• Villafana, Ann Marie C. (USAFLS) From: Jay Lefkowitz [email protected] al ,nt: Monday, October 22,2007 5:10 PM Sloman, Jeff (USAFLS) Uc: Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS) Subject: Re: Epstein Attachments: 071015 Special Master Letter3.wpd; Addendum.wpd Jeff — I will review these materials this evening and be in touch with you tomorrow with the expectation of wrapping this up by the end of the day. One question I have, however, is why you say that Judge Davis is a non-starter. I understood that he was ready, willing and able to serve as the attorney representative. If you have had conversations with him and that is not the case, please let me know. I will go over the other issues you raise in your email and wil look forward to speaking tomorrow. Thanks — Jay "Woman. Jeff MAFIA" f•Jeff.SlomaneusOolipoir• 10/22/2007 04:40 PM a To 'fly Leawake <Jtelliositz010itlan0.cans cc 'Acosta. Nex (WARS)" calex.AcceteOumloi poi>. Viestane Mn MM. C. (USAFLST <Annktstis.C.VIllelansaustill4-90n SotOM Epstein The Judge Davis issue is a non-starter. We've beaten that horse to death. Regarding your contention that "the attorney representative be told clearly that Mr. Epstein has agreed to pay the lawyer's hourly rate only for the time he or she spends working to effectuate settlements for the identified women," Alex and I agree that paragraph 7C is sufficient, Regarding the other points, we have made the following concessions: 1. Regarding the language concerning a lawyer whose firm is sizeable enough to litigate multiple trials simultaneously, I have removed paragraph 4 on page 3 of the letter. 2. Regarding the 150k statutory limit language, I have included a footnote which should satisfy your concern. 3. Regarding language there may be discovery to test the claims of alleged "victims", please see new paragraph 4 on page 3 which now states as criteria that the firm should have "Experience litigating against large law firms and high profile attorneys who may test the veracity of the victims' claims." I have attached the Addendum and the revised letter to Judge Davis. Jay, this needs to be concluded. Alex and I believe that this is as far as we can go. Therefore, please advise me whether we have a deal no later than COB tomorrow, Tuesday, October 23, 2007. Thanks, Jeff • Original Message I RFP MIA 000329 EFTA00209017