AUSA A. MARIE VILLAFANA US Atty Office WPB Re Jeffrey Epstein Dear Ms Villafana We write this letter to renew our request that the United States Attorney's Office provide us, as Mr Epstein's counsel in the federal NPA matter, with clarity as to what legal issues we can advise his civil counsel can be litigated without causing you to consider the raising of legal issues to be in breach of Mr. Epstein's obligations under paragraph 8 of the NPA. On February 11, 2010 you advised us that for reasons including the fact that at the time there were "no currently pending cases arising exclusively under 18 USC 2255 as to any of the victims on the identified list" you would "decline to provide any advisory opinions" in response to our requests during our meeting of February 3. Since February 11, 2010 a lawsuit has been filed by the attorney representative on behalf of Jane Doe 103. Her identity is known by us and she is on the "identified list". Her lawsuit raises only 2255 claims. Although she has not waived her right to file any other state or federal or common law claim so as to fit squarely within the letter of paragraph 8 of the NPA, she does, in her lawsuit, quote paragraph 8 and claim rights as a beneficiary of that agreement, see Case No 10-80309 (SD Fla), Complaint, par 25-26, thus requiring that civil counsel consider responsive motions that relate to the scope of waiver of liability that is memorialized in the NPA. As we said to you and Mr. Sloman and Mr. Senior during our meeting on February 3, we need to provide advice to Mr. Epstein's civil counsel as to whether their raising of certain legal challenges to the Complaint will be perceived as being in conflict with Mr. Epstein's NPA obligations. These issues include: I. Whether Mr. Epstein can contend that any waiver of liability is limited to a single predicate offense as to each claimant? This issue is pertinent since Jane Doe 103 has brought six separate claims of 2255 violations each