EFTA00183732

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
WEST PALM BEACH DIVISION 
CASE NO. 08-80119-CIV-MARRA 
DOE, et al., 
Plaintiffs, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
WEST PALM BEACH, FLORIDA 
JUNE 12, 2009 
9 
10 
TRANSCRIPT OF MOTION HEARING 
11 
BEFORE THE HONORABLE KENNETH A. MARRA, 
UNITED STATES DISTRICT JUDGE 
12 
13 
14 
15 
16
APPEARANCES: 
FOR THE PLAINTIFFS: 
ADAM D. HOROWITZ, ESQ. 
Mermelstein & Horowitz 
18205 Biscayne Boulevard 
Miami, FL 33160 
305.931.2200 
For 
Doe 
BRADLEY J. EDWARDS, ESQ. 
17 
Rothstein Rosenfeldt Adler 
401 East Las Olas Boulevard 
18 
Fort Lauderdale, FL 33301 
Doe 3, 4, 5, 6, 7 
19 
954.522.3456 
20 
ISIDRO M. GARCIA, ESQ. 
Garcia Elkins Boehringer 
21 
224 Datura Avenue 
West Palm Beach, FL 33401 
22 
DOE II 
561.832.8033 
23 
RICHARD H. WILLITS, ESQ. 
2290 10th Avenue North 
24 
Lake Worth, FL 33461 
For 
561.582.7600 
25 
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EFTA00183792

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ROBERT I'. JOSEFSBERG, ESQ. 
2 
Podhurst Orseck Josefsberg 
25 West Flagler Street 
3 
Miami, FL 33130 
Fore 
Doe 101 
305.358.2800 
4 
(Via telephone) 
5 
KATHERINE W. EZELL, ESQ. 
Podhurst Orseck Josefsberg 
6 
25 West Flagler Street 
Miami, FL 33130 
7 
For S 
Doe 101 
305.358.2800 
8 FOR THE DEFENDANT: 
ROBERT D. CRITTON, JR., ESQ. 
MICHAEL BURMAN, ESQ. 
9 
Burman Critton, etc. 
515 North Flagler Street 
10 
West Palm Beach, FL 33401 
561.842.2820 
11 
JACK A. GOLDBERGER, ESQ. 
12 
Atterbury Goldberger Weiss 
250 Australian Avenue South 
13 
West Palm Beach, FL 33401 
561.659.8300 
14 
, ESQ. 
15 
Assistant U.S. Attorney 
500 East Broward Boulevard 
16 
Fort Lauderdale, FL 33394 
For U.S.A. 
954.356.7255 
17 
MARTIN G. WEINBERG, ESQ. 
18 
20 Park Plaza 
Boston MA 02116 
19 
(Via telephone) 
617.227.3700 
20 
JAY LEFKOWITZ, ESQ. 
(Via telephone) 
21 
REPORTED BY: 
LARRY HERR, RPR-RMR-FCRR-AE 
22 
Official United States Court Reporter 
Federally Certified Realtime Reporter 
23 
400 North Miami Avenue, Room 8N09 
Miami, FL 33128 
305.523.5290 
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EFTA00183793

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THE COURT: We are here in the various Doe vs. Epstein 
2 cases. 
3 
May I have counsel state their appearances? 
4 
MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs 
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2 through IIIIIDoe 7. 
6 
THE COURT: Good morning. 
7 
MR. EDWARDS: Brad Edwards, counsel for plaintiff Mil 
8 Doe. 
9 
THE COURT: Good morning. 
10 
MR. GARCIA: Good morning, Your Honor. Sid Garcia for 
11 =Doe 
II. 
12 
THE COURT: Good morning. 
13 
MR. WILLITS: Good morning, Your Honor. Richard 
14 Willits, here on behalf of the plaintiff _.
.
15 
THE COURT: Good morning. 
16 
MS. EZELL: Good morning, Your Honor. I'm Katherine 
17 Ezell from Podhurst orseck, here with Amy Adderly and Susan 
18 Bennett, and I believe my partner, Bob Josefsberg, is going to 
19 appear by telephone. 
20 
THE COURT: Mr. Josefsberg, are you there? 
21 
MR. JOSEFSBERG: I am, Your Honor. 
22 
THE COURT: Good morning. 
23 
MR. JOSEFSBERG: Good morning. 
24 
THE COURT: All right. Do we have all the plaintiffs 
25 stated their appearances? 
Okay. 
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EFTA00183794

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1 as a shield against the plaintiffs that he was supposed to make 
2 restitution for. 
3 
And, certainly, he can take my client's depo. He's 
4 done extensive discovery in the state court case -- very 
5 intrusive, I might add. And we don't care, because we can win 
6 this case with the prosecution agreement or without the 
7 prosecution agreement. We are ready to go forward. 
8 
THE COURT: You're not going to assert to the United 
9 States Government that what he's doing in defending the case is 
10 a violation for which he should be further prosecuted? 
11 
MR. GARCIA: Absolutely not. 
12 
THE COURT: Anyone else for the plaintiffs? 
13 
MR. HOROWITZ: Judge, Adam Horowitz, counsel for 
14 plaintiffs 
Doe 2 through 7. 
15 
I just wanted to address a point that I think you've 
16 articulated it. I just want to make sure it's crystal clear, 
17 which is that we can't paint a broad brush for all of the 
18 cases. 
19 
The provision relating to Mr. Epstein being unable to 
20 contest liability pertains only to those plaintiffs who have 
21 chosen as their sole remedy the federal statute. My clients, 
22 
Doe 2 through 7, have elected to bring additional causes 
23 of action, and it's for that reason we were silent when you 
24 said does anyone here find Mr. Epstein to be in breach of the 
25 non-prosecution agreement. That provision, as we understand 
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EFTA00183795

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1 it, it doesn't relate to our clients. 
2 
THE COURT: Okay. But, again, you're in agreement 
3 with everyone else so far that's spoken on behalf of a 
4 plaintiff that defending the case in the normal course of 
5 conducting discovery and filing motions would not be a breach? 
6 
MR. HOROWITZ: Subject to your rulings, of course, 
7 yes. 
8 
THE COURT: Thank you. 
9 
Anyone else have anything to say from the plaintiffs? 
10 
Ms. 
if you would be so kind as to maybe 
11 help us out. I appreciate the fact that you're here, and I 
12 know you're not a party to these cases and under no obligation 
13 to respond to my inquiries. But as I indicated, it would be 
14 helpful for me to understand the Government's position. 
15 
MS. 
: Thank you, Vour'Honor. And we, of 
16 course, are always happy to try to help the Court as much as 
17 possible. But we are not a party to any of these lawsuits, and 
18 in some ways we are at a disadvantage because we don't have 
19 access. My access is limited to what's on Pacer. So I don't 
20 really know what positions Mr. Epstein may have taken either in 
21 correspondence or in discovery responses that aren't filed in 
22 the case file. 
23 
But your first order was really just what do you think 
24 about a stay, and then the second order related to this hearing 
25 and asked a much more specific question, which is whether we 
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EFTA00183796

STK/mlb 
Kiwi 
LEOPOID-KUVIN, 
CONSUMER JUSTICE ATTORNEYS 
July 31, 2009 
Assistant U.S. Attorney 
Southern District of Florida 
500 E. Broward Blvd, 7th Floor 
Ft. Lauderdale, FL 33394 
Re: 
B.B. 
JEFFREY EPSTEIN 
OUR FILE NO.: 080303 
Dear Ms. MEI 
I am following up on my letter of July 6, 2009, regarding the non-prosecution agreement 
between the U.S. Attorneys office and Jeffrey Epstein. 
Please advise whether or not this document will be produced. 
I 
KUVIN 
2926 PGA Boulevard :ate 200 
Palm Beath Gardena n Florida 33410 I. 681.616.1400 
lax 681.515.1401 
leopoldiaMn.corn 
CRASHWORTHINESS • MANAGED CARE ABUSE • CONSUMER CLASS ACTIONS • PERSONAL INJURY • WRONGFUL DEATH 
EFTA00183797

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Palm Beach. FL 3340! 
(561) 820-8711 
Facsimile: (561) 820.8777 
August 4, 2009 
VIA ELECTRONIC MAIL 
Spencer T. Kuvin, Esq. 
Leopold—Kuvin, P.A. 
2925 PGA Boulevard 
Suite 200 
Palm Beach Gardens, FL 33410 
Re: 
Jeffrey Epstein/B.B. — Requested Disclosure of Non-Prosecution Agreement 
Dear Mr. Kuvin: 
Thank you for your letter regarding the disclosure of the Non-Prosecution Agreement 
signed by Jeffrey Epstein. I understand that you are asking for a copy of that Agreement in 
connection with your representation of "B.B." As you are aware, the Agreement contains a 
confidentiality provision. Based upon a lawsuit filed by some of Mr. Epstein's victims, U.S. 
District Judge Kenneth Marra has issued a Protective Order requiring the U.S. Attorney's Office 
to provide copies of the Agreement to certain individuals under certain circumstances. The 
Order states: 
If any individuals who have been identified by the USAO [U.S. Attorney's 
Office] as victims of Epstein and/or any attorney(s) for those individuals request 
the opportunity to review the Agreement, then the USAO shall produce the 
Agreement to those individuals, so long as those individuals also agree that they 
shall not disclose the Agreement or its terms to any third party absent further 
court order, following notice to and an opportunity for Epstein's counsel to be 
heard. . . 
(Court File No. 08-CV-80737-MARRA, DE 26, 1 (e).) 
The language "individuals who have been identified by the USAO as victims of Epstein" 
refers to a specific list of individuals who were the subject of the federal investigation. A list 
of those individuals was provided to Mr. Epstein's attorney. Your client, B.B., was not 
identified during that investigation, and, therefore was not on the list. By stating this I am not, 
in any way, denigrating any harm that your client may have suffered. I am simply stating that, 
given time and resource limitations that we faced during the investigation, B.B. was not a person 
who was positively identified, such that she would have been the subject of charges within a 
EFTA00183798

SPENCER T. Kuvrri, ESQ. 
Auour 4,2009 
PAOE 2 
possible federal indictment. 
For this reason, your client is not covered by the Court's Protective Order and the 
Agreement's confidentiality provision remains intact. If you are unable to get a copy of the 
Agreement via the civil discovery process in the lawsuit that you have filed against Mr. Epstein, 
please ask his counsel if they will consent to my production of the Agreement to you and I will send 
a copy to you. 
Sincerely, 
Jeffrey H. Sloman 
Acting United States Attorney 
By: 
A 
e/a ..ifarkaa 
. 
Assistant U.S. Attorney 
cc: 
Esq. 
EFTA00183799

Roy BLACK 
HOWARD M. SREBNICK 
Score A. KORNSPAN 
LARRY A. STUMPF 
MARIA NEYRA 
JACKIE PERCZEK 
Manx A.J. SHAPIRO 
JARED 
BLACK 
SREBNICK 
KORNSPAN 
STUMPF 
September 1, 2009 
, Esq. 
Assistant U.S. Attorney 
United States Attorney's Office 
99 N.E. 4th Street 
Miami, Florida 33132 
RE: 
Jeffrey Epstein 
Dear Jeff: 
JESSICA FONSECA-NADER 
*Gammen P. PHILLIPS 
AARON AMON 
MARCOS BEATON, JR. 
MArniew P. O'BRIEN 
JENIPER J. SOULIKIAS 
NOAH Fox 
E-Mail: 
Once again I need to send you a note about Jeffrey Epstein, mainly to keep 
you in the loop so we don't inadvertently violate any provision of his agreement 
with your office. As I am sure you are aware, Mr. Epstein has finished the 
incarceration portion of his sentence and is now serving the one year of 
community control as mandated by both his state plea and the terms of the non-
prosecution agreement with the United States Attorney's Office for the Southern 
District of Florida. 
Mr. Epstein is in compliance with all terms of his community control and 
is applying for transfer of his supervision from the State of Florida to his primary 
residence, the Virgin Islands. This transfer is being requested through the 
Intrastate Compact for Transfer of Adult Supervision (ICAOS). The ICAOS is the 
mechanism for which transfers of probation and community control are 
effectuated. The process requires the offender to seek the approval of the sending 
state (in this case Florida) and, if they agree, the receiving state (in this case the 
United States Virgin Islands) and the United States Virgin Islands after 
investigation has pre-approved the transfer under the same exact conditions of 
supervision as imposed in Mr. Epstein's community control sentence in the State 
of Florida. 
Even though Mr. Epstein is requesting the transfer he is still at the home 
201 S. Biscayne Boulevard. Suite 1300 • Miami, Florida 33131 • Phone•. 305-371-642I • Fax: 305-358-2006 • swiw.RoyBiack.com 
EFTA00183800

Esq. 
September 1, 2009 
Page 2 
in Palm Beach following the rules of state community control. As Mr. Epstein's 
lawyers, we believe that his request to administratively transfer his community 
control is in full compliance with both his state plea agreement and the non-
prosecution agreement with the United States Attorney's Office. Nonetheless we 
have taken to heart your previous suggestion of erring on the side of caution and 
thus we are advising you of this request. 
I am happy to discuss this with you at any time. I did not want to set an 
appointment to see you on this issue since I imagine you have more pressing 
matters to deal with than a transfer of a state community control matter. 
RB/wg 
Very 
Roy Black 
Black. Smbnick. Komspan & Stumpf. PA 
EFTA00183801

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
DELIVERY BY ELECTRONIC MAIL 
Roy Black, Esq. 
Black Srebnick Komspan & Stumpf P.A. 
201 S. Biscayne Blvd, Suite 1300 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Roy: 
500 S. Australian Ave, Ste 400 
West Palm Beach, FL 33401 
(561) 820-8711 
Facsimile: (561) 820-8777 
September 18, 2009 
I write in response to your letter to Mr. Sloman regarding the transfer of supervision 
of Mr. Epstein's community control to the Virgin Islands. I requested from Mr. Goldberger 
a copy of the documentation that Mr. Epstein submitted in support of his request and a copy 
of the interstate compact that you had mentioned. I have not received these documents. 
Rather than wait any longer, I am advising you of our Office's preliminary concerns. The 
Office may have additional concerns upon receipt of the requested items. 
The Non-Prosecution Agreement called for Mr. Epstein to serve eighteen months in 
county jail followed by twelve months of community control. Mr. Epstein's eighteen-month 
jail term was reduced to slightly more than twelve months based upon Mr. Epstein's "work 
release" of more than twelve hours per day, seven days per week. Mr. Epstein has been on 
community control for less than two months and he is already asking that he be allowed to 
transfer his supervision. The request comes on the heels of an instance where Mr. Epstein 
was found by the Palm Beach Police Department walking on the beach. I understand that 
he told the police that he was "walking to work," despite the fact that his "office" was more 
than eight miles away, and the beach where he was found was not en route from his 
residence to his workplace. 
Throughout the negotiation of the NPA, representations were repeatedly made by you 
and your colleagues that Mr. Epstein would serve his complete sentence, including 
community control, in Palm Beach County. During his change of plea and sentencing, Mr. 
EFTA00183802

ROY BLACK, ESQ. 
SEPTEMBER 18, 2009 
PAGE 2 OF 2 
Epstein told the Court that he intended to remain in Palm Beach County during his period of 
community control — a fact that was important to Judge Pucillo in making her decision 
whether or not to accept the plea agreement. Mr. Epstein's presence in Palm Beach County 
was important to the Court, our Office, and, presumably, the State Attorney's Office, because 
it allowed all of these entities to monitor Mr. Epstein's performance of his obligations. 
Relocating to the Virgin Islands, where Mr. Epstein lives on a private island without any 
independent law enforcement presence, would eliminate that ability. 
The Office's ability to determine whether Mr. Epstein has breached the NPA and to 
file charges against him when/if he breaches that Agreement was a key piece of consideration 
for the decision to enter that Agreement. Another key piece was the ability of victims to 
pursue claims against Mr. Epstein under 18 
§ 2255. 
Your September 1, 2009 letter to Mr. Sloman, in essence, asked whether it would be 
the Office's position that Mr. Epstein's move to his private island would violate the terms 
of the NPA. For the reasons stated above, even upon our preliminary review, it is the 
position of the Office that the transfer of community control would frustrate the purpose of 
the agreement and thereby violate its terms. No final decision has been made, of course, 
because Mr. Epstein has not yet moved. However, if Mr. Epstein elects to go forward with 
the transfer of community control with the knowledge of the Office's objection, that will be 
considered, along with all of the previous violations by Mr. Epstein, as set forth in my letters 
of June 15 and July 7, 2009, in determining the Office's final course of action. 
I look forward to receiving the materials requested from Mr. Goldberger. 
Sincerely, 
Jeffrey H. Sloman 
Acting United States Attorney 
By: 
A. no
A. 
Assistant United States Attorney 
cc: IS, 
Chief, Northern Division 
EFTA00183803

STK:mlb 
oiCAT T. I) 
T O' ) 11“:1'C't 
-sz S'A't 
f Y 
LEOPOLD-KUVINn 
CONSUMER JUSTICE ATTORNEV$ 
January 4, 2010 
Assistant U.S. Attorney 
Southern District of Florida 
500 E. Broward Blvd, 7th Floor 
Ft. Lauderdale, FL 33394 
Re: 
B.B. I. JEFFREY EPSTEIN 
OUR FILE NO.: 080303 
Dear Ms. 
After taking the deposition of Police Chief, Michael Reiter, it came to our attention that 
apparently a computer which was initially seized during the search warrant conducted on Mr. 
Epstein's home was returned by the FBI to a private investigator employed by Mr. Epstein. We 
would like to determine who this computer was returned to, and when it was returned. It would 
assist us greatly if you could check your records to determine when, and if, this was ever done. 
Additionally, according to the sworn testimony of Chief Reiter, his department was provided 
with a letter containing a list of potential victims of Mr. Epstein. This letter contained language 
pursuant to a previously unknown Federal Statute which apparently directed him to destroy the 
letter after reading it. We hereby request that your office advise what Statute or Code that letter 
was referring to. Finally, we would like to schedule the depositions of FBI Special Agents 
Nesbitt Kirkendall, Junior Ortiz and Mr. Solomon. Please let me know who we need to direct 
our subpoenas to in order to schedule these depositions. 
I appreciate your immediate attention to this matter. Should you have any additional questions 
about these issues, please do not hesitate to contact me at once. 
VIN 
2925 PGA 6outevane 
Suite 200 
Palm Beach Gamlen* 
Florida 33410 
561.515.1400 . lax 661.516.1401 
ieopoidituvin.com 
CRASIIWORTH IN ESS • MANAGED CARE AAUSL • CONSUMER CLASS ACTIONS • PERSONAL INJURY • WRONGFUL DEATH 
EFTA00183804

ROY BLACK 
HOWARD M. SREBMCK 
SCOTT A. KORNSPAN 
LARRY A. STUMPF 
MAMA NEYRA 
JACKIE PERCZEK 
MARK A.J. SHAPIRO 
JARED 
BLACK 
SREBNICK 
KORNSPAN 
STUMPF 
PA. 
January 20, 2010 
, Esq. 
Assistant United States Attorney 
United States Attorney's Office 
Southern District of Florida 
500 South Australian Avenue 
Suite 400 
West Palm Beach, Florida 33401 
RE: Jeffrey Epstein 
Dear 
JESSICA FONSECA-NADER 
KATHLEEN P. PHILUPS 
AARON ANTHON 
MARCOS BEATON, JR. 
MATTHEW P. OBRIEN 
JENIPER J. SOULIKIAS 
NOAH Fox 
E-Mail: RelaciSityBlack.com 
We are now facing a difficult issue about the attorney's fees in the civil cases 
brought against Mr. Epstein related to your prior criminal investigation. I 
broached this subject with you on the phone a couple of weeks ago, but I could 
see our discussion was not fruitful at that time. Since we could not come to any 
agreement on how to handle this, we must proceed ahead based on our 
understanding of the non-prosecution agreement. 
Mr. Epstein has paid the attorney representative $526,000 and accepts his 
obligation under the NPA to pay additional reasonable legal fees that precede 
litigation claims under 17C of the Addendum. However we believe that the 
request by the attorney representative for over $1.5M additional fees is both 
unreasonable and outside the Addendum's criteria for payment. 
Litigation may ensue since we have been unable to resolve these matters 
through an agreement. We never contemplated that the legal fee agreement would 
result in a bill for $2.1M when the Addendum was entered. We understand you 
and Jay had different views on whether an attorney representative could both sue 
Epstein for some clients and remain as counsel to settle other cases. We believe 
that the attorney representative could either settle the cases and be paid hourly 
or litigate and be paid out of the judgment, but not both. The language of the NPA 
is in need of legal construction regarding whether Epstein's obligations end when 
201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • Phone: 305-371-6421  Fax: 305-358-2006 • www.RoyBluck.com 
EFTA00183805

A. 
, Esq. 
January 20, 2010 
Page 2 
the attorney representative brings a lawsuit for any of his clients - a matter that 
a court should settle free from any consideration that initiating litigation to resolve 
this outstanding issue would be perceived as a breach. 
Just to be sure, Mr. Epstein will pay whatever fees a court determines are 
owed and we only want assurance that litigating the legal and factual issues over 
such liability will be consistent with and not violate the NPA. We don't think it is 
the government's position that Epstein must simply pay any bill he receives, 
regardless of the amount and type of work done, particularly one for $2.1M. So we 
have no alternative but to go to court to resolve this issue. We are sending you 
this letter because the attorney representative is using the threat of a breach as 
leverage to get his fees. I don't believe the government's power to indict and 
incarcerate should be used to assist a private lawyer in collecting an exorbitant 
legal fee. Thus we are putting you on notice, and asking that if you disagree with 
our legal opinion that a suit is not in conflict with the NPA, to tell us without 
delay. 
Cordially yours, 
MW:RC:RB/wg 
Martin G. Weinberg, Esq. 
Robert D. Critton, Jr. 
Roy Black 
By: 
Roy Blac 
Black. SrebnIck, Kornspan & Stumpf, PA 
EFTA00183806

a,m
(USAFLS) 
From: 
Roy BLACK 
To: 
Will 
. (USAFLS) 
Sent: 
Cc: 
ow mgw@wor ne .a .net 
Subject: 
Yesterdays Letter 
Dear 
On second thought my letter yesterday went too far in one respect. So that there Is no misunderstanding of 
the last paragraph of yesterdays letter, our concern is not that the attorney representative in fact has used the threat of 
a breach as leverage to get his fees, only that there exists the legitimate concern that the agreement could be so used 
and the reality that any concern about such use significantly and unfairly burdens Mr Epstein's right to resort to the 
courts to resolve outstanding legal issues regarding the criteria for payment and the amount of payment owed. I hope 
this clarifies our concern in this one area. Thanks Roy 
EFTA00183807

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, Ste 400 
West Palm Beach, FL 3340! 
(561)820-8711 
Facsimile: (561) 820-8777 
February 11, 2010 
DELIVERY BY ELECTRONIC MAIL 
Roy Black, Esq. 
Black Srebnick Kornspan & Stumpf P.A. 
201 S. Biscayne Blvd, Suite 1300 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Mr. Black: 
Thank you for meeting with our Office last week. During our discussion, you and your 
colleagues raised three issues: (1) whether our Office would consider it a breach of the Non-
Prosecution Agreement for Mr. Epstein to file suit against the victim's attorney-representative 
relating to the amount of attorney's fees; (2) whether our Office would consider it a breach of the 
Non-Prosecution A g "fin t for Mr. Epstein to argue that he has no liability for claims raised 
exclusively under 18 
. § 2255 as to any of the victims on the identified list; and (3) whether 
our Office would have any objection to Mr. Epstein applying for early termination of his community 
control. 
As we have told you before, our Office cannot give advisory opinions as to what will and will 
not be a breach of the Non-Prosecution Agreement. Furthermore, as to the first item, your colleagues 
admitted that efforts to reach an agreement with Robert Josefsberg regarding the amount of fees 
owed have not been completed. Similarly, as to the second itur 
colleagues admitted that there 
are no currently pending cases arising exclusively under 18 
. § 2255 as to any of the victims 
on the identified list. Given that these matters may never arise and, if they do arise, there will be 
innumerable legal and factual issues that have not been shared with our Office, we again decline to 
provide any advisory opinions. As discussed during the meeting, the purpose of having the parties 
and a Special Master involved at the beginning of the process in the selection of the attorney-
representative was to avoid dealing with this issue at the end of the process. As with all matters 
related to the Agreement, we expect that Mr. Epstein will act in good faith and comply with the letter 
and spirit of the NPA. 
As to the third item, we have reviewed your letter to Mr. Sloman of February 8, 2010. While 
Mr. Acosta did state in his letter of December 19, 2007, that he did not believe that the Office was 
EFTA00183808

ROY BLACK, ESQ. 
FEBRUARY 11, 2010 
PAGE 2 OF 2 
obligated to notify the victims identified through the federal investigation of proceedings occurring 
in state court, the U.S. Department of Justice's position may have chiral the interim ill 
of 
internal guidance regarding prosecutors' obligations pursuant to 18 
. § 3771, 42 
. § 
10607, and Fed. R. Crim. P. 60 (effective December I, 2008). 
In light of Mr. Acosta's prior statements to Mr. Epstein's counsel that Mr. Epstein would be 
eligible for any benefit available to other similarly-situated state defendants, the Office agrees that 
Mr. Epstein may apply for early termination or modification of community control in accordance 
with Fl. Stat. §§ 948.05 and 948.10(4), assuming that Mr. Epstein has completed "the sanctions 
imposed in the community control plan." The Office takes no position regarding such an 
application; it is entirely within the discretion of the State Attorney's Office and the Palm Beach 
County Circuit Court Judge as to whether it is in "the best interests of justice and the welfare of 
society" to allow Mr. Epstein to terminate prematurely his community control. Mr. Epstein and his 
counsel may no make a representation to the State Attorney's Office, the Court, or any victim that 
the U.S. Attorney's Office agrees with, joins in, or does not oppose such a motion. In light of prior 
erroneous statements in court filings, we respectfully request that a copy of any court filing be 
provided to our office. 
If such a motion is made, in accordance with your proposal, the U.S. Attorney's Office will 
notify the federal victims that the application was filed and, if a hearing is scheduled, the date, time, 
and location of such hearing. The communication will consist merely of a notification and will 
neither encourage nor discourage attendance or submission of materials related to the application. 
Sincerely, 
Jeffrey H. Sloman 
United States Attorney 
By: 
s/A. 
Villa afia 
A. 
Assistant United States Attorney 
cc: 
Jeffrey H. Sloman, U.S. Attorney 
Robert K. Senior, Acting First Assistant U.S. Attorney 
Chief, Northern Division 
EFTA00183809

ROY BLACK 
HOWARD M. SREBNICK 
SCOTT A. KORNSPAN 
LARRY A. STUMPF 
MARIA NEYRA 
JACKIE PERCZEX 
MARK A.J. SHAPIRO 
JARED 
BLACK 
SREBNICK 
KORNSPAN 
&STUMPF 
-RA.-
February 18, 2010 
, Esq. 
Assistant United States Attorney 
99 N.E. 4th Street 
Miami, FL 33132 
RE: 
Jeffrey Epstein 
Dear Ms 
JESSICA FONSECA-NADER 
KATHLEEN P. PHILLIPS 
AARON AN'THON 
MARCOS BEATON, JR. 
MATTHEW P. O'BRIEN 
JENIFER J. SouumAs 
NOAH Fox 
E-Mail: Rfilack®Royffiackcom 
Thank you for your letter of February 11, 2010. We write to update you 
about ongoing efforts to reach an agreement with Robert Josefsberg regarding the 
amount of fees and costs properly owed to him by Mr. Epstein pursuant to the 
NPA. 
On February 16, 2010 Mr. Epstein's principal civil counsel Bob Critton 
advised Mr. Josefsberg in writing that he and Mr. Epstein would meet with Mr. 
Josefsberg on two occasions between now and March 1, 2010 to review Mr. 
Josefsberg's outstanding bills on a line-by-line basis and attempt to reach a non-
adversarial resolution of all outstanding fee issues. Mr. Critton also transmitted 
to Mr. Josefsberg an Agreement for Special Master to Determine Amount of 
Attorneys' Fees and Costs ("Special Master Agreement"), signed by Mr. Epstein, 
containing terms and conditions previously agreed to by Mr. Josefsberg, which 
would mandate binding mediation before a neutral third party in the event the 
proposed settlement discussions did not resolve all outstanding issues in an 
expeditious manner. 
We want to assure you that Mr. Epstein fully intends to fulfill his obligations 
under the NPA. We regret that issues remain unresolved regarding whether all of 
the fees and costs being sought by the attorney representative - which now total 
$1,947,000 exclusive of the $526,466 already paid by Mr. Epstein - meet the 
criteria set forth by the NPA. We assure you that both Mr. Epstein's prior civil 
counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the NPA 
language, and Mr. Critton, each strongly believe that significant amounts of the 
fees and costs billed by Mr. Josefsberg are outside the scope of Mr. Epstein's fee-
201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • Phone: 305.371-6421 • Fax: 305-358-2006 • www.RoyBlack.com 
EFTA00183810

Esq. 
February 18, 2010 
Page 2 
related payment obligations under the NPA. We hope that the fee-related issues 
can be resolved by further settlement discussions or by relying on the Special 
Master Agreement signed Tuesday February 16, 2010 by Mr. Epstein. Mr. Epstein 
and his counsel believe that these options are consistent with the NPA, are good 
faith alternatives to contested litigation, and are reasonable given the unexpected 
magnitude of the bills and their inclusion of charges for legal work that was 
clearly related to the preparation of litigation and thus outside Par 7C of the 
Addendum as well as for extensive work performed by attorneys from outside Mr. 
Josefsberg's law firm. 
Mr. Josefsberg previously advocated for settling outstanding issues through 
a Special Master Agreement nearly identical to the one executed Tuesday by Mr. 
Epstein. In fact, Mr. Joscfsberg and Mr. Epstein had each agreed in the past to 
a specific Master as a third-party neutral to conduct proceedings to resolve the fee 
issues. However, the selected Master withdrew. 
We hope that the Special Master Agreement will provide a basis for a prompt 
resolution of any issue not resolved by the parties through further discussions. 
Respectfully submitted, 
MARTIN WEINBERG, ESQ. 
ROY 
LACK, ESQ. 
By 
/wg 
cc: 
, Esq. 
Robert Senior, Esq. 
Black. Srebnick, Kornspan & Stumpf, P.A. 
EFTA00183811