📄 Extracted Text (11,167 words)
'A osta AlexkUSAFLS\' To
cc
09/21!2007 11:49 AM
bcc
Subject Re: Cal today
I am happy to talk.
My caveat is that in the middle of negotiations, u try
to avoidundermining my staff by allowing
"interlocutorty. appeals so to speak so I'd want
on the call
I'll have her set something up.
Alex
Sent from my BlackBerry Wireless Handheld
ri inal Mes
EFTA00213534
6666•
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 4 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 t9 postmasterekirkland.com,
and
destroy this communication and all copies thereof,
including all attachments.
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To
CC
bcc
Subject Re: Jeffrey Epstein - confidential
1.s.cinesSage-bas been Teb
NSW IL . '
Apologies - a. Call on our side.
Jay will get back to you.
Sent from my BlackBerry Wireless Handheld
Original Message
From: USAFLS
To:
Sent: Sun Sep 23 2007
Subject: Re: Jeffrey Epstein - confidential
Can we do a cone call?
Sent from my BlackBerry Wireless Handheld
Original Message
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"Acosta. Alex To
V(USAFLS1)"
A LA t /II II
cc
09/23/2007 04:33 bcc
PM
Subject Re:
Jay -
I do not mean to be difficult, but our negotiations
must take place with the AUSAs assigned to the case.
and Allilhave discussed this matter at length
with me and several others in the office several
times, inclduing today. They have discretion to
proceed as they believe just and appropriate.
I will be out of pocket much of monday on travel. I
know that you and others will be here and wan
sure that my absence do not cause any delays.
ancipliphave authority to proceed as they, in their
professional opinion, consider best.
Alex.
Sent from my BlackBerry Wireless Handheld
Original Message
From: Jay Lefkowitz
To: Acosta, Alex (USAFLS)
Sent: Sun Sep 23 14:11:57 2007
EFTA00213542
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 [email protected],
and
destroy this communication and all copies thereof,
including all attachments.
#************** ***** **********************************
**IV**
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Acosta,Alex To
cc
bcc
10/11/2007 12:20 Subject Re:
PM
ffrotiveraS
- ,
I'm speaking to the PB bar at noon, but promised to
attend their morning session from 9 to 10 30.
7, 7 30 or even 8 am if that is better should give us
plenty of time. The convention center is 5 moin
away. So I'm not leaving the hotel until 8 45.
Pick whatever is most convenient for you.
Alex
Sent from my BlackBerry Wireless Handheld
Original Messag
From: Jay Lefkowitz
To: Acosta, Alex (USAFLS)
Sent: Thu Oct 11 11:34:5
a
******************************************************
*****
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 [email protected],
and
destroy this communication and all copies thereof,
including all attachments.
********* ******** *A* ***** ******* ***** ***** ******** ****
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'Acosta. Alex To
moo
cc
bcc
10/11/2007 02:31 Subject Fw WPB Marriott 1001 Okeediobee Blvd. West Pall
PM Beach, FL 33401
Jay - see you at 7. Address is below. Alex.
Sent from my BlackBerry Wireless Handheld
0 riinal
1 l.
.5essa
From:
<ACastilloOlusa.doj.gov>
To: Acosta, Alex (USAFLS)
Sent: Thu Oct 11 12:49:09 2007
Subject: WPB Marriott 1001 Okeechobee Blvd. West Palm
Beach, FL 33401
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ACOSTA
ACOSTA
EFTA00213549
"Acosta. Alex To "Jay Lefkowitz"
USAFLS
cc
bcc
10118120071229 Subject RE:Follow up
PM
Igetralt
ne
teetcr,
Jeff -- Can you see any issues with this? If not,
please confirm with
Jay.
Original Message
Sent: Thursday, October
To: Acosta, Alex (USAFLS)
18,
From: Jay Lefkowitz (mailto
Subject: Follow up
a
*ex**
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 [email protected],
and
destroy this communication and all copies thereof,
including all attachments.
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"Acosta, Alex To
cc
bcc
11/192007 Subject Re: important
02:25 PM
Ak: r%hr trt? st-40
Wier:StMe
glAt-aiTAWVAlegeMt 7401-.
Jay -- the 2pm is outside the office. Won't be back
until about 3. How anout then?
Sent from my BlackBerry Wireless Handheld
Original Messag
From: Jay Lefkowitz <
To: Acosta, Alex (USAFLS)
Sent: Mon Nov 19 11:59:25 2007
Subject: Re: important
r •
"Acosta, Alex (USAFLS)"
11/19/2007 10:46 AM
To
CC
Subject
Re: important
Jay -
I'm around mid afternoon tuesday (have a very early
dinner) and early wed (have an appt outside the office
from 11 30 to 2).
EFTA00213552
Should I bring Jeff (if there's business to talk, he
is handling epsteiny?
Alex.
Sent from my BlackBerry Wireless Handheld
Original Message
From: Jay Lefkowitz
To: Acosta, Alex (USAll
Sent: Mon Nov 19 09:31:12 2007
Subject: important
IIIIIIIII************** ***** * ***** ** ********** *********
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 [email protected],
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
EFTA00213553
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 postmasterokirkland.com,
and
destroy this communication and all copies thereof,
including all attachments.
EFTA00213554
.
EFTA00213555
"Acosta, Alex To
USAFLS*
cc
bcc
11/20•20070151UPM Subject Re:
Yes. See you then.
Sent from my BlackBerry Wireless Handheld
Original Message
From: Jay Lefkowitz
To: Acosta, Alex (USAFLS)
Sent: Tue Nov 20 15:39:34 2007
MIN
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 6 Ellis LLP or Kirkland & Ellis Inteinational
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 [email protected],
and
destroy this communication and all copies thereof,
including all attachments.
********************** ***** #.4.* ***** ***************.rn
*****
•
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"Acosta. Alex To "Jay Lefkowitz"
cc
bcc
11121@00711:44 AM &b3 a RE:
cr4-
7A -r irateires„ Ybelied
s' ;Oa-.
I'm on my way to a mtg outside the office. Unlikely
to be before 3pm.
That said, Jeff is around if you want to talk with him
re the 2255.
Original Message
From: Jay Lefkowitz [mailto:
Sent: Wednesday, November 21, 2007 11:38 AM
To: Acosta, Alex (USAFLS)
Subject:
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 i 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 [email protected],
and
destroy this communication and all copies thereof,
including all attachments.
****************************1.04.**********************4
EFTA00213558
"Acosta, Alex To
U AFLS'
cc
bcc
12/20/2007 02:19 Subject Re: Important
PM
If you do prefer to talk, 10 to noon, or 2 to 3 would
work.
Sent from my BlackBerry Wireless Handheld
Original Message
From: Acosta, Alex (USAFLS)
To:
Sloman, Jeff (USAFLS)
Sent: Thu Dec 20 13:46:25 2007
Subject: Re: Important
Sure. Not a problem. We can also talk by phone if
that's easier.
Sent from my BlackBerry Wireless Handheld
Original Messaiit
From: Jay Lefkowitz
To: Acosta, Alex (USAFIS)
Sent: Thu Dec 20 13:37:33 2007
Subject: Important
=Sr
•
********* ***** ************* ***** ***** *********** * *****
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 add . 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
EFTA00213559
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.
leilr********************* ******* ***** *********
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EFTA00213561
"Acosta, Alex To
(USAFLS)"
cc
bcc
12127200701:32 Subject Re:
PM
Not a probelm. We can talk later in the week or
weekend if its easier.
Sent from my BlackBerry Wireless Handheld
Original Message
From: Jay Lefkowitz
To: Acosta, Alex (USAFLS)
Cc: Sloman, Jeff (USAFLS);
(USAFLS)
Sent: Thu Dec 27 12:21:50 2007
Subject: Re:
•
Original Message
From: "Acosta, Alex (USAFLS)"
Sent: 12/27/2007 11:37 AM EST
To: Jay Lefkowitz
Cc: "Sloman, Jeff (USAFLS)"
Subject: RE:
Jay -- I just reviewed the letter. I agree that we
should talk. Can
you give me some times that work on your end, and
we'll try to set
something up?
Original Message
From: Jay Lefkowitz (mailt
Sent: Wednesday, December :
To: Acosta, Alex (USAFLS)
Subject:
EFTA00213562
4
w
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 [email protected],
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 6 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 [email protected],
and
destroy this communication and all copies thereof,
including all attachments.
******************************* ***** * *****************
EFTA00213563
EFTA00213564
"Acosta, Alex To ,"Sloman, Jeff(USAFLS)"
(USAFLS)"
(USAFLS
cc
12/28/2007 02:16 bcc
PM
Subject Re:
Jay - I don't know whet will happen at this point.
May be best to wait until after we speak monday
morning. Alex
Sent from my BlackBerry Wireless Handheld
Original Massa
From: Jay Lefkowitz
To: Acosta, Alex (US
Sent: Fri Dec 28 13:52:31 2007
Subject: Re:
Original Message
From: "Acosta, Alex (USAFLS)"
Sent: 12/28/2007 01:35 PM EST
To: Jay Lefkowitz
Subject: Re:
Jay _
I want to respect your sabbath. Let's just talk
monday morning. Would 11 am work?
Sent from my BlackBerry Wireless Handheld
Original Messa
From: Jay Lefkowitz
To: Acosta, Alex (USAFLS)
Sent: Fri Dec 28 12:51:13 2007
EFTA00213565
******************************************************
*****
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 [email protected],
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 postmasterOkirkland.com,
and
destroy this communication and all copies thereof,
including all attachments.
* * *
EFTA00213566
1
EFTA00213567
'Acosta, Alex To "Jay Lefkowitt
cc
bcc
1V31/200711:05 Subject RE:
AM
Will do. 3 min.
Original Message
From: Jay Lefkowitz [mailto:
Sent: Monday, December 31, 2111.1.
To: Acosta, Alex (USAFLS)
Subject:
1111111111111111111111r
IMO
**66*
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 6 Ellis LLP or Kirkland 6 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 [email protected],
and
destroy this communication and all copies thereof,
including all attachments.
EFTA00213568
1
1
1
I
EFTA00213569
Jay LeficowItz/New To "Acosta, Alex (USAFLS)" <
York/Kirkland-Ellis
01/02/2008 03:44 PM ccaiS FLS)"<
USAFL
"Roman, Jeff (USAFLS)"
bcc
Subject REll
Sraffill11111
INS
"Acosta, Alex (USAFLS)"
'Acosta, Alex
To 'Acosta, Alex SAFLS"
0 uekomte
cc
01/02/2008 an,
03:36 PM Subject RE:
Actually, the morning is bad. How about 3pm or 4pm?
From: Acosta, Alex (USAFLS)
Sent: Wednesday, January 02, 2008 3:33 PM
To: Jay Lefkowitz
Cc: Castillo, Annette (USAFLS); Sloman, Jeff (USAFLS)
Subject: RE:
11 am?
From: Jay Lefkowitz [mailto
Sent: Wednesday, January 02, 2008 2:46 PM
To: Acosta, Alex (USAFLS)
Subject:
***M 4:+illr***************4t*it************* *****
**it**
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
EFTA00213570
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 postmasterOkirkland.com,
and
destroy this communication and all copies thereof,
including all attachments.
******************************************************
ikOsi•
EFTA00213571
EFTA00213572
To -Jay Lekowite
cc
01107/2O08 11:28 AM
tom
Subject RE:
Not a problem.
Original Message
From: Jay Lefkowitz (mailto:
Sent: Monday, January 07, 20
To: Acosta, Alex (USAFLS)
Subject:
****.
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 [email protected],
and
destroy this communication and all copies thereof,
including all attachments.
EFTA00213573
"Acosta Alex USAFLS To "JayLeflmite
cc
01/07200811/8AM
bcc
Subject RE:
Not a problem.
Original Message
From: Jay Lefkowitz
Sent: Monday, January 07, 2
To: Acosta, Alex (USAFLS)
Subject:
*****
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 [email protected],
and
destroy this communication and all copies thereof,
including all attachments.
* • * * *
EFTA00213574
.
EFTA00213575
To -Jay Lefkowite
cc
01/07/2008 03:41 PM
bcc
Subject RE:
Can you pis provide to Jay the conf. table speaker phone
#., for Jeff and I.
From: Jay Lefkowit [mailto
Sent: Wednesday, January 02, 2008 3:44 PM
To: Acosta, Alec (USAFLS)
Co Acosta, Alex (USAFLS); USAFLS); Sloman, Jeff
(USAFLS); Kristin Andersen
Subject: RE:
"Acosta, Alex (LISAFLS)"
To-Acosta, Alex USAFLS -Jay
Lefk
°Mesta°, Annette
01/02/2008 03:36 PM 'Stamen, Jeff (USAFIST
SubjecRE:
Actually, the morning is bad. How about 3pm or 4pm?
From: Arncta, Alex (USAFLS)
Sent: Wednesday, January 02, 2008 3:33 PM
To
USAFLS); Sloman, Jeff (USAFLS)
Subject: RE:
11 am?
From: Jay Lefkowitz [iflailt0ji a
Sent: Wednesday, January ,
To: Acosta, Alex (USAFLS)
Subject:
EFTA00213576
***************************************** ****** ***
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 add . 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 [email protected],
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 [email protected],
and
destroy this communication and all copies thereof,
including all attachments.
EFTA00213577
I
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i
EFTA00213578
To ■
cc
boc
Subject Re:
Jay -
Thanks for the email. I sent it along to the trial
team.
I'm also looking forward to when this is over, so we
can talk about non-work matters.
Hope all is well with you and the family.
Alex.
Sent from my BlackBerry Wireless Handheld
Original Nesse
From: Jay Lefkowitz
To: Acosta, Alex (USA
Sent: Wed Jan 30 13:07:11 2008
***a*
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only
for
EFTA00213579
the use of the addressee. It is the property of
Kirkland S Ellis LLP or Kirkland & Ellis international
LLP.
Unauthorized use, disclOsure or copying of this
communication or any part thereof is strictly
prohibited
and nay be unlawful. If you have received this
communication in error, please notify us immediately
by
return e-mail or by e-mail to [email protected],
and
destroy this communication and all copies thereof,
including all attachments.
N.
EFTA00213580
•
•
EFTA00213581
SLOMAN SI OMAN,
EFTA00213582
"Sloman, Jeff To "Jay Lefkowitz"
USAFLS
cc
bcc
10/12/2007 Subject RE: Addendum
1228 PM
Try
From: Jay Lefkowitz
Sent Friday, October 12, 20 :
To: Sloman, Jeff (USAFLS)
Subject Re: Addendum
--- Original Message ---
From: "Sloman, Jeff (USAFLS)"
Sent: 10/12/2007 09:48 AM AST
To: Jay Lefkowitz
, •
SAF
Jay,
I just got off the phone with Alex. Here is the revised paragraph 1.
Thanks, Jeff
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 victims. If the United States elects to assign
this responsibility to an independent third-party, the United States
retains the right to request that the independent third-party consult
with the United States after the preliminary selection but prior to
the final designation of the attorney representative.
From: Jay Lefkowitz
Sent Thursday, October 11, .
EFTA00213583
To: Sloman, Jeff (USAFLS)
Subject: Re: Addendum
Original Message —
From: "Sloman, Jeff (USAFLS)"
Sent 10/11/2007 12:17 PM AST
To: Jay Letkonitz
Cc "Acosta, Alex (USAF1S)"
Subject Addendum
Jay,
Pursuant to our conversation. Thanks,
Jeff
IN RE:
INVESTIGATION OF
JEFFREY EPSTEIN
EFTA00213584
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:
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 victims. If the United Slates elects to assign
this responsibility to an independent third-party, the United States
retains the right to request that the independent third-party also
consult with the United States.
2. Pursuant to paragraph 7, Epstein has agreed to pay the fees of
the attorney representative. 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, the 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 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.
By signing this Addendum, Epstein asserts and
certifies that the above has been read and explained to
hint Epstein hereby states that he understands the
clarifications to the Non-Prosecution Agreement and
agrees to comply with them.
R. ALEXANDER
ACOSTA
UNITED STATES
EFTA00213585
ATTORNEY
Dated: By:
A. MARIE VILLAFARA
ASSISTANT U.S.
ATTORNEY
Dated:
JEFFREY EPSTEIN
Dated:
GERALD LEFCOURT,
ESQ.
COUNSEL TO JEFFREY
EPSTEIN
Dated:
LILLY ANN SANCIIEZ,
ESQ.
ATTORNEY FOR
JEFFREY EPSTEIN
****“.*****.***** *********** ***************•**********
*****
EFTA00213586
'The intormation 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 [email protected], 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 [email protected], and
destroy this communication and all copies thereof,
including all attachments.
*4***
EFTA00213587
R
EFTA00213588
To 'Jay LefKowitz" <
CC
10/16/2007 12:39 PM
bcc
Subject RE:
4:30 is fine. we'll call you.
Original Message
From: Jay Lefkowitz (mailto
Sent: Tuesday, October 16, 2007 9:26 AM
To: Sloman, Jeff (USAFLS)
Subject:
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 [email protected],
and
destroy this communication and all copies thereof,
including all attachments.
**************** ***** **** ***** * ***** * ******** ** ******* .
EFTA00213589
EFTA00213590
To "Jay Lefkowite
cc
10/16/2007 04:00 PM
bcc
Subject RE: Confidential - for settlement purpose'
Jay,
The below is exactly the same as yours, except for
deletion of "Other than the joint written submission,
neither the United States nor Epstein's counsel shall
communicate with the independent third party nor shall
the United States communicate with the attorney
representative selected by him" in your 1(a).
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 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.
Jeff
Original Message
EFTA00213591
From: Jay Lefkowitz (mailto
Sent: Monday, October 15, 2007 10:53 AM
To: Sloman, Jeff (USAFLS)
Subject: Confidential - for settlement purposes only
EFTA00213592
EFTA00213593
.
.
p
.
EFTA00213594
"Sloman, Jeff To "Jay Letkowite
cc
bcc
10/17/2007 01:58 PM Subject RE:
kitt0 Wroit °Raw.,y r.
cOrsdeddeg
<<071015 Special Master Letter2.wpd>> Jay,
Here's our proposed letter to the special master.
Jeff
Original Message
From: Jay Lefkowitz (mailto
Sent: Tuesday, October 16,
To: Sloman, Jeff (OWLS)
Subject:
*****
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 postmaster9kirkland.com,
and
destroy this communication and all copies thereof,
including all attachments.
********** ****** ************** ***** * ***** *************
071015 Special Master Letter2.wpd
EFTA00213595
S. Department of Justice
United States Attorney
Southern District of Florida
500 South Australian Ave., Suite 400
West Palm Beach FL 33401
(561) 8204711
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
contains, inter alit; the following terms:
7(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
EFTA00213596
The lion. Edward B. Davis (Ret.)
October _ 2007
Page 2 of 4
suggested by the independent third-party prior to the final designation of the attorney
representative.
7(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 7(c), infra.
7(c). Pursuant to additional paragraph 7(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.
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
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.
EFTA00213597
The Hon. Edward B. Davis (Ret.)
October 2007
Page 3 of 4
The most recent version of the statute referenced above, 18 U.S.C. § 2255,
provides that:
My 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 suc 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. Employment with a firm large enough to handle the possibility of at least a
dozen trials at the same time.
5. Experience litigating against large law firms and high profile attorneys.
6. Sensitivity to the nature of the suit and the victims' interest in maintaining
their privacy.
7. Experience litigating in federal court in the Southern District of Florida.
EFTA00213598
The Hon. Edward B. Davis (Rot.)
October 2007
Page 4 of 4
8. 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.
9. 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.
Sincerely,
R. Alexander Acosta
United States Attorney
By:
Jeffrey Sloman
First Assistant United States Attorney
cc: AUSI5
EFTA00213599
.
EFTA00213600
"Sloman, Jeff To 'Jay LefkowIte
cc "Acosta, Alex(USAFLS)
bcc
10/18/2007 Subject RE:
ℹ️ Document Details
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9fcf29805df27cf3e114419acf888f18f8cb0df9783f33812de487f32be2fda1
Bates Number
EFTA00213534
Dataset
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Document Type
document
Pages
108