EFTA00208970

From: 
Tuesda , S !ember 25, 2007 8:37 PM 
Jeer: 
era orneys 
Iii w_ These four people were recommended. I have not contacted them to find out what their rates are. All 
arc very active in the plaintiffs' bar in the West Palm area. -would 
be my first choice of these four 
but I think he is conflicted out because one of his partners is married to an AUSA here. 
is 
probably my second choice. 
• 
Talk to 
about this group. They are all very good personal injury lawyers, but I have concerns 
about whether there would be an inherent tension because they may feel that THEY might make more money 
(and get a lot more press coverage) if they proceed outside the terms of the plea agreement. (Sorry — I just have 
a bias against plaintiffs' attorneys.) One nice thing about his that he is in Miami where there has been 
almost no coverage of this case. 
so you know, I have never met M, but a good friend in our appellate section and one of the district judge!'
• 
in Miami are good friends with him and recommended him. 
Can you let me know tomorrow? I am going to be out for a while starting on Friday, and I would like to get this 
underway before I leave. 
Thank you. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, Fl. 33401 
• 
• 
RFP MIA 000282 
EFTA00208970

From: 
• 
mt: 
A: 
Subject: 
Wednesday, September 26. 2007 11:01 AM 
tt
l
i Meys 
Hi 
Can you give me a call at 
this morning? I am meeting with the agents and want to give 
them their marching orders regarding w at they can tell the girls. 
Also, please remove 
and
 from the list. There is too great a chance of an appearance of 
impropriety with 
and I received a bad report about 
last night. 
Thank you. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
From: 
ent: Tuesda 
Se ember 25, 2007 8:37 PM 
ub 
: 
r a orneys 
— These four people were recommended. I have not contacted them to find out what their rates are. All 
arc very active in the plaintiffs' bar in the West Palm area. would 
be my first choice of these four 
but I think he is conflicted out because one of his partners is married to an AUSA here. 
is 
probably my second choice. 
Talk to 
about this group. They are all very good personal injury lawyers, but I have concerns 
about whether there would be an inherent tension because they may feel that THEY might make more money 
(and get a lot more press coverage) if they proceed outside the terms of the plea agreement. (Sorry - I just have 
a bias against plaintiffs' attorneys.) One nice thing about 
is that he is in Miami where there has been 
almost no coverage of this case. 
It so you know, I have never met M, but a good friend in our appellate section and one of the district judges 
in Miami are good friends with him and recommended him. 
1 
RFP MIA 000283 
EFTA00208971

Can you let me know tomorrow? I am going to be out for a while starting on Friday, and I would like to get this 
underway before I leave. 
• 
sank you. 
l(s ista,Mney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
• 
• 
2 
RFP MIA 000284 
EFTA00208972

dant:
Subject: 
nes ay, ep em er 
11:49 AM 
VIM 
thing 
- Meaning no disrespect to these distinguished gentlemen, one of my criteria is that, if negotiations with you don't 
work out, they have the stamina to take you all to trial, so I politely decline your suggestion. 
From: 
Sent: W
ay, 
ptem
t
,
 
00 11:1 
M 
To: 
Subject: Re: One more thing 
Calling in 15 min. 
I have two other options. Both are retired circuit court judges, 
who do mediation now,l
and 
Any thoughts? 
• 
— Ori 'nal Messa e --
From: 
Sent: 
007 11:03 AM AST 
To: 
Subject: One more thing 
Did you send me the original signed agreement? I would like to sign that copy and return copies to 
you. 
ank you. 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
RFP MIA 000265 
EFTA00208973

•  
The information contained in this communication is 
•
onfidential, may be attorney-client privileged, may 
nstitute inside information, and is intended only for 
Ate use of the addressee. It is the property of 
Kirkland & Ellis I.LP 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. 
• 
• 
2 
RFP MIA 000286 
EFTA00208974

/1152 AM 
oubject: 
Conference Call with 
Hal 
firm has raised a number of good questions about how they are going to get paid and setting up 
a procedure that avoids any conflict of interest with their clients. Are you around today to do a conference call? 
Let me know what timcs work for you because Wants to get their conflicts counsel on the call with us. 
These are some of the questions he sent to me. 1 told 
that as part of our agreement we (the federal 
government) are not going to indict Mr. Epstein, but gave him an idea of the charges that we hadanned to 
bring as related to 18 USC 2255. With respect to question 2, do I have your permission to send Mijust that 
section of the plea agreement that applies to the damages claims (1 would recommend sending paragraphs 7 
through 10, or at least 7 and 8)? Can you talk with your client about items 3 and 4? 1 envisioned Shook Hardy 
sending regular bills to you, with any privileged information redacted, and being paid like every other client 
pays the bills. 
1. Can we get a copy of the indictment (or can you tell me the nature of the crimes against the girls)? 
2. When wdt it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the civil 
case? 
3. Is there any cap or other limitation on attorney's fees that the defendant will pay n the civi case? 
t
hat is the contemplated procedure for, and timing of, the payment of attorney's fees and costs? 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beac 
F 33401 
RFP MIA 000287 
EFTA00208975

r om: 
ant: 
Thursda Se tember 27 2007 10:57 AM 
'subject: 
e: on erence a wi 
I am available around 4 pm today. Not precisely sure of the time yet. I will speak with my client in the interim. 
 
Or 
Fro 11 11 
Sent: 09/27/2007 10:51 AM AST 
To: 
Subject: ili
Mi
aence Call with 
!Minn 
has raised a number of good questions about how they are going to get paid and setting up 
a procedure that avoids any conflict of interest with their clients. Are you around today to do a conference 
call? Let me know what times work for you because -wants to get their conflicts counsel on the call with 
us. 
af
ese are some of the questions he sent to me. I told M 
that as part of our agreement we (the federal 
vemment) are not going to indict Mr. Epstein, but gave him an idea of the charges that we had planned to 
.ing as related to 18 USC 2255. With respect to question 2, do I have your permission to send =just that 
section of the plea agreement that applies to the damages claims (I would recommend sending paragraphs 7 
through 10, or at least 7 and 8)? Can you talk with your client about items 3 and 4? I envisioned Shook Hardy 
sending regular bills to you, with any privileged information redacted, and being paid like every other client 
pays the bills. 
1. Can we get a copy of the indictment (or can you tell me the nature of the crimes against the girls)? 
2. When will it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the civil 
case? 
3. Is there any cap or other limitation on attorney's fees that the defendant will pay in the civil case? 
4. What is the contemplated procedure for, and timing of, the payment of attorney's fees and costs? 
Assistant U.S. Attorney 
1 
RFP MIA 000288 
EFTA00208976

500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
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(Airkland.com, and 
destroy this communication and all copies thereof, 
including all attachments. 
• 
2 
RFP MIA 000289 
EFTA00208977

Villafana, Ann Marie C. (USAFLS) 
tom: 
Villafana, Mn Marie C. (USAFLS) 
nt: 
Thursday. September 27. 2007 11:08 AM 
'Jay Lefkowitz' 
oubjeet: 
RE: Conference CaN with Bert Ocariz 
Thanks, Jay. Can we make it 4:15 or later? I have a 3:30 that might run more than a half hour. And let me 
know about sending Ben the agreement language. That might aid our discussions because the firm will have a 
better idea of what the litigation will entail. 
A. Marie Villafria 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Jay LefkowItz fmailto:[email protected]] 
Sent: Thursday, September 27, 2007 10:57 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject Re: Conference Call with Bert Ocariz 
I am available around 4 pm today. Not precisely sure of the time yet. I will speak with my client in the interim. 
 
Original Message 
From: "Villafana, Ann Marie C. (USAFLS)" [[email protected]) 
Sent: 09/27/2007 10:51 AM AST 
To: Jay Lefkowitz 
Subject: Conference Call with Ben Ocariz 
Hi Jay — Ben's firm has raised a number of good questions about how they are going to get paid and setting up 
a procedure that avoids any conflict of interest with their clients. Are you around today to do a conference 
call? Let me know what times work for you because Bert wants to get their conflicts counsel on the call with 
us. 
These are some of the questions he sent to me. I told Bert that as part of our agreement we (the federal 
government) are not going to indict Mr. Epstein, but gave him an idea of the charges that we had planned to 
bring as related to 18 USC 2255. With respect to question 2, do I have your permission to send Bert just that 
section of the plea agreement that applies to the damages claims (I would recommend sending paragraphs 7 
through 10, or at least 7 and 8)? Can you talk with your client about items 3 and 4? 1 envisioned Shook Hardy 
sending regular bills to you, with any privileged information redacted, and being paid like every other client 
pays the bills. 
S an we get a copy of the indictment (or can you tell me the nature of the crimes against the girls)? 
1 
RFP MIA 000290 
EFTA00208978

. • 2. When will it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the civil 
case? 
• 
Is there any cap or other limitation on attorney's fees that the defendant will pay in the civil case? 
4. What is the contemplated procedure for, and timing of, the payment of attorney's fees and costs? 
A. Marie Villafaria 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820.8777 
e information contained in this communication is 
fidential, may be attorney-client privileged, may 
,frnstitute 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. 
• 
2 
RFP MIA 000291 
EFTA00208979

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Thursday, September 27. 2007 3:06 PM 
'Jay Lefkowitz' 
oubject: 
RE: Conference Call with Bert Ocariz 
Hi Jay — I already told Bert that there is no indictment and, as I mentioned, he doesn't really need to/want to see 
the entire plea agreement, just the relevant paragraphs so that he understands what the scope of his 
representation will be. 1 think they would be happy knowing that their hourly rate will be paid when it is billed. 
The concern is, if all 40 girls decide they want to sue, they don't want to be in a situation where Mr. Epstein 
says this is getting too expensive, we won't pay any more attorneys' fees. 
Two suggestions, that 1 haven't run past Bert. are: 
I. Mr. Epstein signs a standard fee agreement, where one of his attorneys or accountants who is not 
working on the damages litigation receives a monthly bill with attorney's fees charged at an hourly rate 
and costs billed monthly. The bills will have any privileged information redacted. If there is a dispute 
about a bill that cannot be resolved, it will be submitted to a mediator for resolution. 
2. If that is too open-ended for Mr. Epstein, do the hourly/monthly billing until Bert has had a chance to 
confer with all of the girls to determine how many want him to represent them. Once it is known how 
many girls will be represented by Bert, and maybe who those girls arc, there can be a more educated 
discussion about estimated fees and costs. 
t some food for thought. 1 will be out of the office tomorrow, but I will be reachable by cell phone. I will 
*aim sure Bert is available and confirm the time with you. 
A. Marie Villafatia 
Assistant U.S. Attorney 
500 S. Australian Ave. Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
From: Jay Lefkowitz [[email protected]] 
Sent: Thursday, September 27, 2007 2:53 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Re: Conference Call with Bert Ocariz 
Marie - I will not be able to get back to you until tomorrow. However, some of the questions he raised cause me some serious 
concern. 
I. Can we get a copy of the indictment (or can you tell me the nature of the crimes against the girls)? 
Certainly he should not get a copy of any indictment. 
When will it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the civil case? 
I don't think he should get the plea agreement either. 
1 
RFP MIA 000292 
EFTA00208980

3. Is there any cap or other limitation on attorneys fees that the defendant will pay in the civil case? 
I can't imagine he would be entitled to anything other than an hourly fee. 
0
What is the contemplated procedure for, and timing of, the payment of attorney's fees and costs? 
In any event, I need to consider these issues carefully and I cannot agree to any of these issues before we speak. I would suggest we 
plan on talking tomorrow at 12 pm if you are available. 
Jay 
---- Original Message 
From: "Villafana, Ann Marie C. (USAFLS)" [[email protected] 
Sent: 09/27/2007 10:51 AM AST 
To: Jay Lefkowitz 
Subject: Conference Call with Bert Ocariz 
Hi Jay — Bert's firm has raised a number of good questions about how they are going to get paid and setting up 
a procedure that avoids any conflict of interest with their clients. Are you around today to do a conference 
call? Let me know what times work for you because Bert wants to get their conflicts counsel on the call with 
us. 
Ilk
ese are some of the questions he sent to me. I told Bert that as part of our agreement we (the federal 
vernment) are not going to indict Mr. Epstein, but gave him an idea of the charges that we had planned to 
bring as related to 18 USC 2255. With respect to question 2, do I have your permission to send Bert just that 
section of the plea agreement that applies to the damages claims (I would recommend sending paragraphs 7 
through 10, or at least 7 and 8)? Can you talk with your client about items 3 and 4? I envisioned Shook Hardy 
sending regular bills to you, with any privileged information redacted, and being paid like every other client 
pays the bills. 
1. Can we gel a copy of the indictment (or can you tell me the nature of the crimes against the girls)? 
2. When will it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the civil 
case? 
3. Is there any cap or other limitation on attorney's fees that the defendant will pay in the civil case? 
4. What is the contemplated procedure for, and timing of, the payment of attorney's fees and costs? 
Illyvfarie Villajarla 
Assistant U.S. Attorney 
2 
RFP MIA 000293 
EFTA00208981

" 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
• ione 561 209-1047 
Fax 561 820-8777 
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 c-mail or by e-mail to [email protected], and 
destroy this communication and all copies thereof, 
including all attachments. 
• 
3 
RFP MIA 000294 
EFTA00208982

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
wit: 
Wednesday, October 03,2007 3:15 PM 
Jay Lefkowitz 
subject: 
RE: 
Attachments: 
Special Master Proposal.wpd 
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. 
A. Marie Villafana 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
 
Original Message 
From: Jay Lefkowitz (mailto:[email protected]] 
Sent: Wednesday, October 03, 2007 10:53 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Cc: Guy Lewis 
Subject: 
Illi
-
•
ould we try to have a call this pm? I am free much 
the afternoon. Best is around 3 or 4 pm. 
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 postmasteriikirkland.com, and 
destroy this communication and all copies thereof, 
including all attachments. 
• 
Tracking: 
1 
RFP MIA 000295 
EFTA00208983

Recipient 
Jay Letkowitz 
Sloman, Jeff (USAFLS) 
Read 
Read: 10/3/2007 3:38 PM 
2 
RFP MIA 0002% 
EFTA00208984

PROPOSAL FOR SELECTION OF ATTORNEY 
TO REPRESENT VICTIMS 
1. 
Select a Special Master. 
2. 
Provide the Special Master with: 
a. 
a joint list containing the names of five attorneys; 
b. 
a joint statement of relevant facts regarding the case; 
c. 
each party's list of criteria; 
d. 
a copy of the relevant portion of the Non-Prosecution Agreement 
(discussing the role of the attorney for the victims); and 
e. 
a proposed retainer agreement. 
3. 
Each attorney on the list can provide the Special Master with information 
regarding his/her experience, firm size, etc. 
4. 
The Special Master can interview any or all of the attorneys as the Special 
Master deems appropriate. 
5. 
The Special Master will provide us with the top three choices (in order). The 
first attorney will be contacted and a conflicts check will be run. If there is a 
conflict in representation, the second attorney will be contacted, etc. 
RFP MIA 000297 
EFTA00208985

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
109nt: 
Wednesday, October 03, 2007 3:38 PM 
Jay Lefkowitz 
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 (which becomes a text message) 
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. 
A. Marie Villafaila 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
 
Original Message 
From: Jay Lefkowitz [mailto:[email protected]] 
Sent: Wednesday, October 03, 2007 3:30 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Subject: Re: 
lill
rie - I appreciate your taking a stab at this. There is a lot here, and I don't want to 
give you any reaction before I speak with my client. I will let you know as soon as I do so 
we can speak about it. But 4 pm will certainly be too soon. 
Jay 
 
 Original Message  
From: "Villafana, Ann Marie C. (USAFLS)" [[email protected]] 
Sent: 10/03/2007 03:15 PM AST 
To: Jay Lefkowitz 
Subject: RE: 
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. 
A. Marie Villafaha 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
• 
 
Original Message 
From: Jay Lefkowitz (mailto:flefkowitzfikirkland.com] 
1 
RFP MIA 000298 
EFTA00208986

a Sent: Wednesday, October 03, 2007 10:53 AM 
To: Villafana, Ann Marie C. (USAFLS) 
Cc: Guy Lewis 
ilirbject: 
Should we try to have a call this pm? I am free much 
of the afternoon. Best is around 3 or 4 pm. 
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 postmastenOkirkland.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 
lee
stitute inside information, and is intended only for 
use of the addressee. It is the property of 
.irkland & 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 postmasterlkirkland.com, and 
destroy this communication and all copies thereof, 
including all attachments. 
• 
2 
RFP MIA 000299 
EFTA00208987

Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
nt: 
Wednesday, October 03, 2007 4:23 PM 
Jay Lefkowitz 
..object: 
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 
ter to Special Ma 
A. Marie Villafana 
Assistant U.S. Attorney 
561 209-1047 
Fax 561 820-8777 
• 
• 
Tracking: 
RFP MIA 000300 
EFTA00208988

Recipient 
Jay Letkowitz 
Siciman. Jeff OJSAFLS) 
Read 
Read: 10/3/2007 4:43 PM 
2 
RFP MIA 000301 
EFTA00208989