From: " (USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN= To: "Jay Lefkowitz" c Cc: "Acosta, Alex (USAFLS)" < . (USAFLS)" Subject: Epstein Date: Mon, 22 Oct 2007 20:40:35 +0000 Importance: Normal Attachments: 071015_Special_Master_Letter3.wpd; Addendum.wpd Jay, The Judge Davis issue is a non-starter. We've beaten that horse to death. Regarding your contention that "the attorney representative be told clearly that Mr. Epstein has agreed to pay the lawyer's hourly rate only for the time he or she spends working to effectuate settlements for the identified women," Alex and I agree that paragraph 7C is sufficient, Regarding the other points, we have made the following concessions: 1. Regarding the language concerning a lawyer whose firm is sizeable enough to litigate multiple trials simultaneously, I have removed paragraph 4 on page 3 of the letter. 2. Regarding the 150k statutory limit language, I have included a footnote which should satisfy your concern. 3. Regarding language there may be discovery to test the claims of alleged "victims", please see new paragraph 4 on page 3 which now states as criteria that the firm should have "Experience litigating against large law firms and high profile attorneys who may test the veracity of the victims' claims." I have attached the Addendum and the revised letter to Judge Davis. Jay, this needs to be concluded. Alex and I believe that this is as far as we can go. Therefore, please advise me whether we have a deal no later than COB tomorrow, Tuesday, October 23, 2007. Thanks, -----Original Message From: Jay Lefkowitz [mailto: Sent: Frida , October 19, 2007 4:05 PM To: (USAFLS) Subject: Re: - I have reviewed your proposed language and wanted to raise a few areas of concern. First, I am not sure why we are not just asking Judge Davis to represent these women. If he is available, that would save us a whole additional layer of process. I had thought that was initially the idea. I am not sure why you seem to be