| From: “ | (USAFLS)“ | |
|---|---|---|
| To: “Acosta, Alex (USAFLS)” < | ||
| Subject: FW: Epstein | ||
| Date: Tue, 16 Oct 2007 21:27:55 +0000 | ||
| Importance: Normal | ||
| fyi |
From: (USAFLS) Sent: Tuesda October 16, 2007 5:16 PM To: (USAFLS) Subject: RE: Epstein¶
Hi I.— This looks perfect. Thank you for all of the time that you spent on this.¶
Assistant U.S. Attorney¶
Fax 561 820-8777¶
From: (USAFLS) Sent: Tuesday, October 16, 2007 3:51 PM To: . (USAFLS) Subject: RE: Epstein¶
Here’s our version that we plan to send to Lefkowitz. Alex and I have read your proposed letter to Judge Davis and other than parts of the last paragraph concerning “consulting with the victims”, it looks good.¶
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The United States has the right to assign to an independent third-party the responsibility for consulting with and, subject to the good faith approval of Epstein’s counsel, selecting the attorney representative for the individuals identified under the Agreement. If the United States elects to assign this responsibility to an independent third-party, both the United States and Epstein retain the right to make good faith objections to the attorney representative suggested by the independent third-party prior to the final designation of the attorney representative.
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The parties will jointly prepare a short written submission to the independent third-party regarding the role of the attorney representative and regarding Epstein’s Agreement to pay such attorney representative his or her regular customary hourly rate for representing such victims subject to the provisions of paragraph 3, infra.
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Pursuant to additional paragraph 1, Epstein has agreed to pay the fees of the attorney representative selected by the independent third party. This provision, however, shall not obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, if
after consideration of potential settlements, an attorney representative elects to file a contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney representative, as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney representative, shall cease.¶
From: (USAFLS) Sent: Monda October 15, 2007 9:38 AM To: (LISAFLS) Subject: Epstein¶
Hi M— I have prepared this as a letter from you to Judge Davis. I am going to call to see if we have nailed down the final number of victims so that you can include the information in the letter. You can get me on my cell phone.¶
Thank you!¶
cc File: 071015 Special Master Letter.wpd Ȧ
Assistant U.S. Attorney¶
Fax 561 820-8777¶