Jeff Sloman
Robert Senior
A Marie Villafana
Dear Counsel
We received notice this morning that the Podhurst firm has filed a civil
Complaint seeking over $2,000,000 in addition to the $526,000 they have
already been paid by Jeffrey Epstein for their work as attorney
representatives. As we communicated to you in prior correspondence dated
and (and during our February 2010 meeting with you) there
exists significant differences between Mr. Epstein and the attorney-
representative over what portions of the latter's bills were within Mr.
Epstein's obligations under the NPA. Mr. Epstein has been attempting to
resolve the outstanding invoices through efforts to review with the attorney
representative the particulars of his charges, through settlement discussions
with the attorney representative and through his signing a Special Masters
Agreement which would allow a neutral third party to make a binding
resolution as to what portions of the invoices at issue are reasonable, non-
duplicative, and within Mr. Epstein's NPA-obligations. It was only several
days ago that Mr. Epstein even received an up to date invoice seeking
payment for legal work dating back to .
We regret these efforts did not resolve the matter and that the Podhurst
firm elected instead to litigate. Mr. Epstein has today placed the entire
disputed amount of $2,000,000 in a trust account (detail) pending the results
of the litigation. Mr. Epstein has always agreed that he is entirely
responsible for any settlement-related fees that are not excessive and will
take no litigation position inconsistent with that understanding.
YT
RB
MGW
EFTA00587591