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

ly agreed that he will waive the right to contest liability and jurisdiction for the purpose of settling claims with the alleged victims pursuant to Sections 7 through 8 of the Agreement and Addendum. Mr. Epstein has no obligation to waive this right to contest liability RFP MIA 000035 EFTA00209081 12/11/2007 11:

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

ly agreed that he will waive the right to contest liability and jurisdiction for the purpose of settling claims with the alleged victims pursuant to Sections 7 through 8 of the Agreement and Addendum. Mr. Epstein has no obligation to waive this right to contest liability RFP MIA 000035 EFTA00184901 . . . _ Case

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

ly agreed that he will waive the right to contest liability and jurisdiction for the purpose of settling claims with the alleged victims pursuant to Sections 7 through 8 of the Agreement and Addendum. Mr. Epstein has no obligation to waive this right to contest liability EFTA00214323 12/11/2007 11:49 FAX 5095/099

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

ly agreed that he will waive the right to contest liability and jurisdiction for the purpose of settling claims with the alleged victims pursuant to Sections 7 through 8 of the AgreementAnd Addendum. Mr. Epstein has no obligation to waive this right to contest liability EFTA01718671 12/11/2007 11:49 FAX 035/09,9