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8/04/09 
AGREEMENT FOR SPECIAL MASTER 
TO DETERMINE ENTITLEMENT AND 
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 
attomeys, Burman, Critton, Luttier & Coleman, LLP and the "Second Party" 
defined as the attorney representative which is the law firm of Podhurst Orseck, 
P.A. 
WHEREAS, there exists an agreement between the United States and 
Epstein known as the Non-Prosecution Agreement and Addendum ("NPA") that 
contains various provisions, some of which will be provided to the Special 
Master, dealing with the appointment of an attorney representative to potentially 
represent various individuals who were identified in a separate list (but the list 
itself is referenced in the NPA) to discuss pursuing claims against Epstein. 
Pursuant to the relevant portions of the NPA which will be provided to the Special 
Master, Epstein had an obligation to pay fees and costs under certain 
circumstances. 
WHEREAS, Podhurst Orseck Firm was appointed as the attorney 
representative on or about October 25, 2007 by the Honorable Edward B. Davis. 
The Podhurst Orseck Firm, with lead counsel being Robert C. Josefsberg, began 
undertaking his responsibility shortly thereafter and has incurred attorneys' fees 
and costs. 
WHEREAS, the legal bills, including attorneys' fees and costs, have been 
submitted for payment to Epstein through his counsel other than Burman, Critton, 
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Luttier & Coleman, and a portion of the claimed fees and costs have been paid 
by Epstein. 
The attorneys' fees and costs incurred relate to a number of 
individuals. 
WHEREAS, the Podhurst Orseck Firm and its clients on the one hand and 
Epstein, on the other hand, have disagreements regarding what fees and costs 
are due and owing based upon the NPA agreement and various correspondence 
that has been exchanged between the United States Attorneys' Office and 
Epstein and others. 
WHEREAS, the parties have agreed on Sidney A. Stubbs, Esq. to serve 
as a Special Master to make a binding determination with regard to issues 
associated with past and future disputes/disagreements (unless a filed lawsuit) 
relating to entitlement and amount of attorneys' fees and costs. 
The parties therefore agree as follows: 
1. Sidney A. Stubbs, Esq., shall serve as the Special Master to conduct 
whatever hearings and/or proceedings he deems are necessary, 
including any discovery requests and/or issues, so as to determine 
entitlement and amount of attorneys' fees and costs due and owing to 
the Podhurst Orseck Firm by Epstein, currently and in the future, 
pursuant to the NPA. If the parties cannot agree, Mr. Stubbs' decision 
shall be written and in the form of an order. 
2. Epstein agrees that Podhurst Orseck, P.A. is entitled to attorneys fees 
and costs as provided for in the NPA (Section 7A, 7B and 7C). Epstein 
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however contests entitlement if fees and costs are not provided for in 
the NPA. 
3. If suit has been filed, then any issue relating to fees or costs is to be 
determined by the presiding judge only. 
4. No party is required to present expert testimony, but if expert testimony 
is presented, it shall be considered by the special master, as it would 
be in either state of federal court. 
5. The parties may provide legal memoranda, exhibits, witness (fact and 
expert) and any other evidence to support their respective positions. 
6. The Florida Rules of Evidence shall govern the proceeding. 
7. The decisions made by Sidney A. Stubbs, Esq. shall be final and 
binding on these parties, without the ability of any party to appeal that 
decision. Any orders issued by Sidney A. Stubbs, Esq. finding an 
entitlement and an award of fees shall be paid by Epstein within twenty 
(20) days thereof. 
8. Mr. Stubbs shall be paid his hourly rate 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, 
P.A. Is awarded 75% of the amount sought, Epstein shall be 
responsible for 75% of Mr. Stubbs' bill. 
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First Party: 
Jeffrey Epstein 
By: 
ROBERT D. CRITTON, JR., ESQ. 
Florida Bar No. 224162 
Burman, Critton, Luttier & Coleman 
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 West Flagler Street, Suite 800 
Miami, FL 33130 
Attorney Representative 
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