To: Jay Lefkowitz Subject: RE: Epstein No, but it should be done soon because if JEE does not want the amended complaint filed, then Edwards' will move the case to be set for trial and it is harder to amend after the case is set for trial. There will be a number of problems for JEE if he decides not to file the amended complaint, which we should discuss before any final decision is made. From: Jay Lefkowitz [mailto Sent: Monday, August 08, 2011 2:14 PM To: Joseph L. Ackerman, Jr. Subject: Re: Epstein Is there a deadline for filing a supplemental response? From: "Joseph L. Ackerman, Jr." Sent: 08/08/2011 05:53 PM GMT To: Jay Lefkowitz Subject: Re: Epstein I We have already answered. I believe we have sent it to you already. It needs to be amended. Joe Ackerman On Aug 8, 2011, at 1:36 PM, Jay Lefkowitz l> wrote: Joe, I don't think Jeffrey will end up filing another complaint, although it's useful to have an extra week or two to consider the issue. But it's important to pin down when our response to the counterclaim is due. I had heard it was mid-September, but can you please let me know. Thanks From: "Joseph L. Ackerman, Jr." Sent: 08/07/2011 04:15 PM GMT To: "CHRISTOPHER E. KNIGHT" •4 Cc: Jay Lefkowitz; Jeffrey Epstein Darren Indyke .e- >; Lilly Ann Sanchez Subject: Re: Epstein Yes because it will be directed to counter claim. Joe Ackerman EFTA00429390

On Aug 7, 2011, at 12:13 PM, "CHRISTOPHER E. KNIGHT" < > wrote: All ideas I agree with as previously discussed. Lilly get approvals. Can we file a proposal when complaint is dismissed waiting amendment? Not sure valid. Sent from my iPhone On Aug 7, 2011, at 12:09 PM, "Joseph L. Ackerman, Jr." .aMI M wrote: Motions for partial summary judgement/strike on damages. Time as a party working on a Case is not recoverable. Mental pain and suffering is not recoverable in absence of a physical impact. Reputation damages need to be part of a defamation claim which is not pled. They will have to drop some replead others and we say to the judge that he cannot allow punitive damages until they have viable claims. We should also send a proposal for settlement so that when they see other motions and that if they are too cavalier they may end up paying our fees. We can discuss amount but I suggest $500,000, which fair, reflects last offer, allows us to go up if necessary and we hold at that number until Edwards gets more reasonable. Joe Ackerman On Aug 7, 2011, at 11:48 AM, Jay Leflcowitz cza , wrote: What motion do you propose filing this week? From: "Joseph L. Ackerman, Jr." [ Sent: 08/07/2011 03:46 PM GMT To: Jay Lefkowitz Cc: Jeffrey Epstein .c :•; Darren Indyke Lilly Ann Sanchez Subject: Re: Epstein I hit send before I was done. Edwards will have more credibility with his claim. As it is, he had the same problems we did, and many of his damage claims are not available. So I think we need to file motions at them this week or soon. This us the only way to get a more realistic settlement response. Joe Ackerman On Aug 7, 2011, at 10:40 AM, Jay Leflcowitz wrote: Joe, Procedurally, what happens to the counterclaim if Jeffrey doesn't file a new complaint. The prior complaint was dismissed as I understand it. So if he simply doesn't file another one, can a counterclaim continue? What would the jurisdictional basis be at that point? Can you send me some case law on this? Thanks. Jay EFTA00429391