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Correspondence · May 18, 2010

Epstein defense counsel letter to prosecutors on fee dispute, May 2010

Epstein's defense counsel letter to federal prosecutors disputing a $2 million fee claim by the victims' attorney firm under the non-prosecution agreement.Machine-written summary

ROY BLACK
HOWARD M. SREBNICK
SCOTT A. KORNSPAN
LARRY A. STUMPF
MARIA NEYRA
JACKIE PERCZEK
MARK A.J. SHAPIRO
JARED

BLACK

SREBNICK KORNSPAN & STUMPF

P.A.

JESSICA FONSECA-NADER KATHLEEN P. PHILLIPS AARON ANTHON MARCOS BEATON, JR. JENIFER J. SOULIKIAS NOAH FOX JOSHUA SHORE

E-Mail: RBlack@RoyBlack.com

May 18, 2010

VIA EMAIL AND U.S. MAIL

Assistant United States Attorney

United States Attorney’s Office

Southern District of Florida

500 South Australian Avenue

Suite 400

West Palm Beach, Florida 33401

Jeff Sloman, Esq.

United States Attorney

99 N.E. 4th Street

Miami, FL 33132

Assistant United States Attorney

99 N.E. 4th Street

Miami, FL 33132

RE: Jeffrey Epstein

Dear Counsel:

We received notice this morning that Podhurst Orseck, P.A. has filed a civil complaint seeking over $2,000,000 in addition to the $526,000 they have already been paid by Jeffrey Epstein for their work as attorney representatives. As we communicated to you during our February 3, 2010 meeting and both before (January 20, 2010) and thereafter (February 18, 2010) by letter, see appended letters, there exists significant differences between fees that Mr. Epstein and his civil counsel believe are within his NPA obligations and additional amounts which the attorney representative is claiming are due.

Mr. Epstein has in the past attempted to resolve issues relating to the outstanding invoices through efforts to review the particulars in the unpaid bills with the attorney representative, through settlement discussions with the attorney representative, and through his signing on February 16, 2010 a Special Masters Agreement which would allow a neutral third party to make a binding determination as to what portions of the invoices at issue were reasonable, non-

201 S. Biscayne Boulevard, Suite 1300 • Miami, Florida 33131 • Phone: 305-371-6421 • Fax: 305-358-2006 • www.RoyBlack.com

EFTA00183038

Jeff Sloman, Esq.

May 18, 2010

Page 2

duplicative, and within Mr. Epstein’s NPA-obligations. As a preliminary matter, Mr. Epstein had been requesting, but did not receive, an invoice including billing dating back to the end of 2009 until May 11, 2010 – and even this invoice was without the charges of certain of the outside contractors relied upon by the Podhurst firm.

We regret that these efforts did not resolve the matter and that Podhurst Orseck, P.A. elected instead to litigate. Mr. Epstein is today, in response to the lawsuit, filing a motion for authority to place $2,000,000 in an account maintained at the Clerk’s Office for the United States District Court pending the results of the litigation. Mr. Epstein has always agreed that he is entirely responsible for any settlement-related fees that are not excessive and will take no litigation position inconsistent with that understanding. However, we have contended as a matter of principle that given the unexpected enormity of the claims for legal fees, that absent additional detail on why the invoiced fees were not duplicative and excessive and outside the ambit of Mr. Epstein’s NPA obligations, payment should depend on either an agreement with the attorney representative which never occurred or a determination by a neutral third party. Mr. Epstein will pay whatever amount Judge Gold or any selected Master determine he owes under the NPA.

Respectfully submitted,

MARTIN WEINBERG, ESQ.

RO, 3LACK, ESQ.

By ___

/wg

Black, Srebnick, Kornspan & Stumpf, P.A.

Epstein defense counsel letter to prosecutors on fee dispute, May 2010

Emails and letters

Epstein's defense counsel letter to federal prosecutors disputing a $2 million fee claim by the victims' attorney firm under the non-prosecution agreement.

DOJ Epstein Files, Data Set 9 · May 18, 2010

<table <tr <td ROY BLACK</td </tr <tr <td HOWARD M. SREBNICK</td </tr <tr <td SCOTT A. KORNSPAN</td </tr <tr <td LARRY A. STUMPF</td </tr <tr <td MARIA NEYRA</td </tr <tr <td JACKIE PERCZEK</td </tr <tr <td MARK A.J. SHAPIRO</td </tr <tr <td JARED</td </tr </table BLACK SREBNICK KORNSPAN & STUMPF P.A. JESSICA FONSECA-NADER KATHLEEN P. PHILLIPS AARON ANTHON MARCOS BEATON, JR. JENIFER J. SOULIKIAS NOAH FOX JOSHUA SHORE E-Mail: RBlack@RoyBlack.com May 18, 2010 VIA EMAIL AND U.S. MAIL Assistant United States Attorney United States Attorney’s Office Southern District of Florida 500 South Australian…