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ment by the government or its agents. Below, I've outlined our main areas of concern with the approach Ms. Chicago Hong Kong London Los Angeles Munich San Francisco Washington. D.C. RFP MIA 000001 EFTA00209047 ConfidentiaL For Settlement Purposes Only, Pursuant to Rule 408. • • • R. Alexan
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
USAO which served to further clarify the Agreement with respect the role of the attorney representative. Chicago Hong Kong London Los Angaies - Munich San Francisco Washington, D.C. EFTA00212853 '03/03/2009 18:33 FAX Qh003/004 KiRKLAND & ELLIS LIP Robert C. Josefsberg March 3, 2009 Page 2
k of suppo Mt. E ein's offer of $50,000 to resolve claims that are not time-barred (as we believe claim to be), without any On several occasions, IJSAO representatives have asserted that the government takes no position as to the claims of the individuals identified as alleged victims. For the sake
ant United States Arta •conduct has troubled us from day one has quite recently reached out to the attorney fur and Chicago Hong Kong London Munich Now York Sun rtanctoco Washington. D.C. EFTA00214291 12/11/2007 11 37 FAX /003/088 KIRKLAND & ELLIS LLP Honorable K. Alexander Acosta Decem
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
uthored by Detective Katy and certain affidavits executed by him contained both material misstatements Chicago Hong Kong I muffin LOU Atlaulr,r Munich Son Francisco Washington. n.C. EFTA00176114 12/11/2007 11:37 FAX i 005/099 KIRKLAND & ELLIS LLP It. Alexander Acosta December II. 2007 Page
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
me. you indicate that the reason for the rejection or a fund was because it would place an upper limit on Chiongo Hong Kong London Los Angeles Munich San Francisco Washington, D.C. EFTA01718661 12/11/2007 11:45 FAX @j 025/099 KIRKLAND & ELLIS LLP R. Alexander Acosta l)ecember I I. 2007 Pa
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
entencing in the same manner as would the appearance and statements of a member of your Office or the FBI. Chicago Hong Kong London Los Angeles Munich San Francisco Washington. D.C. RFP MIA 000007 EFTA00184878 Case 9:08-cv-80736-KAM Document 362-15 Entered on FLSD Docket 02/10/2016 Page 3 of 5
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
Entities connected to both Munich and IJSAO

Jeffrey Epstein
PERSONKirkland & Ellis LLP
ORGANIZATION
George W. Bush
PERSON
United States
LOCATIONLeon Black
PERSON
Jay Lefkowitz
PERSON
Alexander Acosta
PERSON
Ken Starr
PERSONJack Goldberger
PERSON
Department of Justice
ORGANIZATIONSouthern District
LOCATIONRoy Black
PERSON
Alan Dershowitz
PERSON
Jeffrey Sloman
PERSONRobert C. Josefsberg
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSON
Prince Andrew
PERSONCitigroup Center
ORGANIZATION
Podhurst
PERSON