EFTA00190318

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500S Australian Ave Ste 400 
West Palm Beall, FL 33401 
(361)8204711 
Facsimile• O6O8204777 
August 21, 2008 
DELIVERY BY ELECTRONIC MAIL 
Jay P. Lefkowitz, Esq. 
Kirkland & Ellis liP 
Citigroup Center 
153 East 53rd Street 
New York, New York 10022-4675 
Roy Black, Esq. 
Black Srebnick Kornspan & Stumpf P.A. 
201 S. Biscayne Blvd, Suite 1300 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Jay and Roy: 
Thank you for your response to my earlier letter. The U.S. Attorney's Office shares 
in your desire to implement all of the terms of the Non-Prosecution Agreement. As you are 
aware, the jointly-approved Special Master. Judge Mi. has already selected an attorney 
representative, Robert Josefsberg, who was accepted by both parties. The Office has 
conferred with Mr. Josefsberg, who has agreed to continue in that role. In October 2007, Mr. 
Josefsberg expended time, effort, and funds in preparing to serve as the attorney 
representative, and he will need a written confirmation from you that his future fees and 
expenses will be paid in accordance with the terms of the Non-Prosecution Agreement. 
Please provide me with a copy of that correspondence for my file. 
With that matter settled, I believe that the requirement for a joint written submission 
to the Special Master has been extinguished. Nonetheless, I have no objection to attempting 
to create a joint statement to assist Mr. Josefsberg in serving his duties. Regarding your 
suggestion that we ask Judge 
to "offer the final word on how certain clauses should 
be interpreted and satisfied," I believe that the Agreement speaks for itself. 
EFTA00190378

JAr P. LFIXOWIT7, ESQ. 
Ror BLACK. ESQ. 
AUGUST' 21,2008 
PAGE 2 op 2 
Pursuant to the terms of the Agreement, following Mr. Epstein's sentencing, the U.S. 
Attorney's Office provided Mr. Epstein's counsel with a list of the individuals whom it was 
prepared to name in an indictment as victims of an offense enumerated in 18 U.S.C. § 2255. 
and none of those names will be deleted. By his agreement, Mr. Epstein sought to resolve 
liability for all criminal activity known to the United States as of the lime of his plea and 
sentencing, and he is responsible for damages to all victims of that criminal activity. 
. 
Copies of the victim notifications will continue to be provided to counsel for Mr. 
Epstein. Please let me know whether I should continue to list Mr. Goldberger as the point 
of contact for the civil litigation. Regarding your suggestion on the content of the 
notification letters, I intend to use the same format that was used in the letters previously 
approved by Messrs. Goldberger and Tein, except that I will include the language from the 
September and October agreements. I have enclosed a draft herewith. Because I previously 
provided the victims with incorrect information—albeit with the approval of Mr. Epstein's 
counsel—it is imperative that I correct the error promptly. Accordingly, if you have any 
substantive objections to the letter, please advise me by tomorrow afternoon. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: ad 
. <4
, 62€4:ther
—
A. Marie Villafafta 
Assistant United States Attorney 
cc: 
Karen Atkinson, Chief. Northern Division 
EFTA00190379

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Aw.. Suite 400 
West Palm Beach. FL 3340! 
(36!) 820.87!! 
Facsimile: 060 820-8777 
August 22. 2008 
VIA FACSIMILE A
 U.S. MAIL 
ND
Michael E. Dutko, Esq. 
Bogenschutz & Dutko 
600 S. Andrews Ave, Suite 500 
Fort Lauderdale, FL 33301-2802 
DRAFT 
Re: 
Jeffrey Epstein= 
: AMENDED NOTIFICATION 
OF IDENTIFIED vicrim 
Dear Mr. Dutko: 
By virtue of this letter, the United States Attorney's Office for the SouthernMt 
of Florida asks that you provide the following amended notice to your client, 
Some of the information contained in the July 20,2008 letter to Ms. 
was inaccurate, 
so please advise her of the following changes. 
As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter 
referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 
796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in 
prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
009454AXXXMB and 2008-cf-00938IAXXXMB) and was sentenced to a term of twelve 
months' imprisonment to be followed by an additional six months' imprisonment, followed 
by twelve months of Community Control I, with conditions of community confinement 
imposed by the Court. 
In light of the entry of the guilty plea and sentence, the United States has agreed to 
defer federal prosecution in favor of this state plea and sentence, subject to certain 
conditions, including the following: 
I. 
An independent Special Master was assigned the task of selecting an 
attorney representative to represent the victims in connection with civil 
EFTA00190380

MICIIAEL E. DUTKO, ESO. 
AMENDED Ronne'mot+ OF IDENTIFIED VIC nm 
Aucus-r 22, 2008 
PAGE 2 OF 3 
DRAFT 
litigation between the victims and Mr. Epstein. The Special Master 
selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., a 
highly-respected and experienced attorney. 
Ms. 
is not 
obligated to use Mr. Josefsberg as her civil attorney, but, as explained 
in greater detail below, Mr. Josefsberg's services will be provided at no 
cost to Ms. 
because Mr. Epstein is obligated to pay the costs 
and fees of the attorney-representative. Also, Mr. Epstein and his 
attorneys can only contact Ms. 
via Mr. Josefsberg, assuming 
that she would like Mr. Josefsberg to serve as her attorney. 
2. 
If Ms. 
elects to file suit against Mr. Epstein pursuant to Title 
18, United States Code, Section 2255, Mr. 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 Mr. Epstein 
waives his right to contest liability and also waives his ri t to contest 
damages up to an amount as a eed to between Ms. 
and Mr. 
Epstein, so long as Ms. 
elects to proceed exclusively under 18 
U.S.C. § 2255, and she waives any other claim for damages, whether 
pursuant to state, federal, or common law. Notwithstanding this 
waiver. Epstein's agreement with the United States, his waivers and 
failure to contest liability and such damages in any suit are not to be 
construed as an admission of any criminal or civil liability. 
3. 
As stated above. Mr. 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 ra
ft . Thus, if after consideration of 
potential settlements, Ms. 
and Mr. Josefsberg elect to file a 
contested lawsuit pursuant to 18 U.S.C. § 2255 or she elects to pursue 
any other contested remedy, the 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 
Section 2255 to bear the costs of the attorney representative, shall 
cease. 
Mr. Josefsberg will be contactiniovithin the next week to explain these terms and 
to determine if he may contact Ms. 
directly. If you would like to contact Mr. 
EFTA00190381

MICHAEL E. DUTKO, 
AMENDED NOTIFICATION OF IIXNTIFIFS) VICTIM 
AUGUST 22.2008 
PAGE 3 OF 3 
Josefsberg directly, he can be reached at 305 358-2800. 
If Ms. 
has selected other counsel to represent her, or if she does so in the 
future, and she decides to pursue a claim against Jeffrey Epstein. his attorney, Jack 
Goldberger, asks that he be contacted at Atterbury Goldberger and Weiss, 250 Australian 
Avenue South, Suite 1400, West Palm Beach, FL 33401. 
In addition, a judge has ordered that the United States make available to any 
designated victim (and/or her attorney) a copy of the actual agreement between Mr. Epstein 
and the United States, so long as the victim (and/or her attorn 
reviews, signs, and agrees 
to be bound by a Protective Order entered by the Court. If Ms. 
would like to review 
the Agreement, please let me know, and I will forward a copy of the Protective Order for her 
signature. 
As I stated in my earlier notification, please understand that neither the U.S. 
Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist 
in civil litigation, but we again thank you and your client for all of her assistance during the 
course of this investigation. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
DRAFT 
By: 
A. MARIE VILLAFANA 
ASSISTANT U.S. ATTORNEY 
cc: 
Robert Josefsberg, Esq. 
Jack Goldberger, Esq. 
EFTA00190382

Case 9:08-cv-80736-KAM 
Document 26 
Entered on FLSD Docket 08/21/2008 
Page 1 of 2 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
NO. 08-80736-CIV-MARRABOHNSON 
IN RE: JANE DOES I AND 2, 
Petitioners. 
ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER 
THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the 
production of the Non-Prosecution Agreement between the United States Attorney's Office for the 
Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the 
Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the 
Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement, 
including any modifications and addenda thereto, in accordance with the following procedures: 
(a) 
The USAO shall produce a copy of the Non-Prosecution Agreement, 
including any modifications and addenda thereto (collectively referred to as the "Agreement"), to 
the attorneys for Petitioners. 
(b) 
Petitioners and their attorneys shall not disclose the Agreement or its terms 
to any third party absent further court order, following notice to and an opportunity for Epstein's 
counsel to be heard. 
(c) 
Before counsel for petitioners show the Agreement to their clients or discuss 
the specific terms with them, they must provide a copy of this Order to petitioners, who must review 
and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for 
petitioners must promptly provide a copy of that acknowledgment to the USAO. 
(d) 
If any individuals who have been identified by the USAO as victims of 
EFTA00190383

Case 9:08-cv-80736-KAM 
Document 26 
Entered on FLSD Docket 08/21/2008 
Page 2 of 2 
Epstein and/or any attomey(s) for those individuals request the opportunity to review the 
Agreement, then the USAO shall produce the Agreement to those individuals, so long as those 
individuals also agree that they shall not disclose the Agreement or its terms to any third party 
absent further court order, following notice to and an opportunity for Epstein's counsel to be heard 
(e) 
Prior to producing the documents to any other individuals who have been 
identified by the USAO as victims of Epstein and/or any attomey(s) for those individuals, a copy 
of this Order must be provided to said individuals, who must review and acknowledge their receipt 
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly 
provide a copy of that acknowledgment to the USAO. 
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, 
this 21" day of August, 2008. 
KENNETH A. MARRA 
UNITED STATES DISTRICT JUDGE 
Copies furnished to: all counsel of record 
By signing below, I certify that I have reviewed and agree to be bound by the terms of this 
Order. 
Dated: 
Signed by:  
Printed Name: 
2 
EFTA00190384

KIRKLAND & ELLIS LLP 
N•10 XOINnp PANINO:11 ISM 
Cilirup Conies 
153 East 53ifo Strom . 
Now York. Nnw York 160274611 
Joy P I olkowitz. P C 
Ir
To 
Sot [Sealy 
413.11./M 
pent 
zekilklaiml Co..' 
VIA FACSIMILE (561) 820-8777 
446.4000 
wow kirkkind can 
August 22.2008 
A. Marie Villafana 
I intent States Attorney's Office 
Southern District of Florida 
300 South Australian Avenue. Suite 400 
West Palm Beach. Florida 33401 
Affiry Epsitin 
Dear Mark: 
Facrarnoe 
r: 
44S 4900 
I write this letter to correct certain misstatements made in win. letter dated August 21. 
2008. and the accompanying draft notification. 
First, you state that "Mr. Josefsbcrg expended time, effort and funds in preparing to serve 
as attorney representative in October of 2007.- Neither I. nor any other attorney un Mr. 
Epstein's defense team. was notified of this work by Mr. Joselsherg. 
Second. in the victim notification letter, no judge "has ordered that the United States" 
make available a copy of the Non-Prosecution. Agreement. Section (d) of the Order to Compel 
Production and Protective Order provides that if any of the alleged - victims- andior their 
altonieys "request the opportunity to review the Agreement." the MAO shall comply with tlx: 
request so long as those individuals agree not to disclose the Non-Prosecution Agreement. There 
is no court order requiring the government to provide the alleged "victims' with ninice that the 
Non-Prosecution Agreement is available to them upon request and doing so is in conflict with 
the confidentiality provisions of the Agreement. Given that the individuals on the list will have 
an attorney representative who is fully aware of the terms of the Non-Prosecution Agreement. 
this conflicting paragraph of your notice is unnecessary in any event and should he excised. 
Third. misstatements in your prior notification were not made "with the approval of 
Mr. Epstein's counsel.-
Fourth. we arc concerned with your open-ended description of Mr. lipstein's 
responsibilities regarding civil restitution. The resolution of liability pursuant to 18 U.S.C. 
EFTA00190385

KIRKLAND & ELLIS LLP 
A. Marie Villahiuia 
August 22. 2008 
Page 2 
§ 2253 is as stated in paragraphs 7 and S of the Agreement and the Addendum to the Agreement. 
no more. no less. 
Filth. while ?nu state, in your letter, that the IISAO does nut intend to delete any of the 
names on the list provided to Mr. Epstein's counsel. you do not confirm that the prior list is final 
and complete. There can be no expansion of the list of individuals that you informed us had 
been memorialized as of September 24. 2007 and disclosed to Mr. Epstein un June 30. 2008 (the 
date of sentence pursuant to the Agreement's disclosure requirements). Please confirm the exact 
name and number of individuals the government plans on notifying as provided for under the 
Agreement. 
Sixth. based on express language in prior communications front your Office. we are in 
agreement that paragraphs 7 and ft of the Agreement arc in need of clari ileation and 
implementation. We will work with the attorney representative in attempting to reach a fair 
resolution of the outstanding civil matters in a manner that is in accordance with the Agreement. 
Seventh, we have previously communicated our objections to the propriety of the 
attorney representative engaging in contested litigation. We again dispute the assertion that 
Mr. Jostisberg's dutit.s include filing contested litigation. In any ease, that issue is not ripe for 
resolution in this point, but again, given his agreement to be the attorney representative, we will 
address these matters directly with Mr. Josefsberg. 
Siqstircly. 
tr, 
cc: 
Karen Atkinson, Chia, Northern Division 
EFTA00190386

KIRKLAND & ELLIS LLP 
Fax Transmittal 
Citigroup Center 
153 East 53rd Street 
New York, New York 10022-4611 
Phone: 
Fax 
Please notify us immediately it any pages are not received. 
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. UNAUTHORIZED USE. 
DISCLOSURE OR COPYING IS STRICTLY PROHIBITED AND MAY BE UNLAWFUL 
IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, 
PLEASE NOTIFY US IMMEDIATELY AT: 
To: 
Company: 
Fax #: 
Direct II: 
A. Marie Villafana 
United States Attorney's Office 
561-S20-S777 
561-2W)-1047 
CC: 
Company: 
Fax #: 
Direct #: 
Karen Atkinson 
t Inited States Attorney's Office 
561-820-8777 
561-520-5711 
From: 
• 
Date: 
Pagesimicover: 
Fax #: 
Direct 
Jay 1'. Lelkowitz 
August 22.2008 
3 
Message: 
EFTA00190387

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, Ste 400 
West Palm Beach, FL 33401 
(561)8204711 
Facsimile: (561) 820-8777 
August 26, 2008 
DELIVERY BY ELECTRONIC MAIL 
Jay P. Lefkowitz, Esq. 
Kirkland & Ellis LLP 
Citigroup Center 
153 East 53rd Street 
New York, New York 10022-4675 
Roy Black, Esq. 
Black Srebnick Kornspan & Stumpf P.A. 
201 S. Biscayne Blvd, Suite 1300 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Jay and Roy: 
Thank you for your letter of August 22nd. I write to follow up on some of the points 
that you raised. 
The list of thirty-two victims that was provided to Mr. Goldberger via certified mail 
on July 10, 2008 is the final list. As I mentioned, copies of the notification letters to each 
victim will be carbon-copied to an attorney for Mr. Epstein and Mr. Josefsberg. I asked you 
to advise me whether Mr. Goldberger should continue to be listed as the contact person for 
the civil litigation in the amended victim notification letters and whether he should receive 
the carbon copies of those letters as they are sent. 
1 also asked you to provide me with written confirmation of your agreement to pay Mr. 
Josefsberg's fees. Please provide that confirmation to Mr. Josefsberg so that he can begin 
his representation, and provide me with a copy for my file. 
I have conferred with the lead AUSA in the case of Jane Doe I and 21 United States, 
EFTA00190388

JAY P. LEFKOWITZ, ESQ. 
ROY BLACK, ESQ. 
AUGUST 26, 2008 
PAGE 2 OF 2 
and he agrees that, based upon the discussion with Judge Marra during the hearing on the 
plaintiffs' motion, a notification of the judge's ruling is required. I will, however, change 
the language slightly to direct the victims to discuss the matter with Mr. Josefsberg. 
With regard to your concerns with my "open-ended description of Mr. Epstein's 
responsibilities regarding civil restitution," I agree that the resolution of civil damages claims 
is as stated in paragraphs 7 and 8 of the Agreement and Addendum. That is why the 
language in the notification is taken verbatim from paragraphs 7, 8, and 7C of the Agreement 
and Addendum, except that the victim's name is used in place of "identi fied individual." As 
I mentioned in my earlier letter, i f you have any proposed substantive changes, please provide 
them to me. 
Mr. Goldberger and Mr. Tein explicitly approved the language in my earlier victim 
notification letter, even though they apparently were taking the position that the December 
19, 2007 letter was not part of the Agreement, so that misinformation was provided to the 
victims with the approval of Mr. Epstein's attorneys. 
With regard to your sixth and seventh points, I reiterate that it is the Office's position 
that the Agreement and Addendum speak for themselves. Let me also reiterate that, while 
the Office does not intend to involve itself in any civil negotiations or litigation, if it comes 
to our attention that Mr. Epstein has breached the terms of the Agreement, the Office intends 
to enforce its right pursuant to the Agreement. 
I would appreciate a prompt response to the question regarding which of Mr. Epstein's 
attorneys should be named in and receive copies of the notification letters, as well as 
documentation of your commitment to paying Mr. Josefsberg's fees so that I may begin 
distributing the revised victim notifications on Wednesday morning. 
Sincerely, 
R. Alexander Acosta 
Un' 
States Attorney 
By: 
A. 
Villa fafla 
Assistant United States Attorney 
cc: 
Karen Atkinson, Chief, Northern Division 
EFTA00190389

From: Barry Krischer fmailto:[email protected]] 
Sent: Wednesday, September 17, 2008 10:46 AM 
To: Garcia, Rolando LUSAFLS) 
Subject: FW: State I. Jeffrey Epstein 
Please advise how you would like us to proceed. The agreement referred to is the Federal Non-Prosecution agreement 
sealed in the file by the judge at the time of the Epstein plea. 
From: Lanna Belohlavek 
Sent: Tuesday, September 16, 2008 4:21 PM 
To: Barry Krischer 
Subject: FW: State 
I
 
Jeffrey Epstein 
How to proceed? Lanna 
From: Bryce Albu [mailto:[email protected]] 
Sent: Tuesday, September 16, 2008 3:52 PM 
To: Lanna Belohlavek 
Cc: Martin Reed r 
Subject: State I. Jeffrey Epstein 
Ms. Belohlavek, 
433 
EFTA00190390

We represent The Palm Beach Daily News. The newspaper recently discovered that a non-prosecution agreement (and 
an addendum thereto) was filed under seal pursuant to an agreed order entered in the above-referenced case. Because 
the records are sealed, we cannot assess the propriety of the decision to seal them or even whether the newspaper is 
interested in the information contained therein. I was hoping you would discuss with me the nature of the agreement and 
the basis for sealing it so that we can advise our client on whether it should pursue an order unsealing the 
agreement. Please call me at your earliest convenience. 
Very truly yours, 
C. Bryce Albu 
Reeder & Reeder P.A. 
250 S. Central Blvd., Suite 200 
Jupiter, FL 33458 
Direct Dial: (561) 575-9721 
Facsimile: (561) 575-9765 
bniceareederandreedercom 
434 
EFTA00190391

09/16/2088 
17:18 
PODHURST,ORSECK 
h10, 269 
0001 
PODHURST OKSECK, P.A. 
City National Bank Building, Suite 800 
25 West Flagler Street 
Miami, FL 33130 
Please deliver the following page(s) to: 
AUSA A. Maria Villafana (561) 820-8777 
Michael R. Tein, Esq. (305) 442-6744 
Roy Black, Esq. (305) 358-2006 
File No. Epstein 
From: Robert C. Josefsberg, Esq. 
Number of page(s): (Including cover page) 
Our Fax Number: (305) 358-2382 
MESSAGE: 
Date: 9/16/08 
If you do not receive all pages, please contact us immediately at: 
(305) 358-2800 - Extension 3241 
THIS IS A PRIVILEGED AND CONFIDENTIAL COMMUNICATION. IF 
YOU ARE NOT AN INTENDED RECIPIENT, YOU SHOULD: (1) REPLY 
TO SENDER; (2) DESTROY THIS COMMUNICATION ENTIRELY, 
INCLUDING DELETION OF ALL ASSOCIATED TEXT FILES FROM ALL 
INDIVIDUAL AND NETWORK STORAGE DEVICES; AND (3) REFRAIN 
FROM COPYING OR DISSEMINATING THIS COMMUNICATION BY 
ANY MEANS WHATSOEVER. THANK YOU. 
EFTA00190392

09/ 16/2008 
17:18 
PODHURST,ORSECK 
NO. 269 
P002 
Aaron S. Podhurst 
Robert I jsosefsberg 
Joel D. 
Steven 
ks 
Victor M. Diaz, Jr 
Katherine W. Ezell 
Stephen F. Rosenthal 
Ricardo M Marttnez-Cki 
Ramon A. Rasco 
Alexander T. Rundlet 
John Gravanta lIl 
T 24.: A:. & 
22 
A 
NY 113 E.; 
AUSA A. Marie Villafana 
U.S. Attorney's Office 
Southern District of Florida 
500 S. Australian Avenue, Suite 400 
West Palm Beach, FL 33401 
Roy Black, Esq. 
Black, Srebnick, et al. 
201 S. Biscayne Blvd., Suite 1300 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Ms. Villafana and Gentlemen: 
September 15, 2008 
VIA FACSIMILE 
Robert Orseck (1934-1978) 
Walter H. Beckham. Jr. 
Karen Podhurst Dan 
Of Counsel 
Michael R. Tein, Esq. 
Lewis Tein, P.L. 
3059 Grand Avenue, Suite 340 
Coconut Grove, FL 33133-5166 
Enclosed please find a letter received today from Jeffrey Herman. Before I start wasting my 
time and Mr. Epstein's money researching the ethical issues, I would like to know if any of you 
looked into Rule 4-7.4. Until I ant advised to the contrary, I shall assume Mr. Herman is incorrect, 
but I would like this issue resolved as soon as possible. 
Very truly yours, 
Robert C. JoseEberg 
RCJ/bp 
Enclosure 
cc: 
Katherine W. Ezell, Esq. 
Amy Ederi, Esq. 
Podllunt Oneck, P.A. 23 West Ftsgler Street, Suite SOO, Wand FL 33130 
Mind 3053562900 Fax 305.3502382 • Fort Lauderdale 954463.4316 
wonv.puntuntcan 
EFTA00190393

09/ 16/2008 
17:18 
PODHLRST.ORSECK 
bierrnan dMermelitein, P 
NO.269 
P003 
10:50.10 a.m. 
16-09-2008 
2/2 
HERMAN Sr. M ER MEL-STEI N PA 
ATTORNEYS AT LAW 
September 16, 2008 
Via Fax and Regular Mail 
Robert Josefsberg, Esq. 
Podhurst Orseck P A 
25 W Flagler St Ste 800 
Miami, Florida 331301720 
Re: 
Jeffiey Epstein 
Dear Mr. Josofsberg: 
Kt_t_c 
Rc-7 
PLU'E 
Jeffrey M. Herman 
Tel 305.0312200 
Fax 305.031.0877 
Thermanahermanlaw cam 
18205 Biscayne Blvd. 
Suite 2218 
Miami, Ronda 33160 
vnwthennantaw.com 
We are in receipt of letters dated September 2, 2008 from Assistant U.S. Attorney A. 
Marie Villafaila that were sent to sexual assault victims of Jeffrey Epstein. That letter 
advises victims that you will be contacting them regarding civil claims against Epstein. 
Please be advised that we strenuously object to these letters and the contemplated unsolicited 
contacts with victims. Please be further advised that we represent the following victims in 
claims against Jeffrey Esptein, and direct that you make no contact with any of them, except 
through our office: 
• 
We further believe that Mr. Epstein's plan for you to represent victims, and for the 
Assistant U.S. Attorney to assist you in soliciting them, is in violation of the Florida Bar 
Rules, particularly Rule 4-7.4. We urge you not to participate in these activities. 
EFTA00190394

Herman &Mermelstem, P 
10:48:06 a.m. 
16-09-2008 
1 )3 
ERMAN E., M ERMELSTEIN PA 
A IORNEYS AT LAW 
FAX TRANSMITTAL 
Jeffrey M. Herman 
Tel 305-931.2200 
Fax 305-931-0877 
[email protected] 
18205 Biscayne Boulevard 
Suite 2218 
Miami, Florida 33160 
www.hermanlaw.com 
FROM 
DATE 
NO. OF PAGES 
Jeffrey M. Herman 
September 16, 2008 
3 
TO 
COMPANY 
FAX NUMBER 
A. Marie Villafana, Esq. 
U.S. Attorney's Office 
(561)820-8777 
MESSAGE 
RE: Jane Does 2-5I Jeffrey Epstein 
Please see enclosed correspondence. 
THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY 
CONTAIN_INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE 
LAW. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE 
FOR DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT. YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION. 
DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. 
IP YOU HAVE RECEIVED THIS 
COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE, AND RETURN THE ORIGINAL MESSAGE 
TO US AT THE ABOVE ADDRESS VIA THE V.S. POSTAL SERVICE. THANK YOU. 
EFTA00190395

305 9312200 
Herman 8Mermelsteln, P 
10:48:28 a.m. 
16-09-2008 
2 /3 
HERMAN & MERMELSTEIN PA 
ATTORNEYS AT LAW 
September 16, 2008 
Via Fax and Regular Mail 
A. Marie Villafalia, Esq. 
Assistant U.S. Attorney 
500 Australian Ave., Fourth Floor 
West Palm Beach, FL 33401 
Re: 
Jeffrey Epstein 
Dear Ms. Villafafla: 
Jeffrey M. Herman 
Tel 305.931.2200 
Fax 305.931.0877 
jherman©hermanlaw.com 
18205 Biscayne Blvd. 
Suite 2218 
Miami, Florida 33160 
WWW. he rmanl aw. co m 
This concerns your letters to us and to sexual assault victims of Mr. Epstein dated September 
2, 2008. Please be advised that we strenuously object to your letters on various grounds, and believe 
that they are in violation of the Florida Bar Rules. 
First, your letters attempt to steer the victims to a particular attorney, Mr. Josefsberg, and 
advise them that Mr. Josefsberg will be making an unsolicited contact to them in the next two weeks. 
This contact with prospective clients and solicitation reflected in your letters is contrary to Fla. Bar. 
Rule 4-7.4. Additionally, your letters are misleading in the following respects: (1) the action 
advocated to the victims in paragraph 2 refers generally to the victims' waiver of "any other claim for 
damages", failing to advise them that this waiver may include a valuable claim to punitive damages 
against an alleged billionaire; and (2) the letters imply in paragraph 3 that Mr. Epstein's agreement to 
pay attorney fees is a significant concession, when in fact a victim is entitled to reasonable attorneys' 
fees under the Statute upon proof of a violation, irrespective of Mr. Epstein's agreement. 
We accordingly demand that the U.S. Attorneys' office immediately cease and desist from 
directing unrepresented victims into unsolicited attorney contacts and misleading them about their 
rights in claims against Mr. Epstein. We demand that you instruct Mr. Josefsberg not to solicit 
victims, and to send letters to unrepresented victims correcting the misleading statements contained 
in your September 2, 2008 letters. 
EFTA00190396

30S 9312200 
Herman &Mermelsteln. P 
10:48:58 a.m. 
16-09-2008 
313 
A. Marie Villafafla, Esq. 
September 16, 2008 
Page 2 
Finally, we demand that you make no contact with our clients directly, and contact them only 
through our office. Our clients inclut 
Sincerely, 
r
-
effrey M. Herman 
JMH/lr 
EFTA00190397