Case 9:08-cv-80736-KAM Document 362-3 Entered on FLSD Docket 02/10/2016 Page 2 of 2 . (USAFLS) From: Sent: To: Subject: Jay Lefkowltz [email protected]] Thursday. September 27, 2007 2:53 PM (USAFLS) Re: Conference Call with Bert Ocariz - I will not be able to get back to you until tomorrow. However, some of the questions he raised cause me some serious COMM. I. Can we get a copy of the indichmot (or can you tell me the nature of the crimes against the girls)? Certainly he should not get a copy of any indictment. 2. When will it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the civil case? don't think he should get the pica agreement either. 3. Is there any cap or other limitation on attorney's fees that the defendant will pay in the civil case? I can't imagine he would 1w entitled to anything other than an hourly fee. 4. 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 al 12 pm if you arc available. Jay 0ri inal Message From: • (USAFIS)" Sent: 09/27/2007 10:51 AM AST To: lay Lelkuwitz Subject: Conference Call with Bed Denny 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. These are some of the questions he sent to me. I told Bert that as part of our agreement we (the federal government) arc 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 hills. 1. Can we get a copy of the indictment (or can you tell me the nature of the crimes against the girls)? 08-80736-CV-MARRA RFP WPB 001687 EFTA00184820
Case 9:08-cv-80736-I<AM Document 362-4 Entered on FLSD Docket 02/10/2016 Page 1 of 2 EXHIBIT 74 EFTA00184821

