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ement on the identified individuals' behalf and dispersing the settlement proceeds. Mr. Epstein has agreed that he will not contest jurisdiction in the Southern District of Florida, and he will not contest liability pursuant to 18 U.S.C. § 2255 for those identified individuals who elect to settle all potential claim
al litigation. In keeping with the parties' understanding of Paragraphs 7 and 8, you should know that we are in agreement with your choice of Judge Edward Davis, but we believe Judge Davis should act as the attorney representative to settle claims pursuant to the Agreement and the parties' longstanding unde
ted your representation of a select group of individuals in connection with a matter between Mr. Epstein and the United States Attorney's Office in the Southern District of Florida (the "USAO"). We write this letter to (1) address issues raised by those invoices and (2) suggest a resolution to this matter that would
t third-party, the responsibility of selecting the Atty Rep, subject to the good faith approval ofEpsteints counsel. As you know, former Chief Judge Edward Davis was the independent third-party chosen by the United States in consultation with and with the good faith approval of Podhurst Orseck, PA. 25 West H
of any certain set of facts, other than whether a charging document was ever filed against Jeffrey Epstein in the United States District Court for the Southern District of Florida. And while this Office remains willing to cooperate, cooperation does not mean agreeing to facts that arc not relevant to the resolution
ase 9:08-cv-80736-KAM Document 58 Entered on FLSD Docket 04/07/2011 Page 13 of 15 elected to use a Special Master (retired U.S. District Court Judge Edward Davis) to make the final selection. The Petitioners also know that the AUSA, the agents, and the FBI's victim-witness coordinator obtained counseling se
rted "upon information and belie?' that they understood that Epstein was involved in on-going plea negotiations with the U.S. Attorney's Office for the Southern District of Florida. Victims' Petition (doe. #1) at 1. On July 9, 2008, the Government responded with a sealed response (quickly unsealed by the Court), that
ase 9:08-cv-80736-KAM Document 58 Entered on FLSD Docket 04/07/2011 Page 13 of 15 elected to use a Special Master (retired U.S. District Court Judge Edward Davis) to make the final selection. The Petitioners also know that the AUSA, the agents, and the FBI's victim-witness coordinator obtained counseling se
rted "upon information and belie?' that they understood that Epstein was involved in on-going plea negotiations with the U.S. Attorney's Office for the Southern District of Florida. Victims' Petition (doe. #1) at 1. On July 9, 2008, the Government responded with a sealed response (quickly unsealed by the Court), that
ase 9:08-cv-80736-KAM Document 58 Entered on FLSD Docket 04/07/2011 Page 13 of 15 elected to use a Special Master (retired U.S. District Court Judge Edward Davis) to make the final selection. The Petitioners also know that the AUSA, the agents, and the FBI's victim-witness coordinator obtained counseling se
Entities connected to both the Southern District and Edward Davis

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSONLeon Black
PERSONJack Goldberger
PERSON
Southern District of New York
ORGANIZATION
Scarlett Johansson
PERSON
Paul Cassell
PERSONMaria Farmer
PERSON
Jay Lefkowitz
PERSON
A. Marie Villafana
PERSONRoy Black
PERSONRobert C. Josefsberg
PERSON