Salutation: "Jay,"

From: [redacted]

To: "Jay Lefkowitz" <[redacted]>

Bcc: [redacted] (USAFLS) <[redacted]> [redacted]

Subject: RE: Epstein

Date: Wed, 31 Oct 2007 15:51:29 +0000

Importance: Normal

Jay,

Regarding your statement that "we are beginning to think about what discovery we may need to take to verify any claims", I remind you that paragraph 8 of the agreement states that Epstein "waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between the identified individual and Epstein, so long as the identified individual elects to proceed exclusively under 18 USC s 2255 and agrees to waive any other claim for damages ... ." That being said, you are correct in assuming that we do not want to be copied on anything related to discovery. Monitoring the status of the negotiations/litigation by this Office is limited to insuring that the terms and conditions of the Non-Prosecution Agreement are not breached.

From: Jay Lefkowitz [mailto:
Sent: Tuesday, October 30, 2007 4:54 PM
To:
Cc: (USAFLS)
Subject: Re: Epstein

Thanks

[ ]

I haven't heard anything from Judge Davis. I assume he is still willing to take on the role you asked him to take on, but can you please let me know if that is not the case?

Also, we are beginning to think about what discovery we may need to take to verify any claims. I am assuming that your office does not want to be copied on any subpoenas or anything related to discovery. But please let me know if that is an incorrect assumption.

Thanks - Jay

Original Message-----
From:
Sent: 10/30/2007 02:42 PM AST
To: Jay Lefkowitz
CC: (USAFLS)"
Subject: Epstein

Jay,

Here is an executed version of the addendum. Please Fed Ex the original signature pages to me. Thanks,

EFTA00013521

<<epstein addendum 10 30.pdf>>

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EFTA00013522