EFTA00208970

• e information contained in this communication is 
Jnfidential, 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. 
• 
• 
3 
RFP MIA 000322 
EFTA00209010

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Palm Beath, FL 33401 
(561) 820-8711 
Facsimile: (561) 820-8777 
October -, 2007
DELIVERY BY FACSIMILE 
The Hon. Edward B. Davis (Ret.) 
Akerman Senterfitt 
One Southeast Third Avenue, 25th Floor 
Miami, Florida 33131 
Re: 
Service as a Special Master 
Dear Judge Davis: 
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 contaithefer 
alga, 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. 
RFP MIA 000323 
EFTA00209011

• 
• 
• 
THE HON. EDWARD B. DAVIS (RET.) 
OCTOBER 
2007 
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 
RFP MIA 000324 
EFTA00209012

• 
• 
THE HON. EDWARD B. DAVIS (RET.) 
OCTOBER 
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 
victims as defined by 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 (the victims' 
current ages are between 16 and 24). 
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. 
RFP MIA 000325 
EFTA00209013

• 
• 
• 
Tiff: HON. EDWARD B. DAVIS (RET.) 
OCTOBER 
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. 
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 I can provide you with any further information, please do not hesitate to contact me. 
Thank you again for your assistance with this matter. 
cc: 
AUSA A. Marie Villafaha 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
Jeffrey Sloman 
First Assistant United States Attorney 
RFP MIA 000326 
EFTA00209014

• 
• 
• 
IN RE: 
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: 
A. 
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. 
B. 
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. 
C. 
Pursuant to additional paragraph A, 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. 
RFP MIA 000327 
EFTA00209015

• 
• 
• 
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 Non-
Prosecution Agreement and agrees to comply with them. 
Dated: 
 
By: 
Dated: 
Dated: 
Dated: 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
A. MARIE VILLAFAICIA 
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
RFP MIA 000328 
EFTA00209016

• 
Villafana, Ann Marie C. (USAFLS) 
From: 
Jay Lefkowitz pLefkowitz@kirkland.comj 
al ,nt: 
Monday, October 22,2007 5:10 PM 
Sloman, Jeff (USAFLS) 
Uc: 
Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS) 
Subject: 
Re: Epstein 
Attachments: 
071015 Special Master Letter3.wpd; Addendum.wpd 
Jeff — I will review these materials this evening and be in touch with you tomorrow with the expectation of wrapping this up 
by the end of the day. One question I have, however, is why you say that Judge Davis is a non-starter. I understood that 
he was ready, willing and able to serve as the attorney representative. If you have had conversations with him and that is 
not the case, please let me know. 
I will go over the other issues you raise in your email and wil look forward to speaking tomorrow. 
Thanks — Jay 
"Woman. Jeff MAFIA" f•Jeff.SlomaneusOolipoir• 
10/22/2007 04:40 PM 
a 
To 'fly Leawake <Jtelliositz010itlan0.cans 
cc 'Acosta. Nex (WARS)" calex.AcceteOumloi poi>. Viestane Mn MM. C. 
(USAFLST <Annktstis.C.VIllelansaustill4-90n 
SotOM Epstein 
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." 
I 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 
I 
RFP MIA 000329 
EFTA00209017

From: Jay Lefkowitz (mailto:JLefkowitz@kirkland.com) 
Sent: Friday, October 19, 2007 4:05 PM 
To: Sloman, Jeff (USAFLS) 
Subject: Re: 
• 
ff - 
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 directly at odds with the purpose of the agreement, which is to facilitate 
out of court settlements. 
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 interests that would cause. 
This part of your proposed language is 
of signficiant concern to me. 
Your letter also indicates the 150k statutory limit without reference to the pre-
existing 50G limit. To be sure, any of the women are free to seek whatever settlement 
they want, but given the question that exists about the statutory amount, the letter 
should not state definitely that it will be 150k. 
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." 
• nally, I think it is important that the attorney representative be told clearly that 
.ir. 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, 
Here's our proposed letter to the special master. 
Jeff 
 
Original Message 
From: Jay Lefkowitz (mailto:JLefkowitzekirkland.com) 
Sent: Tuesday, October 16, 2007 9:26 AM 
To: Sloman, Jeff (USAFLS) 
Subject: 
Jeff - is there a time today we can speak? 
2 
RFP MIA 000330 
EFTA00209018

How about 430 pm? 
The information contained in this communication is 
•
•nfidential, may be attorney-client privileged, may 
nstitute inside information, and is intended only for 
,ne 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 postmasterekirkland.com, and 
destroy this communication and all copies thereof, 
including all attachments. 
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 postmastertikirkland.com, and 
destroy this communication and all copies thereof, 
including all attachments. 
• 
3 
RFP MIA nrin'431 
EFTA00209019

Villafana, Ann Marie C. (USAFLS) 
From: 
Sloman, Jeff (USAFLS) 
0 
nt: 
Wednesday, October 24, 2007 3:45 PM 
Jay Lefkowitz 
4;c: 
Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) 
Subject: 
Epstein - Addendum and Letter to Judge Davis 
Addendum.wpd 071015 Special 
Master Letter4.... 
Jay, 
Pursuant to our conversation, here is the revised letter and a new addendum. The only change to the addendum is that I 
renumbered the new paragraphs from A,B, and C to 7A, 7B, and 7C. Once you approve, I will contact Judge Davis and 
send him the letter. Please execute the addendum, PDF the executed original to me as soon as possible and Fed Ex the 
original to me thereafter. 
Jeff 
• 
• 
1 
RFP MIA 000332 
EFTA00209020

• 
• 
• 
IN RE: 
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-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 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. 
RFP MIA 000333 
EFTA00209021

• 
• 
• 
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 Non-
Prosecution Agreement and agrees to comply with them. 
Dated: 
 
By: 
Dated: 
Dated: 
Dated: 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
A. MARIE VILLAFA&A 
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
RFP MIA 000334 
EFTA00209022

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
99 N.E. 44 Street 
Miami. FL 33132-211/ 
(305) 961-9299 
Facsimile: (305) 530-6444 
October 
2007 
DELIVERY BY FACSIMILE 
The Hon. Edward B. Davis (Ret.) 
Akerman Senterfitt 
One Southeast Third Avenue, 25th Floor 
Miami, Florida 33131 
Re: 
Service as a Special Master 
Dear Judge Davis: 
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 contaiiisier 
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. 
RFP MIA 000335 
EFTA00209023

• 
• 
• 
THE !ION. EDWARD B. DAVIS (RET.) 
OCTOBER 
2007 
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. 
8.1f 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 
RFP MIA 000336 
EFTA00209024

• 
• 
THE HON. EDWARD B. DAVIS (Rat) 
OCTOBER 
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. 
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. 
RFP MIA 000337 
EFTA00209025

• 
• 
• 
ME HON. EDWARD B. DAvis (BET.) 
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. 
cc: 
AUSA A. Marie Villafana 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
Jeffrey Sloman 
First Assistant United States Attorney 
RFP MIA 000338 
EFTA00209026

Villafana, Ann Marie C. (USAFLS) 
From: 
Sloman, Jeff (USAFLS) 
III
rnt:  
Wednesday, October 24, 2007 5:30 PM 
x 
Jay Lefkowitz 
...;c: 
Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS) 
Subject: 
Epstein - Letter to Judge Davis 
Jay, 
Here is the latest and hopefully final version of the letter to Judge Davis. 
Jeff 
071015 Special 
Master Letter5.... 
• 
• 
1 
RFP MIA 000339 
EFTA00209027

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 3340! 
(56!) 820-871! 
Facsimile: (561) 820-8777 
October -, 2007 
DELIVERY BY FACSIMILE 
The Hon. Edward B. Davis (Ret.) 
Akerman Senterfitt 
One Southeast Third Avenue, 25th Floor 
Miami, Florida 33131 
Re: 
Service as a Special Master 
Dear Judge Davis: 
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 contaitisfer 
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. 
RFP MIA 000340 
EFTA00209028

• 
• 
• 
THE HON. EDWARD B. DAVIS (Rer.) 
OCTOBER 
2007 
PAGE 2 or 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 Epstcin'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. 
8.1f 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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