EFTA00183838
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. MATTHEW P. O'BRIEN JENIFER J. SOULIKIAS NOAH FOX E-Mail: March 29, 2010 Jeff Sloman, Esq. United States Attorney 99 N.E. 4th Street Miami, FL 33132 Assistant United States Attorney 500 South Australian Avenue West Palm Beach, FL 33401-6223 Esq. Assistant United States Attorney 99 N.E. 4th Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: Jeffrey Epstein has an April 5, 2010 deadline for the filing of a Motion to Dismiss, and thereafter an Answer, to claims brought by Doe 103 pursuant to 18 USC §2255 that were referenced in our earlier letter to you dated March 5, 2010, to which there has been no response. We firmly believe that the issues raised in the draft motion that is appended to this letter do not conflict with, nor, if filed, breach Mr. Epstein's obligations under the NPA. Please advise if any of the issues in the draft motion authored by his civil counsel Robert Critton are, from your perspective, in conflict with the §2255 provisions of the NPA so that we may reassess our legal opinion that Mr. Epstein's civil counsel can litigate the legal issues contained in the draft motion without fear that the litigation will be construed by your office as being in violation of the NPA. If the government believes that any of the issues intended to be raised in defense of the Doe 103 lawsuit are in breach of Mr. Epstein’s obligations under the NPA, we request notice so that we could decide before any filing whether to file a 201 S. Biscayne Boulevard, Suite I300 • Miami, Florida 33131 • Phone: 305-371-6421 • Fax: 305-358-2006 • www.RoyBlack.com EFTA00183839 Declaratory Judgment action asking the Court presiding over the Doe 103 lawsuit to determine whether the raising of the issue by motion or defense would be in conflict with Mr. Epstein's contractual duties under the NPA or to withdraw the issue to the extent we become convinced that your position, if in conflict with ours, is correct. Again, Mr. Epstein's paramount priority, and ours, is that the terms of Mr. Epstein's agreement with the government be followed and fulfilled. Your truly, MARTIN WEINBERG, ESQ. ROY BLACK, ESQ. By Pig Black /wg Black, Srebnick, Kornspan & Stumpf, P.A.