Epstein Secrets

construed as an admission of civil or criminal liability in regards to any of those who seek compensation from the Trust. See draft proposal from Jay Lelkowitz to Andrew l.nurie dated September 15. 2007. In response, Ms. • nded that the Agreement contain language considering the inclusion of guardian ad M

ch. I did this in an attempt to avoid what I foresaw would likely be 'litigious seleaion process. It was only after I proposed this change that Mr. Lelkowitz raised with me his enumerated concerns. 2 Section 2255 provides that: "[tiny person who, while' minor, was' victim of violation of [enumerated secti

dentified victims and Epstein's counsel may contort the identified victims through that counsel. Sere draft non-pmsecutio agreement nailed from to Lelkowitz dated September 17. 20117. The inclusion of I guardian ad litem. however. only served to complicate mailers. We continued to reiterate our objectio

d. Needless to say. we were elisi alarmed that Ms. would attempt to influence the settlement process on such improper grounds. And even alter the IJSAO conceded that it was inappropriate for its attorneys to select the attorney representative. Ms. Villafana continued to improperly lobby for Mr. Ocar

AFLS) Subject: Re: Follow up - Thanks. Jeff, are we all set? Jay Original Message From: " , (USAFLS)" Sent: 10/18/2007 12:15 PM AST To: Jay Lefkowitz Cc: " , Jeff (USAFLS)" Subject: RE: Follow up Jeff -- Can you see any issues with this? If not, please confirm with Jay. Original Message From: J

d by the FBI to confirm whether they were 17 or 18 at the time of their activity with Mr. Epstein." See Tab 26, September 24, 2007 Email from M. to J. Lefkowitz (emphasis added). This statement indicated that, at least the "six others" (and, as it turns out, all those identified except two) had reached the a

to confer with your co-counsel regarding this matter. Although the language of Paragraph 8 could be so construed, our First Assistant informed Mr. Lefkowitz some weeks ago that this was not our position. As Mr. Lefkowitz has noted, were Mr. Epstein convicted at trial, the plaintiff-victims in a subsequen

fendant gives up certain rights to contest liability for a chill mettle specifically. Ms. • ' not believe there wits room for contention given the IJSAO's, and ultimatums that required that we acquiesce to these unprecedented terns. Concerns Iteaardinu Section 2253 Mr Epstein unconditionally re-as

pay for the attorney representative — when originally stated that the n:presrmative could he paid for by us or the federal court. Sec c-mail frona Lelkowitz dated September 23. 2007. EFTA00214315 12/11/2007 11:45 FAX t 027/099 KIRKLAND & ELLIS Lir R. Alexander Acosta I)cecmhcr I I. 2007 l'age 4 t

dentified victims and Epstein's counsel may contact Ow identified victims through that counsel. See draft non-pmsecution agreement e-mailed fro to Lelkowitz dated September I?. 2007. the inclusion of a guardian ad 'them, however. on y served to complicate matters. We continued to reiterate our objection

tified individuals, raises cause Ibr concern as to the nature of all conununications that are made to the 'victims.' You previously stated that the IJSAO's main objective with respect to the Section 2255 component of the Agreement was to -place the victims in the same position as they would have been

ictims and Epswin's counsel may contact the identified victims through that Col/MCI. See droll non-prosecution agreement c-mailed from Villafana to Lelkowitz dated September 17. 2007. The inclusion of a guardian ad Mem, however. only served to complicate matters. We continued to reiterate our objections

strued as an admission of civil or criminal liability in regards to any of those who seek compensation from the Trust. See dmft proposal sent from Jay Lelkowitz to Andrew Laurie dated September 15, 2007. In response, Ms. Villafamt demanded that the Agreement contain language considering the inclusion of a g

but based on the belief that a guardian ad litem would not be appropriate lbr adults that are capable of making their own decisions. Ilowever. the IJSAO included into the Agreement that we pay Ibr the attorney representative -- when originally Ms. Villafana stated that the representative could he paid

rued as an admission or civil or criminal liability in regards to any of those who seek I. pensalion from the Trust. See draft proposal sent from Jay Lerkowitz to Andrew I.ourie doted September 15. 2007." In response, Ms. Villarana demanded that the Agreement contain language considering the inclusion of a

t of Florida DELIVERY BY ELECTRONIC MAIL Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP ew York, New York 10

utgrowth of the fact that civil settlement. as opposed to restitution. is considered in the Agreement, A. Rule of the Attorney Representative The IJSAO has improperly emphasised that the chosen Bonney representative should be able to litigate the claims of individuals, which violates the terms, and