EFTA00214980.pdf
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From: '
(USAFLS)"
To: "'Jay Lefkowitz"'
Subject: RE: Conference Call with Bert Ocariz
Date: Thu, 27 Sep 2007 15:08:25 +0000
Importance: Normal
Thanks, Jay. Can we make it 4:15 or later? I have a 3:30 that might run more than a half hour. And let me know
about sending Bert the agreement language. That might aid our discussions because the firm will have a better
idea of what the litigation will entail.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
From: Jay Lefkowitz
Sent: Thursday, September 27, 2007 10:57 AM
To:
. (USAFLS)
Subject: Re: Conference Call with Bert Ocariz
I am available around 4 pm today. Not precisely sure of the time yet. I will speak with my client in the interim.
-- Original Message
From: '
Sent: 09/27/2007 10:51 AM AST
To: Jay Lefkowitz
Subject: Conference Call with Bert Ocariz
Hi Jay — Bert's firm has raised a number of good questions about how they are going to get paid and setting up a
procedure that avoids any conflict of interest with their clients. Are you around today to do a conference call?
Let me know what times work for you because Bert wants to get their conflicts counsel on the call with us.
These are some of the questions he sent to me. I told Bert that as part of our agreement we (the federal
government) are not going to indict Mr. Epstein, but gave him an idea of the charges that we had planned to
bring as related to 18 USC 2255. With respect to question 2, do I have your permission to send Bert just that
section of the plea agreement that applies to the damages claims (I would recommend sending paragraphs 7
through 10, or at least 7 and 8)? Can you talk with your client about items 3 and 4? I envisioned Shook Hardy
sending regular bills to you, with any privileged information redacted, and being paid like every other client pays
the bills.
1. Can we get a copy of the indictment (or can you tell me the nature of the crimes against the girls)?
2. When will it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the civil
case?
EFTA00214980
3. Is there any cap or other limitation on attorney's fees that the defendant will pay in the civil case?
4. What is the contemplated procedure for, and timing of, the payment of attorney's fees and costs?
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
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EFTA00214981
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| Filename | EFTA00214980.pdf |
| File Size | 101.8 KB |
| OCR Confidence | 85.0% |
| Has Readable Text | Yes |
| Text Length | 3,120 characters |
| Indexed | 2026-02-11T11:16:26.788082 |