleman, LLP, and the "Second Party,", defined as the attorney 
representative, Robert C. Josefsberg of the law firm Podhurst Orseck, P.A. ("Podhurst Orseck" ). 
WHEREAS, there exists an agreement between the United States Attorney's Office 
("USAO") and Epstein known as the Non-Prosecution Agreement and Addendum ("NPA") 
(Exhibit "A"). 
The NPA provides for the appointment of an attorney representative to 
potentially represent various individuals who were identified and listed by the USAO as victims 
who might pursue claims against Epstein. This list of victims' names was referenced in and 
contemplated by the NPA. Pursuant to the NM, the USAO provided this list to Epstein's 
counsel after Epstein was sentenced on June 30, 2008. A copy of this list with the names of the 
victims redacted, except for their initials, is attached hereto as Composite Exhibit "B."I
WHEREAS, Epstein has an obligation to pay fees and costs to the attorney 
representative pursuant to the NPA. The NPA is being provided to the Special Master, who will 
execute the required Confidentiality Order (Exhibit "C") upon reviewing it. Thereafter, a copy 
of the executed Confidentiality Order and this Agreement for Special Master shall be provided 
immediately to the USAO. 
For ease of reference by the Special Master, the individuals who thus far have chosen 
to be represented by Robert C. Josefsberg are identified on Exhibit "B" by the highlighting of 
their initials. 
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WHEREAS, Robert C. Josefsberg of the law firm Podhurst Orseck, P.A. was appointed 
as the attorney representative on or about September 2008 by the Honorable Edward B. Davis. 
Robert C. Josefsberg, as lead counsel, began performing his responsibilities immediately 
thereafter, and, as a result, Podhurst Orseck has incurred attorneys' fees and costs. 
WHEREAS, some of the attorney representative's bills for fees and costs relating to the 
representation of the designated victims have been submitted for payment to Epstein through his 
counsel. A majority of these claimed fees and costs have not been paid by Epstein. 
WHEREAS, Podhurst Orsock and Epstein disagree as to the amount of fees and costs due 
and owing and whether certain fees and costs are Epstein's responsibility based upon the NPA 
and correspondence that was exchanged between the USAO, Epstein, and others. 
WHEREAS, the Parties have jointly selected Sidney A. Stubbs, Esq. to serve as Special 
Master to make a binding determination with regard to issues associated with past, present, and 
future disputes and disagreements (unless a lawsuit has been filed which would result in the 
court determining any award of fees and costs) relating to the amount of attorneys' fees and costs 
due the attorney representative. 
The Parties therefore agree as follows: 
1. 
Sidney A. Stubbs, Esq. shall serve as Special Master to conduct hearings and/or 
proceedings, obtain documents, and/or resolve issues he deems necessary and 
pertinent to the determination of the amount of attorneys' fees and costs due and 
owing Podhurst Orseck by Epstein, pursuant to the NPA, in the past, present, and 
future (unless a lawsuit has been filed which would result in the court determining 
any award of fees and costs). If the Parties cannot agree, Mr. Stubbs' decision 
shall be written in the form of an order. 
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2. 
No Party is required to present expert testimony. However, if expert testimony is 
presented, it shall be considered by the Special Master, as it would be in federal 
court. 
3. 
The Parties may provide legal memoranda, exhibits, expert witnesses, and any 
other evidence to support their respective positions. 
4. 
The Federal Rules of Evidence shall govern any proceeding(s). 
5. 
The decisions made by Sidney A. Stubbs, Esq. shall be final and binding on these 
Parties, without the ability of any Party to appeal such decisions. Any order(s) 
issued by Sidney A. Stubbs, Esq. awarding fees and costs shall be paid by Epstein 
within twenty (20) days of the issuance of the order(s). 
6. 
Mr. Stubbs shall be paid his hourly rate upon submission of his bills to counsel 
for all work, including preparation, research, hearings, and orders, as well as any 
out-of- pocket expenses. Mr. Stubbs' fees and costs shall be apportioned based 
upon the amount sought and awarded, i.e. if Podhurst Orseck, ■. is awarded 
75% of the amount sought, Epstein shall be responsible for 75% of Mr. Stubbs' 
bill. 
First Party: 
By: 
Jeffrey Epstein 
By: 
ROBERT D. CRITTON, JR., ESQ. 
Florida Bar No. 224162 
Burman, Critton, Luttier & Coleman, LLP 
515 N. Flagler Drive, Suite 400 
West Palm Beach, FL 33401 
Attorneys for Jeffrey Epstein 
Second Party: 
By: 
ROBERT JOSEFSBERG, ESQ. 
Florida Bar No. 040856 
Podhurst Orseck, P.A. 
25 W. Flagler Street, Suite 800 
Miami, FL 33130 
Attorney Representative 
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