ROY BIACK HOWARD M. SREBNICK SCOTT A. KORNSPAN LARRY A. srumpt. MARIA NEYRA JACKIE PERCZEK MARK A.J. SHAPIRO JARED LOPEZ Jeff Sloman, Esq. United States Attorney 99 N.E. 4th Street Miami, FL 33132 BLACK SREBNICK KORNSPAN STUMPF - P.A. March 29, 2010 Assistant United States Attorney 99 N.E. 4th Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: JESSICA FONSECA-NADER KATifunrii P. PHILUPS AARON AMMON MARCOS BEATON, JR. MATTHEW P. O'BRIEN JENIPER J. SOUUKIAS NOAH Fox Assistant United States Attorney 500 South Australian Avenue West Palm Beach, FL 33401-6223 Jeffrey Epstein has an April 5, 2010 deadline for the filing of a Motion to Dismiss, and thereafter an Answer, to claims brought by Jane 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 Jane 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 1300 • Miami, Florida 33131 • Phone: 305.371.6421 • Fax: 305-358.2006 • www.RoyBlack.com EFTA00207722