Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Wednesday, October 31, 2007 11:00 AM To: Sloman, Jeff (USAFLS) Subject: RE. Epstein Hi Jeff— There are two issues that could arise. First, it in the context of litigation or settlement negotiations with one of the victims. Epstein tries to contest liability or otherwise violate the particular terms related to the victims, the victim's attorney should file suit in District Court asking to enforce the agreement as an intended third party beneficiary. Second. if Epstein violates this or any other term of the agreement. the agreement says that we must give timely notice to Epstein of his breach and then file an indictment/information within 60 days of providing notice of the breach. This is one of the reasons why we shouldn't be completely blocked from communicating with the attorney for any of the named victims. He/she will be the only person who can tell us about the breach. A. Marie Villafana Assistant U.S. a 500 S. Australian Ave. Suite 400 West Palm Beach. FL 33401 Phone 561 209-1047 Fax 561 820-8777 From: Sloman, Jeff (USAFLS) Sent: Wednesday, October 31, 2007 10:00 AM To: Villafana, Ann Marie C. (USAFLS) Subject: RE: Epstein Here's what I propose to send to lay. 81W, what is the mechanism to resolve such potential disputes? Jay. The agreement says that your client will not contest liability as to the victims 6n our list. The way I read the agreement. discovery may be relevant to the issue of the amount of damages suffered. but not the veracity of the claims. That being said, I do not view our office as the mediator of such disputes. From: Villafana, Ann Made C. (USAFLS) Sent: Wednesday, October 31, 2007 9:52 AM To: Sloman, Jeff (USAFLS) Subject: RE: Epstein Ili Jeff - The agreement says that they will not contest liability as to the gigs on our list. Discovery may be relevant to the issue of the amount of damages suffered, but not the veraci of the claims. A. Marie Villatafia Assistant U.S. Attorney 500 S. Australian Ave. Suite 400 West Palm Beach, FL 33401 2653 08-80736-CV-MARRA P-014254 EFTA00189169