From:" (USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To: "Acosta, Alex (USAFLS)" <
Subject: FW: Epstein
Date: Tue, 16 Oct 2007 21:27:55 +0000
Importance: Normal
fyi
From: (USAFLS)
Sent: Tuesda October 16, 2007 5:16 PM
To: (USAFLS)
Subject: RE: Epstein
Hi I.— This looks perfect. Thank you for all of the time that you spent on this.
Assistant U.S. Attorney
Fax 561 820-8777
From: (USAFLS)
Sent: Tuesday, October 16, 2007 3:51 PM
To: . (USAFLS)
Subject: RE: Epstein
Here's our version that we plan to send to Lefkowitz. Alex and I have read your proposed
letter to Judge Davis and other than parts of the last paragraph concerning "consulting with
the victims", it looks good.
1. 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.
2. 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 3, infra.
3. Pursuant to additional paragraph 1, 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
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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.
From: (USAFLS)
Sent: Monda October 15, 2007 9:38 AM
To: (LISAFLS)
Subject: Epstein
Hi M— I have prepared this as a letter from you to Judge Davis. I am going to call to see if we have
nailed down the final number of victims so that you can include the information in the letter. You can get me on
my cell phone.
Thank you!
cc File: 071015 Special Master Letter.wpd »
Assistant U.S. Attorney
Fax 561 820-8777
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