EPSTEIN DECLARATORY JUDGMENT MEMO to Jay Lefkowitz Introduction 1. On September 24, 2007, following lengthy negotiations between his counsel and representatives of the United States Attorney's Office for the Southern District of Florida, PlaintiffJeffrey Epstein signed a Non-Prosecution Agreement (hereinafter "Agreement") with the Defendant United States. An Addendum was added by agreement of the parties and signed on October 30, 2007. A copy of each is appended hereto as Exhibits "A" and "B"; 2. Pursuant to and in specific performance of his obligations under the Agreement, Epstein has plead guilty to state felony charges, served acompleted his 18 month county jail sentence, been registered as a sexual offender, is currently under the restrictions of community control probation under the supervision of the Palm Beach County Probation Department, and has fulfilled certain additional civil obligations as detailed below; 3. Epstein is a defendant in a series of federal civil lawsuits, two of which have been filed by an attorney-representative who was appointed pursuant to the Agreement and who has been-paid-for-his billed over 1.5 million dollars to date for his settlement-related legal fees Jay Epstein pursuant to his interpreation of paragraph 7 of the Agreement and paragraph of the Addendum to the Agreement, see Jane Doe 101 v Epstein, Civil No and Jane Doe 102 v Epstein, Civil No . Additional lawsuits have been filed by others and consolidated for pretrial purposes by this Honorable Court as Jane Doe 2 v Epstein, Civil No . This Declaratory Judgment results directly from Epstein's intent and purpose to fulfill and not violate each of his obligations under the Agreement and Addendum, from the Government's repeated refusals to provide specifically sought guidance to Epstein and his counsel regarding how certain ambiguous terms of the Agreement will be construed, from the Government's expressed belief that it can unilaterally dec