EFTA00013616.pdf

Type: pdf
Source set: data-set-8
Extracted text

From: " 
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN= 
To: "Jay Lefkowitz" <
Subject: RE: Confidential - for settlement purposes only 
Date: Tue, 16 Oct 2007 20:00:00 +0000 
Importance: Normal 
Jay, 
The below is exactly the same as yours, except for deletion of "Other than the joint written submission, neither the United 
States nor Epstein's counsel shall communicate with the independent third party nor shall the United States communicate 
with the attorney representative selected by him" in your 1(a). 
1. The United States has the right to assign to an independent third-party the responsibility for consulting with and, subject 
to the good faith approval of Epstein's counsel, selecting the attorney representative for the individuals identified under the 
Agreement. If the United States elects to assign this responsibility to an independent third-party, both the United States 
and Epstein retain the right to make good faith objections to the attorney representative suggested by the independent 
third-party prior to the final designation of the attorney representative. 
2. The parties will jointly prepare a short written submission to the independent third-party regarding the role of the 
attorney representative and regarding Epstein's Agreement to pay such attorney representative his or her regular 
customary hourly rate for representing such victims subject to the provisions of paragraph 3, infra. 
3. Pursuant to additional paragraph 1, Epstein has agreed to pay the fees of the attorney representative selected by the 
independent third party. This provision, however, shall not obligate Epstein to pay the fees and costs of contested litigation 
filed against him. Thus, if after consideration of potential settlements, an attorney representative elects to file a contested 
lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested remedy, the paragraph 7 obligation of the 
Agreement to pay the costs of the attorney representative, as opposed to any s…
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