Roy BLACK HOWARD M. SREEINICK SCOTT A. KORNSPAN LARRY A. STUMPF MARIA NEYRA JACKIE. PERCZEK MARK A.J. SHAPIRO JARED LOPEZ BLACK SREBNICK KORNSPAN & STUMPF _PA= January 20, 2010 JESSICA FONSECA-NADP.R KATHLEEN P. PHILLIPS AARON ANTHON MARCOS BEATON. JR. MATTHEW P. O'BRIEN JENIFER J. SOULIKIAS NOAH Fox E-Mail: iffilack4RoyBlack.com RE: Jeffrey Epstein Dear Marie: We are now facing a difficult issue about the attorney's fees in the civil cases brought against Mr. Epstein related to your prior criminal investigation. I broached this subject with you on the phone a couple of weeks ago, but I could see our discussion was not fruitful at that time. Since we could not come to any agreement on how to handle this, we must proceed ahead based on our understanding of the non-prosecution agreement. Mr. Epstein has paid the attorney representative $526,000 and accepts his obligation under the NPA to pay additional reasonable legal fees that precede litigation claims under 17C of the Addendum. However we believe that the request by the attorney representative for over $1.5M additional fees is both unreasonable and outside the Addendum's criteria for payment. Litigation may ensue since we have been unable to resolve these matters through an agreement. We never contemplated that the legal fee agreement would result in a bill for $2.1M when the Addendum was entered. We understand you and Jay had different views on whether an attorney representative could both sue Epstein for some clients and remain as counsel to settle other cases. We believe that the attorney representative could either settle the cases and be paid hourly or litigate and be paid out of the judgment, but not both. The language of the NPA is in need of legal construction regarding whether Epstein's obligations end when 201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • Phone. 305-371-6421 • Fax: 30S-358.2006 • AN%M.F0yBI3Ck.COM EFTA00207040