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e-
FROPOSED JOINT LETTER TO : 
SPECIAL MASTER 
Re: 
Special Master: Privileged and Confidential 
Dear Sir: 
The undersigned, as counsel for the United States of America and Jeffrey Epstein, 
jointly write to you to provide information relevant to your service as a Special Master in the 
selection of an attorney to represent several young women who may have civil damages 
claims against Mr. Epstein. 
The U.S. Attorney's Office and the Federal Bureau of Investigation (jointly referred 
to as the "United States") have conducted an investigation of Jeffrey Epstein regarding his 
solicitation of minor females in Palm Beach County to engage in prostitution. Mr. Epstein, 
through his assistants, would recruit underage females to travel to his home in Palm Beach 
to engage in lewd conduct in exchange for money. Based upon the investigation, the United 
States has identified 40 young women who can be characterized as victims pursuant to 18 
U.S.C. § 2255. Some of those women went to Mr. Epstein's home only once, some went 
there as much as 100 times or more. Some of the women's conduct was limited to 
performing a topless or nude massage while Mr. Epstein masturbated himself. For other 
women, the conduct escalated to full sexual intercourse. 
As part of the resolution of the case, Mr. Epstein agreed that he would not contest 
jurisdiction in the Southern District of Florida for any victim who chose to sue him for 
damages pursuant to 18 U.S.C. § 2255. Mr. Epstein agreed to provide an attorney for victims 
who elected to proceed exclusively pursuant to that section, and agreed to waive any 
challenge to liability under that section up to an amount agreed to by the parties. 
08-80736-CV-MARRA 
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"Ibe parties have agreed to submit the selection of an attorney to a Special Master. 
Attached hereto is a list of five attorneys whom the parties have agreed should be considered 
by the Special Master for selection. Also attached hereto is a memorandum explaining the 
anticipated duties and responsibilities of the attorney who is selected, and that portion of the 
agreement between the United States and Mr. Epstein addressing the attorney's role. Each 
attorney has provided some background information regarding his or her practice, 
experience, and other relevant factors. The Special Master may contact any or all of those 
attorneys for additional information, as the Special Master deems appropriate. Each party 
will also provide the Special Master with a list of the criteria that the party believes should 
be considered in making the selection. If the Special Master has any questions regarding the 
criteria, he may contact the relevant party to inquire further, as he deems appropriate. 
The parties ask that the Special Master "rank" the top three attorneys, in case one or 
more has a conflict that preVents him or her from accepting the representation. 
The parties thank you for your willingness to conduct this task as a pro bona public° 
matter. Please do not hesitate to contact us if you need any further information. 
08-80736-CV-MARRA 
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Case 9:08-cv-80736-KAM Document 362-7 Entered on FLSD Docket 02/10/2016 Page 2 of 3 
From: 
Sent: 
To: 
Cc: 
Subject: 
(USAFLS) 
1
, Jeff (USAFLS) 
.
lay, October 18, 2007 4:40 PM 
(USAFLS) 
ollow up 
The change of plea will take place on November 20. Agreed. 
 
Original Message 
From: Jay Lefkowitz (mailto:JLefkowitz@kirkland.com] 
Sent: Thursday, October 18, 2007 4:35 PM 
To: 
, 
(USAFLS) 
Cc: 
, Jeff (USAFLS) 
Subject: Re: Follow up 
- Thanks. 
Jeff, are we all set? 
Jay 
 
 Original Message  
From: " 
, 
(USAFLS)" 
Sent: 10/18/2007 12:15 PM AST 
To: Jay Lefkowitz 
Cc: " 
, Jeff (USAFLS)" 
Subject: RE: Follow up 
Jeff -- Can you see any issues with this? If not, please confirm with Jay. 
 
Original Message 
From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com] 
Sent: Thursday, October 18, 2007 10:12 AM 
To: 
) 
(USAFLS) 
Subject: Follow up 
- I wanted to thank you for making the time for 
breakfast Friday. It was great to catch up. 
Following up on our conversation about the date for Mr. 
Epstein's plea, where you said that you didn't want to 
dictate a schedule to the state, as we discussed I have 
a case where I represent an individual who is now the 
lead witness for the government, and openings are set 
2724 
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of 3 
for next week. Accordingly, I have now confirmed with 
Mr. Epstein's Florida counsel that the state's 
attorney's office and the court will be available to 
have him enter his plea on November 20. 
So we will 
plan to proceed on one that date. Please confirm that 
this is ok. 
Thanks, Jay 
t****************************************************###*## 
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 postmaster@kirkland.com, and 
destroy this communication and all copies thereof, 
including all attachments. 
#************************######******####****************** 
******************************************************44##* 
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 postmaster@kirkland.com, and 
destroy this communication and all copies thereof, 
including all attachments. 
*****************####44g***********************#######****** 
2725 
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Case 9:08-cv-80736-KAM Document 362-8 Entered on FLSD Docket 02/10/2016 Page 2 of 8 
"Siomnn, Jeff (USAFLS)" 
To "Jay Lefkowitz" <JLeikowitz@kirkland.col 
cc i'kfiliainnn Ann 
r: el 'CAN Sr 
10/24/2007 03:45 PM 
bcc 
Subject Epstein - Addendum and Letter to Judge 
g 
erbloo-datil Otik,"txtit: 
<<Addendum.wpd>> <<071015 Special Master Letter4.wpd>> 
Jay, 
Pursuant to our conversation, here is the revised letter and a new 
addendum. Theonly changeto the addendumisthat I renumbered the 
new paragraphs from A,B, aic.o 7A, 7B, and 7C.Once you 
approve,I will contact Judge 
and send him the letter. Please 
execute the addendum,PDFthe executedoriginalto me as soon as 
possible and Fed Ex the original to me thereafter. 
Jeff 
sat 
'Addendum.wpd' has been archived  by user 
'CommonStore/IT/Kirkland-Ellis' on '12/25/2007 00:26:41'. >» 
«< gnachment '071015 Special Master Letter4.wpd' has been 
archived by user 'CommonStore/IT/Kirkland-Olls' on '12/25/2007 
00:26:42'. >> 
US_Atty_Cor_00220 
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IN FIE: 
INVESTIGATION OF 
JEFFREY EPSTEIN 
ADDENDUM TO THE NON-PROSECUTION AGREEMENT 
IT APPEARING that the parties seek to clarify certain provisions of page 4, 
paragraph 7 of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that 
agreement is modified as follows: 
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-patty, 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. 
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 C, 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. s 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 s 2255 to bear the costs of the attorney representative, shall 
cease. 
By signing this Addendum, Epstein asserts and certifies that the above has been read 
and explained to him. Epstein hereby states that he understands the clarifications to the 
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Case 9:08-cv-80736-KAM Document 362-8 Entered on FLSD Docket 02/10/2016 Page 4 of 8 
Non-Prosecution Agreement and agrees to comply with them. 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
Dated: 
Dated: 
Dated: 
A. 
VILLAFARA 
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
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S. Department of Justice 
United States Attorney 
Southern District of Florida 
99 NE ek Street 
Alla* FL 33132-2111 
October 
2007 
LIVE
 l 
i r 
The Hon. 
B. 
(Ret.) 
Akerman Senterfitt 
One Southeast Third Avenue, 25th Floor 
Miami, Florida 33131 
Re: 
Service as a Special Master 
Dear Judge M. 
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 
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The Iion. 
B. 
(Ret.) 
October 
2007 
Page 2 of 4 
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. 
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. 
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The Hon. 
B. 
(Ret.) 
October 
2007 
Page 3 of 4 
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 
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: 
My 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. 
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. 
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. 
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The Hon. 
B. 
(Rot) 
October 
2007 
Page 4 of 4 
If I can provide you with any further information, please do not hesitate to contact 
me. Thank you again for your assistance with this matter. 
Sincerely, 
United States Attorney 
By: 
Jeffrey 
First Assistant United States Attorney 
cc: 
AUSA 
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U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
The Hon. 
B. 
(Ret.) 
Akerman Senterfitt 
One Southeast Third Avenue, 25th Floor 
Miami, Florida 33131 
Re: 
Service as a Special Master 
Dear Judge 
991V.E. 44 Street 
Miami. Fl 33132 
Telephone: (305) 961-9299 
Facsimile: (305) 5304444 
October 25, 2007 
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. 
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TUB HON. 
B. =Rat) 
OCTOBER 25, 2001 
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 
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Tile HONG B. DAVIS (REr.) 
Ocionit 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. 
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THE HON. 
B. 
(Rm.) 
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! can provide you with any further information, please do not hesitate to contact me 
and/or the U.S. Attorney an or Jay Lefkowitz, Esq. on behalf of Epstein. Mr. Leflcowitz can 
be reached at 
- Kirkland & Ellis LLP, Citigroup Center, 153 East 53rd Street, 
Thank you again for your assistance with this matter. 
Sincerely, 
cc: 
AUSA A. 
By: 
United States 
Jeffrey 
First Assistant United States Attorney 
ttomey 
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