EFTA00013698.pdf

Type: pdf
Source set: data-set-8

Extracted text

KIRKLAND & ELLIS LLP
AND AFFILIATED PARTNERSHIPS
Jay P. Lefkowitz, P.C.
To Call Writer Directly:
(212)446-4970
[email protected]
VIA E-MAIL
Da
=group Center
159 East 53rd Street
New York, New York 10022-4611
(212) 446.4800
wvny.kirkland.com
November 8, 2007
Re: Jeffrey Epstein
Facsimile:
(212) 4464900
I write in response to your recent letter, dated November 5, 2007. I want to make clear at
the outset that Mr. Epstein is complying fully with the Non Prosecution Agreement (the
"Agreement") and that he has every intention of continuing to honor its terms in good faith. Any
disagreement the parties have regarding the terms of the Agreement should be resolved through
open dialogue and should not be construed as a repudiation of the Agreement. I do, however,
want to address each of the points you raise in your letter.
First, we do not believe Mr. Epstein's agents are precluded from speaking to any
individuals at this point in time. We carefully reviewed the Agreement and the laws governing
contact with witnesses and proceeded under the belief that Mr. Epstein's agents could properly
contact potential witnesses in this matter. We believe that nothing in the Agreement precludes
contact by Mr. Epstein's agents with any individuals. Paragraph 7 of the Agreement states that
"Epstein's counsel may contact the identified individuals through [the attorney representative],"
but it in no way restricts any other contacts that are both lawful and appropriate. Furthermore,
your Office has not yet identified the alleged victims under 18 U.S.C. § 2255 nor has an attorney
representative been selected.
Indeed, it is quite common for a party's agents, and even his attorneys, to speak with
potential claimants prior to their retaining formal representation. And in this situation — where
Mr. Epstein faces significant potential civil exposure, and he has a right to test the veracity of
these claims — it is appropriate that his agents would seek to obtai…

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