EFTA00184386¶
Case 9:08-cv-80736-KAM Document 361-23 Entered on FLSD Docket 02/10/2016¶
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EXHIBIT¶
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EFTA00184387¶
Case 9:08-cv-80736-KAM Document 361-23 Entered on FLSD Docket 02/10/2016¶
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Hi Jay – I already told Bert that there is no indictment and, as I mentioned, he doesn’t really need to/want to see the entire plea agreement, just the relevant paragraphs so that he understands what the scope of his representation will be. I think they would be happy knowing that their hourly rate will be paid when it is billed. The concern is, if all 40 girls decide they want to sue, they don’t want to be in a situation where Mr. Epstein says this is getting too expensive, we won’t pay any more attorneys’ fees.¶
Two suggestions, that I haven’t run past Bert, are:¶
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Mr. Epstein signs a standard fee agreement, where one of his attorneys or accountants who is not working on the damages litigation receives a monthly bill with attorney’s fees charged at an hourly rate and costs billed monthly. The bills will have any privileged information redacted. If there is a dispute about a bill that cannot be resolved, it will be submitted to a mediator for resolution.
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If that is too open-ended for Mr. Epstein, do the hourly/monthly billing until Bert has had a chance to confer with all of the girls to determine how many want him to represent them. Once it is known how many girls will be represented by Bert; and maybe who those girls are, there can be a more educated discussion about estimated fees and costs.
Just some food for thought. I will be out of the office tomorrow, but I will be reachable by cell phone. I will make sure Bert is available and confirm the time with you.¶
A. Villafaña¶
Assistant U.S. Attorney¶
US_Atty_Cor_00166¶