## Villafana, Ann Marie C. (USAFLS)

<table><tr><td>From:</td></tr><tr><td>Sent:</td></tr><tr><td>To:</td></tr><tr><td>Subject:</td></tr></table>

Villafana, Ann Marie C. (USAFLS)

Wednesday, October 31, 2007 11:40 AM

Sloman, Jeff (USAFLS)

RE: Epstein

Maybe make the changes underlined below? Either way is fine.

A. Marie Villafaña

Assistant U.S. Attorney

500 S. Australian Ave, Suite 400

West Palm Beach, FL 33401

Phone 561 209-1047

Fax 561 820-8777

<table border="1"><tr><td>From:</td><td>Sloman, Jeff (USAFLS)</td></tr><tr><td>Sent:</td><td>Wednesday, October 31, 2007 11:36 AM</td></tr><tr><td>To:</td><td>Villafana, Ann Marie C. (USAFLS)</td></tr><tr><td>Subject:</td><td>RE: Epstein</td></tr></table>

Marie.

Here's my proposed response to Jay. What do you think?

Jeff

Jay,

Regarding your statement that “we are beginning to think about what discovery may need to take to verify any”. I remind you that paragraph 8 of the agreement states that Epstein “his right to contest liability and also gives his right to contest damages up to an amount as agreed to between the identified individual and Epstein, so long as the identified to proceed exclusively under 18 USC s 2255 and agrees to waive any other claim for damages ...” That being said, you are correct in assuming that we do not want to be copied on anything related to discovery. Monitoring the status of the negotiations/litigation is limited to insuring that the terms and conditions of the Non-Prosecution Agreement are not breached.

<table border="1"><tr><td>From:</td><td>Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]</td></tr><tr><td>Sent:</td><td>Tuesday, October 30, 2007 4:54 PM</td></tr><tr><td>To:</td><td>Sloman, Jeff (USAFLS)</td></tr><tr><td>Cc:</td><td>Acosta, Alex (USAFLS)</td></tr><tr><td>Subject:</td><td>Re: Epstein</td></tr></table>

Thanks Jeff.

I haven't heard anything from Judge I assume he is still willing to take on the role you asked him to take on, but can you please let me know if that is not the case?

Also, we are beginning to think about what discovery we may need to take to verify any claims. I am assuming that your office does not want to be copied on any subpoenas or anything related to discovery. But please let me know if that is an incorrect assumption.

2650



08-80736-CV-MARRA


P-014252

EFTA00189167

Thanks - Jay

<table border="1"><tr><td>----- Original Message -----</td></tr><tr><td>From: "Sloman, Jeff (USAFLS)" [Jeff.Sloman@usdoj.gov]</td></tr><tr><td>Sent: 10/30/2007 02:42 PM AST</td></tr><tr><td>To: Jay Lefkowitz</td></tr><tr><td>Cc: "Acosta, Alex (USAFLS)&lt;Alex.Acosta@usdoj.gov&gt;</td></tr><tr><td>Subject: Epstein</td></tr></table>

Jay,

Jeff

Here is an executed version of the addendum. Please Fed Ex the original signature pages to me. Thanks,



<<epstein addendum 10 30.pdf>>





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Tracking:

2651

08-80736-CV-MARRA

P-014253