EFTA00213740

. 
EFTA00213740

(uSAFIS • 
10/03/2007 03:38 PM 
To "Jay Lefkowite •c==. 
cc 
bcc 
Subject RE: 
That is fine. I'm sorry I didn't get your e-mail 
sooner. Since I am out of the office, the best way to 
reach me is on my cell, or you can send an e-mail 
ssissierge) to 
Tomorrow I am available early in the morning (7:00 to 
7:45), or at 8:30, or at 5:00, or after 6:45. 
Thanks. 
Assistant U.S. Attorney 
Fax 
 0 
Mess 
 
Sent: 10/03/2007 03:15 PM AST 
To: Jay Lefkowitz 
Subject: RE: 
inal Messa 
Hi Jay -- This afternoon is fine. Here is the memo 
that I put together. Just let me know where I should 
call you at 4:00. Thanks. 
S. Attorney 
EFTA00213741

Fax 
- 
-Ori inal Message 
***** 
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. 
* 
* • 
***** 
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. 
EFTA00213742

EFTA00213743

10/03/2007 04:24 PM 
To "Jay Lefkowitz" 
CO 
bce 
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>> 
Assistant U.S. Attorney 
Fax 
«< Attachment 'PROPOSED Letter to Special Master.ndf has been 
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EFTA00213744

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. 
EFTA00213745

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 bona public° 
matter. Please do not hesitate to contact us if you need any further information. 
EFTA00213746

.• 
EFTA00213747

10/33/2007 07:31 PM 
To "Jay Lelkowilt 
cc 
bcc 
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. 
311
11Clea
10/03/2007 04:24 PM 
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» 
Assistant O.S. Attorney 
Fax 
EFTA00213748

EFTA00213749

10/05/2007 07:48 AM 
To 
Lefkowitz' 
cc 
bcc 
Subject RE: Proposed Letter to Special Master 
,Ringreq 
1114 
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 
providing, I propose Bert Ocariz, 
Podhurst Orseck, Stuart Grossman, 
Walter Cobath. 
that we will be 
Katherine Ezell at 
Ed Rogers, and 
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 
and let me know which of those 
times works best or you. 
Thank you. 
11.11111C 
111111111111Pir 
10/03/2007 04:24 PM 
To 
"Jay Lefkowitz" 
EFTA00213750

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. 
c<PROPOSED Letter to Special Master.pdf>> 
Assistant U.S. Attorney 
Fax 
EFTA00213751

EFTA00213752

To 
cc 
bcc 
'Jay Lorkowite 
10/05/2007 04:47 PM 
Subject RE: Proposed LettertoSpectal Master 
IP VW 
1. 
• „a , 
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Jay -- I will call in at 5:30. 
10/05/2007 07:48 AM 
To 
"Jay Lefkowitz" < 
cc 
Subject 
RE: Proposed Letter to Special Master 
EFTA00213753

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 6:00. Please call me on 
my cell 
•
l 
and let me know which of those 
times works best for you. 
Thank you. 
111011111
-
"Villafana, Ann Marie C. (USAFLS)" 
<Ann.Marie.C.VillafanaElusdoj.gov> 
10/03/2007 04:24 PM 
To 
"Jay Lefkowitz" <JLefkowitz@kirkland.com> 
cc 
Subject 
Proposed Letter to Special Master 
EFTA00213754

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» 
Assistant U.S. Attorney 
Fax 
10/03/2007 04:24 PM 
To 
"Jay Lefkowitz" 
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>> 
Assistant U.S. Attorney 
Fax 
10/03/2007 03:18 PM 
To 
"Jay Lefkowitz" 
cc 
Subject 
Memo in PDF format 
EFTA00213755

Hi Jay - In case you can't open the other version, 
here it is in pdf. 
«special Master Proposal.pdf» 
Assistant U.S. Attorney 
Fax 
EFTA00213756

10/05/2007 05:42 PM 
Jay - I will call you at 5:30. 
Assistant U.S. Attorney 
Oki 
10/092007 07:48 AM 
To "Jay Letkowite 
cc 
bcc 
Subject RE: Proposed Letter to Special Master 
Teisy loolkowte" 
Co 
SubjettRE: Proposed Letter to Special 
Master 
EFTA00213757

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 
and let me know which of those 
times works best for you. 
Thank you. 
10/03/2007 04:24 PM 
To 
"Jay Lefkowitz" < 
cc 
Subject 
Proposed Letter to Special Master 
EFTA00213758

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>> 
Assistant U.S. Attorney 
Fax 
To"Jay Lefkowite 
10/03/2007 04:24 PM 
ct 
SubjectProposed 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 Masterpdf» 
Assistant U.S. Attorney 
Fax 
10/03/2007 03:18 PM 
To"Jay Lefkowitz" 
cc 
SublecMemo in PDF format 
EFTA00213759