EFTA00208970

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PROPOSED JOINT LETTER TO THE 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. 
RFP MIA 000302 
EFTA00208990

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The 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 bono publico 
matter. Please do not hesitate to contact us if you need any further information. 
RFP MIA 000303 
EFTA00208991

Villafana, Ann Marie C. (USAFLS) 
Villafana, Ann Marie C. (USAFLS) 
(IF 
Wednesday, October 03. 2007 7:30 PM 
Jay Lefkowitz 
.sUbject: 
RE: Proposed Letter to Special Master 
Hi Jay -- That was simply a draft for discussion purposes. I am hoping that we will send such a letter jointly, once we 
have finalized the process and pick a master. Thanks. 
From: .lay Lefkowitz [mailto:Jlefkowitz@kirkland.comj 
Sent: Wed 10/3/2007 4:26 PM 
To: Vineland, Ann Marie C. (USAFLS) 
Subject: Re: Proposed Letter to Special Master 
Marie - I, too, am interested In speed. But I really need to go over this and then discuss with Jeffrey. So please do not 
send this to any Special Master before we discuss the next steps. 
Thanks -- Jay 
"Vallafana. Am Mari* C. (USAFLS)" 
<AnnAlasii.C.VIllalansttusdOidapv>
101012007 04 74 PM 
To 'Jay Ledtcreitz- ctILdsoyetznitAland.com>
cc
SuOpect Proposed Letter to Special Master 
Hi Jay - To move things along, I also have enclosed the proposed text of a letter to the Special Master. 
«PROPOSED Letter to Special Master.pdf» 
A. Mark Villafana 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
RFP MIA 000304 
EFTA00208992

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
ent: 
Friday, October 05, 2007 7:49 AM 
Jay Lefkowitz 
-subject: 
RE: Proposed Letter to Special Master 
Good morning, Jay. We need to resolve the attorney issue today. It has been weeks since execution of the contract, and 
there is no need for further delay. 
As far as the five attorney names that we will be providing, I propose Bert Ocariz, Katherine Ezell at Podhurst Orseck, 
Stuart Grossman. Ed Rogers, and Walter Cobath. 
If you would like to use the same Special Master to resolve fees disputes as well as to handle the selection of the 
attorney, I would recommend that we use retired 11th Circuit Judge Joseph Hatchett instead of Judge Davis because of 
Judge Davis's health problems. (No one has contacted Judge Hatchett yet, but one of the District Judges in Miami 
mentioned him as a good choice.) 
I am available for a conference call between 9:00 and 10:00, and between 3:15 and 6:00. Please call me on my cell (561 
601-2301) and let me know which of those times works best for you. 
Thank you. 
From: Jay Lefkowitz [mailto:3Lefkowitz@kirkland.com] 
Sent: Wed 10/3/2007 4:26 PM 
To: Villafana, Ann Marie C. (USAFLS) 
"Object: Re: Proposed Letter to Special Master 
Marie - I, too, am interested in speed. But I really need to go over this and then discuss with Jeffrey. So please do not 
send this to any Special Master before we discuss the next steps. 
Thanks -- Jay 
'Villeins, Ann Marl* C. (USAFLS)' 
cAnn.Marie.C.VIllafanatusdoloov>
10/03/2007 04:24 PM 
To ;lay Lefkowitz" <JLefkomta0kirkland.com>
cc 
Subject Proposed Letter to Special Master 
Hi Jay — To move things along, I also have enclosed the proposed text of a letter to the Special Master. 
«PROPOSED Letter to Special Master.pdf» 
A. Marie Villafaiia 
Assistant U.S. Attorney 
• 
209-1047 
RFP MIA 000305 
EFTA00208993

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Fax 561 820-8777 
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2 
RFP MIA 000306 
EFTA00208994

Villafana, Ann Marie C. (USAFLS) 
From: 
JayLefkowttIpLefkomaziDkirMand.coml 
nt 
Friday, October 05.2007 11:04 AM 
. 
Villedana,AnnhiarieC.(USAFLS) 
...c: 
Loude, Andrew; wilapirm@vioddnetaft me; glewis@lewiMeincom 
Subject: 
RE: Proposed Letter to Special Master 
Attachments: 
PROPOSED Letter to Special Master.pdf; Special Master ProposeLudt; Ltr from Lefkowitz to 
),IiiWane (Oct. 5, 2007)_(12135690_4DOC 
Marie, 
Attached is a letter responding to your latest proposals. For your convenience, I've also attached your prior e-mails and 
attachments regarding this matter so that you can easiy see what I am responding to (see the chain below). If you are 
avaiable, I'm free to talk at 5:30 this evening. We can use my usual call-in number at (866) 462.0164. The code is 
'4464970*. 
Thanks, 
Jay 
• 
"Mean; Ann Merle C. (USAFUIr 
cAnn.Marle.C.VNIstanafluidolore
10/052007 07:45 AM 
To *my Lefradite c althaengakiddrigSZP 
Subject RE: Peopose0 Lett lo Special Mauler 
Good morning, Jay. 
We need to resolve the attorney issue today. 
It has been weeks since 
execution of the contract, and there is no need for further delay. 
As far as the five attorney names that we will be providing, I propose Bert Ocariz, 
Katherine Ezell at Podhurst Orseck, Stuart Grossman, Ed Rogers, and Walter Cobath. 
If you would like to use the same Special Master to resolve fees disputes as well as to 
handle the selection of the attorney, I would recommend that we use retired 11th Circuit 
Judge Joseph Hatchett instead of Judge Davis because of Judge Davis's health problems. 
(No one has contacted Judge Hatchett yet, but one of the District 
Judges in Miami 
mentioned him as a good choice.) 
I am available for a conference call between 9:00 and 10:00, and between 3:15 and 6:00. 
Please call me on my cell (561 601-2301) and let me know which of those times works best 
you. 
ank you. 
1 
RFP MIA 000307 
EFTA00208995

From: Jay Lefkowitz (mailto:JLefkowitz@kirkland.comi 
Sent: Wed 10/3/2007 4:26 PM 
Villafana, Ann Marie C. (USAFLS) 
bject: Re: Proposed Letter to Special Master 
Marie - I, too, am interested in speed. But I really need to go over this and then 
discuss with Jeffrey. So please do not send this to any Special Master before we discuss 
the next steps. 
Thanks -- Jay 
"Villafana, Ann Marie C. (USAFLS)" cAnn.Marie.C.VillafanaOusdoj.gov>
10/03/2007 04:24 PM 
To 
"Jay Lefkowitz" <JLefkowitzBkirkland.com>
cc 
Subject 
Proposed Letter to Special Master 
III, 
Jay - To move things along, I also have enclosed the proposed text of a letter to the 
apecial Master. 
«PROPOSED Letter to Special Master.pdf» 
A. Marie Villafana 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
'Malaria. Ann Marty C. (USAFLS)' 
.4Ann.Markt,VAllefonseusdoLoov>
10/03/2007 04:24 PM 
To "Jay Leficovaitte calLerkowitalltkirkland.com>
cc 
Subject Proposed Letter to Special Master 
Hi Jay — To move things along, I also have enclosed the proposed text of a letter to the Special Master. 
•ROPOSED Letter to Special Master.pdf» 
A. Marie Villafatia 
2 
RFP MIA 000308 
EFTA00208996

. 
Assistant U.S. Attorney 
561 209-1047 
• 
x 561 820-8777 
ViUlan.. Ann Made C (USAFLS)" 
<Ann Mat4 C 
V Mai ilnatin0QA 
OCONI> 
10;03/7007 03 18 PM 
To 'Jay Lens:Pate <JleOkomezi5lIkekland we> 
cc 
SuMeM Memo m PDF format 
Hi Jay - In case you can't open the other version, here it is in pill 
«Special Master Proposai.pet» 
A. Marie Villafada 
Assistant U.S. Attorney 
561 209-1047 
OX 561 820-8777 
• 
3 
RFP 
MIA 000309 
EFTA00208997

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Kenneth W. Stan 
To Cal Writer Directly: 
213 6804440 
kstarteltirkland com 
October 5, 2007 
VIA FEDERAL EXPRESS 
A. Marie Villafana 
United States Attorney's Office 
Southern District of Florida 
500 South Australian Avenue, Suite 400 
West Palm Beach, Florida 33401 
Re: Jeffrey Epstein 
Dear Marie: 
Dir. Fax: 213480-6500 
I write in response to your emails dated October 3, 2007 in which you propose the use of 
a Special Master to select an attorney representative (the "selected attorney"), a general outline 
of how the selected attorney should proceed pursuant to the Federal Plea Agreement (the 
"Agreement"), and a drag joint letter to the Special Master. Below, I've outlined our main areas 
of concern with the approach you have taken in your proposed drafts. Once we can come to a 
resolution on the issues detailed herein, we would be happy to cooperate with you on the specific 
drafting of the proposals. 
First, the Agreement does not provide for the appointment of a Special Master to appoint 
the selected attorney. In fact, the Federal Plea Agreement clearly states that "the United States, 
in consultation with and subject to the good faith approval of Epstein's counsel, shall select an 
attorney representative for these persons." (Paragraph 7, Agreement). Thus, the Agreement only 
contemplates the selection of one selected attorney who will represent the identified individuals 
in a limited capacity. We see no need for the appointment of a Special Master, nor does the 
Agreement call for one. 
Second, if the parties cannot settle on a damages amount with Mr. Epstein, then the 
selected attorney may not continue his representation and is barred from filing lawsuits pursuant 
to § 2255. Paragraph 7 and Paragraph 8 of the Agicciiient outline the scope and manner of 
representation of the identified individuals. Specifically, Paragraph 7 defines who may be 
represented by the selected attorney and Paragraph 8 outlines the terms of that representation. 
And under Paragraph 8 of the Agreement, the selected attorney is only appointed to protect the 
interests of those individuals who elect to waive any claim for damages other than the damages 
agreed to by the parties. Paragraph 8 states: 
RFP MIA 000310 
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October 5, 2007 
Page 2 
If any of the individuals referred to in paragraph (7), supra, 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 this 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 as agreed to between the 
identified individual and Epstein, 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, as 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. 
Paragraph 8 addresses how Mr. Epstein's waivers are triggered pursuant to a settlement 
with each identified individual. The Agreement's silence with respect to what happens if the 
parties cannot settle on a damages amount indicates that the parties intended for the scope of the 
selected attorney's representation to be limited to settling claims with Mr. Epstein, not 
representing these identified individuals in § 2255 lawsuits. 
Otherwise, the selected attorney will be faced with serious conflicts of interest. For 
instance, if Mr. Epstein agrees to pay for the selected attorney's fees and monthly expenses, then 
the selected attorney would effectively be incentivized to reject settlement under § 2255 in an 
effort to draw out the lawsuits and incur more fees. If allowed to represent the identified 
individuals in a lawsuit, the best interests of each identified individual may not be served because 
the selected attorney will always be more interested in pursuing lawsuits in lieu of settling claims 
against Mr. Epstein efficiently and fairly. Multiple representation of a group of individuals that 
elects to settle on damages as well as one or more individuals who reject settlement carries with 
it the heightened potential for irreparable conflicts. For example, a conflict could arise if the 
selected attorney represents both a client who may be a potential witness and a client who is a 
civil plaintiff. And the fact that Mr. Epstein could pay compensation to the plaintiff's attorney in 
such a case only underscores this conflict. 
The procedure we propose is reasonable and consistent with the Agreement and intention 
of the parties: the selected attorney should evaluate the claims of each identified individual, 
negotiate a total fund amount with Mr. Epstein, then distribute the monies based on the strength 
of each case. For those identified individuals who elect not to settle with Mr. Epstein, they may 
proceed on their own, but by doing so, they would not be suing under § 2255 as contemplated by 
Paragraph 8 and therefore may not continue to be represented by the selected attorney. 
RFP MIA 000311 
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October 5, 2007 
Page 3 
Third, if the identified individuals choose not to settle with Mr. Epstein, he will not waive 
liability for those individuals whose claims are not settled by the selected attorney. Paragraph 8 
is clear that Mr. Epstein will only waive § 2255 liability so long as each identified individual 
proceeds exclusively under § 2255 and agrees to waive damages other than "an amount as agreed 
to between the identified individual and Epstein." (Paragraph 8, Agreement) This interpretation 
is supported by your own language in the draft proposed joint letter to the Special Master ("Mr. 
Epstein...agreed to waive any challenge to liability under that section up to an amount agreed to 
by the parties."). Consequently, those identified individuals who choose not to settle with Mr. 
Epstein are not covered by the Agreement and will have to prove, among other things, that they 
are victims under the enumerated statutes. 
Fourth, our objections to the appointment of a Special Master notwithstanding, we have 
serious concerns regarding the language in your draft joint letter to the Special Master, which 
describes Mr. Epstein's alleged conduct. Specifically, we will not concede that "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," because we think this overstates the facts. In 
addition, we will not concede that his most benign conduct involved topless or nude massage by 
the identified individuals while he masturbated. Nor will we concede that some of the identified 
individuals visited Mr. Epstein's home over one hundred times. Any joint statement must be 
such that it cannot be construed as a stipulation to liability that could be utilized against Mr. 
Epstein as to any individual who elects to reject the settlement contemplated by the Agreement. 
Fifth, neither federal agents nor anyone from your Office should contact the identified 
individuals to inform them of the resolution of the case, including appointment of the selected 
attorney and the settlement process. Not only would that violate the confidentiality of the 
agreement, but Mr. Epstein also will have no control of what is communicated to the identified 
individuals at this most critical stage. We believe it is essential that we participate in crafting a 
mutually acceptable communication to the identified individuals — perhaps in the form of a joint 
letter explaining the resolution and the settlement process. We further believe that 
communications between yourself or your case agents and the identified individuals might well 
violate Rule 6(e)(2XB) of the Federal Rules of Criminal Procedure. The powers of the federal 
grand jury should not, even in appearance, be utilized to advance the interests of a party to a civil 
lawsuit. 
Finally, we are also concerned that you have been engaging in conversations with judges 
about this matter. 
We look forward to resolving these open issues with you at your earliest convenience. 
RFP MIA 000312 
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October 5, 2007 
Page 4 
Sincerely, 
Jay P. Lefkowitz 
RFP MIA 000313 
EFTA00209001

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FOWLERWHITE 
BURNETT 
MMMT • FORT LAUOIROALE • WEST PALM BEACH • ST. PETERSBURG 
October 8, 2007 
Jeffrey Sloman 
First 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 Jeff: 
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OwtocT Piec No.; 130517890279 
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I
LVIA FEDERAL EXPRESS II 
I write to follow up on the conversation we had regarding the role of the 
attorney representative and the settlement process for 18 U.S.C. § 2255 claims 
pursuant to the Federal Plea Agreement between your Office and Mr. Epstein (the 
"Agreement"). First, thank you for reaching out to Marie on these issues. Marie 
has already left me a voicemail this afternoon asking that I clarify the selection 
process for the attorney representative and the scope of his role pursuant to the 
Agreement. 
With respect to the selection of the attorney representative, you have 
suggested Former Judge Edward B. Davis of Akerman Senterfitt. 
We are 
comfortable with Judge Davis. Pursuant to the Agreement, Judge Davis will 
represent the identified individuals provided they opt to enter into a settlement 
agreement with Mr. Epstein with respect to their § 2255 claims. If the identified 
individuals cannot settle or opt not to settle on a damages amount with Mr. Epstein, 
then Judge Davis may not continue his representation and is barred from filing 
lawsuits pursuant to § 2255. 
As agreed, Mr. Epstein will pay the fees for the 
services of Judge Davis. 
The provisions of the Agreement make clear that the role of the attorney 
representative is to settle the claims of the identified individuals pursuant to the 
Agreement. While Paragraph 7 defines who may be represented by the attorney 
representative, Paragraph 8 outlines the scope of that representation. Paragraph 7 
states: 
The United States shall provide Epstein's attorneys 
with a list of individuals whom it has identified as 
victims, as defined in 18 U.S.C. § 2255, after Epstein 
FOWLER WHITE BURNETT P.A. 
RFP MIA 000314 
EFTA00209002

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Page 2 
has signed this agreement and has been sentenced. Upon 
the execution of this agreement, the United States, in 
consultation with and subject to the good faith 
approval of Epstein's counsel, shall select an attorney 
representative for these persons, who shall be paid for 
by Epstein. Epstein's counsel may contact the 
identified individuals through that representative. 
Under Paragraph 8 of the Agreement, which provides the terms of the 
representation, the attorney representative is only appointed to protect the interests 
of the identified individuals who elect to waive any claim for damages other than the 
damages agreed to by the parties. Paragraph 8 states: 
If any of the individuals referred to in paragraph (7), 
supra, 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 this 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 as agreed to between the identified individual 
and Epstein, 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, as 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. 
Mr. Epstein's waivers are triggered pursuant to a settlement with each 
identified individual. Paragraph 8 is clear that Mr. Epstein will only waive § 2255 
liability "so long as" each identified individual proceeds exclusively under § 2255 
and agrees to waive damages other than "an amount as agreed to between the 
identified individual and Epstein." 
To that end, Judge Davis' role should be limited to contact, coordination and 
mediation. This would include the following: 
- Interviewing each identified individual to confirm standing; 
- Explaining the identified individual's option to settle § 2255 claims pursuant to 
the Agreement; 
- Explaining Mr. Epstein's waivers as to jurisdiction, liability and damages only if 
the identified individuals elect to settle claims pursuant to the Agreement; 
FOWLER WHITE BURNETT P.A. 
RFP MIA 000315 
EFTA00209003

Page 3 
- Explaining the capacity of his representation, including an explanation that his 
role is limited to negotiating settlement amounts for each identified individual; 
- Negotiating a total amount with Mr. Epstein pursuant to the Agreement for each 
identified individual; 
- Distribute the monies to each identified individual in the manna he sees fit; and 
- Assure that the United States Attorney's Office and the FBI not be involved in 
the civil settlement or litigation. 
If any of the identified individuals decide not to utilize Judge Davis 
pursuant to the Agreement, they may proceed on their own, but by doing so, they 
would not be proceeding as contemplated by Paragraph 8 and therefore may not 
continue to be represented by Judge Davis. 
Marie indicated in her message that she would be talking to Jay Lefkowitz 
tomorrow. In the interest of finality on this matter, I would greatly appreciate it 
if you could confirm for me that both the settlement procedure and the scope of 
Judge Davis' representation is resolved. 
Finally, I find it imperative that we have a meeting later this week with 
you to finalize this agreement. It should not take longer than 90 minutes. I hope 
you can set aside the time. 
Jeff, I greatly appreciate your efforts in helping to resolve this matter. I 
look forward to hearing from you shortly regarding your availability. 
Very truly yours, 
/s/ 
Lilly Ann Sanchez 
cc: Jay Lefkowitz, Esq. 
Alan Dershowitz, Esq. 
Martin Weinberg, Esq. 
Wit) W 'Met ***** 202 LAS (IWW7-20151 
FOWLER WHITE BURNETT P.A. 
RFP MIA 000316 
EFTA00209004

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
fra nt: 
Tuesday, October 09, 2007 5:09 PM 
Lilly Ann Sanchez 
mac: 
Sloman, Jeff (USAFLS) 
Subject: 
Jeffrey Epstein 
Attachments: 
071009 Sanchez Ltr.pdf 
Dear Lilly: Enclosed please find a response to your letter to Jeff Sloman. You can reach me at 561 
Thank you. 
Marie 
• 
• 
RFP MIA 000317 
EFTA00209005

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Paint Beach, FL 33401 
($61) 8204711 
Facsimile: (561)820-8777 
October 9, 2007 
VIA ELECTRONIC MAIL 
Lilly Ann Sanchez, Esq. 
Fowler White Burnett 
1395 Brickell Ave Fl 14 
Miami Florida 33131-3300 
Re: 
Jeffrey Epstein 
Dear Lilly: 
Thank you for your letter to First Assistant Sloman regarding the selection of an attorney to 
represent the victims identified in the investigation of Mr. Epstein. While I appreciate your client's 
interest in a resolution of the victim's claims without the filing of lawsuits, I do not believe that your 
proposal falls within the terms of the Non-Prosecution Agreement signed by your client and the 
United States. 
I would reconunend the following. The U.S. Attorney's Office would ask Judge Davis to 
assist in the selection of one or more attorneys to represent the identified victims. If Judge Davis 
is willing to perform that limited service pro bono, Mr. Epstein will not need to pay for that service. 
The United States would provide Judge Davis with a list of criteria for the selection of the 
attorney(s). 
The selected attomey(s) would represent the victim(s) on a contingency fee basis, pursuant 
to a fee agreement reached between the victim(s) and the attomey(s). If he deems it appropriate, 
Judge Davis can propose the terms of that agreement, subject to acceptance by the victim. The 
lawyer(s) can interview each potential client to determine how they want to proceed — including 
whether she wants to use the attorney selected by Judge Davis or if she wants to choose her own 
attorney. Judge Davis can advise the selected attorney(s) of Mr. Epstein's desire to settle the cases 
out of court using Judge Davis as the mediator/special master, which the attorneys can report to their 
clients. If any one or more of the victims, in consultation with their independent counsel, wants to 
mediate the case, and agrees that Judge Davis should serve as the mediator/special master, they can 
proceed accordingly. At that point, Mr. Epstein's payment of Judge Davis's fees would be more 
appropriate. 
RFP MIA 000318 
EFTA00209006

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LILLY ANN SANCHEZ, ESQ. 
OCTOBER 9, 2007 
PAGE 2 
I am out of the District, so I am not available to meet with you this week. I am available for 
a telephone conference tomorrow at 5:00 p.m. or Thursday at 5:00 p.m., if you would like to discuss 
this in more detail. I also have not heard any more from Jay Lefkowitz or Guy Lewis, so please let 
me know whether I need to contact them directly or if you will share this information with them. 
Thank you for your assistance. 
cc: 
Jeffrey Sloman, Esq. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
s/A. Marie Villafaiia 
A. Marie Villafana 
Assistant United States Attorney 
RFP MIA 000319 
EFTA00209007

Villafana, Ann Marie C. (USAFLS) 
From: 
Stornan,Jeff(USAFLS) 
411,
mt 
Monday.Cctober22.20074:41 PM 
I: 
Jay Lefkowitz 
Cc: 
Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS) 
Subject: 
Epstein 
Attachments: 
071015 Special Master Letter3.wpd; Addendum.wpd 
Jay, 
The Judge Davis issue is a non-starter. We've beaten that horse to death. Regarding your 
contention that "the attorney representative be told clearly that Mr. Epstein has agreed to 
pay the lawyer's hourly rate only for the time he or she spends working to effectuate 
settlements for the identified women," Alex and I agree that paragraph 7C is sufficient, 
Regarding the other points, we have made the following concessions: 
1. 
Regarding the language concerning a lawyer whose firm is sizeable enough to litigate 
multiple trials simultaneously, I have removed paragraph 4 on page 3 of the letter. 
2. 
Regarding the 150k statutory limit language, I have included a footnote which should 
satisfy your concern. 
3. 
Regarding language there may be discovery to test the claims of alleged "victims", 
please see new paragraph 4 on page 3 which now states as criteria that the firm should have 
"Experience litigating against large law firms and high profile attorneys who may test the 
veracity of the victims' claims." 
illl
have attached the Addendum and the revised letter to Judge Davis. Jay, this needs to be 
concluded. Alex and I believe that this is as far as we can go. Therefore, please advise me 
whether we have a deal no later than COB tomorrow, Tuesday, October 23, 2007. Thanks, 
Jeff 
 
Original Message 
From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com] 
Sent: Friday, October 19, 2007 4:05 PM 
To: Sloman, Jeff (USAFLS) 
Subject: Re: 
Jeff - 
I have reviewed your proposed language and wanted to raise a few areas of concern. 
First, I am not sure why we are not just asking Judge Davis to represent these women. If he 
is available, that would save us a whole additional layer of process. 
I had thought that 
was initially the idea. I am not sure why you seem to be moving in another direction. 
I also cannot understand why the draft affirmatively requests that J Davis select a lawyer 
whose firm is sizeable enough to litigate multiple trials simultaneously. That seems to be 
ir:
• ectly at odds with the purpose of the agreement, which is to facilitate out of court 
tlements. 
Indeed, to the extent any woman were to elect to bring an action against Mr. 
Epstein, she would not only be free to select any lawyer of her choice, but would be 
restricted from using the lawyer representative in this capacity due to the conflicts of 
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. interests that would cause. 
This part of your proposed language is of signficiant concern 
to me. 
Your letter also indicates the 15Ok statutory limit without reference to the pre-existing 
Illi
OG limit. To be sure, any of the women are free to seek whatever settlement they want, but 
ven the question that exists about the statutory amount, the letter should not state 
-finitely that it will be 15Ok. 
In addition, you have omitted a few important items from your proposal. Given that Judge 
Davis or any other potential attorney representative should understand the scope of the work, 
the language should make clear that there may be discovery to test the claims of alleged 
"victims." 
Finally, I think it is important that the attorney representative be told clearly that Mr. 
Epstein has agreed to pay the lawyer's hourly rate only for the time he or she spends working 
to effectuate settlements for the identified women. 
Jay 
 
 Original Message  
From: "Sloman, Jeff (USAFLS)" [Jeff.Sloman@usdoj.gov] 
Sent: 10/17/2007 01:58 PM AST 
To: Jay Lefkowitz 
Subject: RE: 
«071015 Special Master Letter2.wpd» Jay, 
o
re's our proposed letter to the special master. 
Jeff 
 
Original Message 
From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com] 
Sent: Tuesday, October 16, 2007 9:26 AM 
To: Sloman, Jeff (USAFLS) 
Subject: 
Jeff - is there a time today we can speak? 
How about 430 pm? 
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2 
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