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Ror BUCK HOWARD M. SREBNICK SCOTT A. KORNSPAN Warr A. STUMP? MARIA NrrintA JACKIE PERCZEK MARK A.J. SHAPIRO JARED LOPEZ BLACK SREBNICK KORNSPAN & STUMPF =PA - May 18, 2010 VIA EMAIL AND U.S. MAIL Esq. Assistant United States Attorney United States Attorney's Office Southern District of Florida 500 South Australian Avenue Suite 400 West Palm Beach, Florida 33401 RE: Jeffrey Epstein Dear Counsel: JESSICA FONSECA-NADF.R KATHLEEN P. PHILLIPS AARON ANTHON MARCOS BF.ATON, JR. JENIPER J. SOUUKIAS NOAH Fox JOSHUA SHORE E-Mail: RBloclogiRoyBlack.com sq. United Attorney 99 N.E. 4th Street Miami, FL 33132 Esq. Assistant United States Attorney 99 N.E. 4th Street Miami, FL 33132 We received notice this morning that Podhurst Orseck, P.A. has filed a civil complaint seeking over $2,000,000 in addition to the $526,000 they have already been paid by Jeffrey Epstein for their work as attorney representatives. As we communicated to you during our February 3, 2010 meeting and both before (January 20, 2010) and thereafter (February 18, 2010) by letter, see appended letters, there exists significant differences between fees that Mr. Epstein and his civil counsel believe are within his NPA obligations and additional amounts which the attorney representative is claiming are due. Mr. Epstein has in the past attempted to resolve issues relating to the outstanding invoices through efforts to review the particulars in the unpaid bills with the attorney representative, through settlement discussions with the attorney representative, and through his signing on February 16, 2010 a Special Masters Agreement which would allow a neutral third party to make a binding determination as to what portions of the invoices at issue were reasonable, non- 201 5. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131. Phone: 305.371.6421 Fax: 305.358.2006 • www.RoyBlack.com EFTA00213888 A. Marie Villafitha, Esq. Jeff Sloman, Esq. Bob Senior, Esq. May 18, 2010 Page 2 duplicative, and within Mr. Epstein's NPA-obligations. As a preliminary matter, Mr. Epstein had been requesting, but did not receive, an invoice including billing dating back to the end of 2009 until May 11, 2010 - and even this invoice was without the charges of certain of the outside contractors relied upon by the Podhurst firm. We regret that these efforts did not resolve the matter and that Podhurst Orseck, P.A. elected instead to litigate. Mr. Epstein is today, in response to the lawsuit, filing a motion for authority to place $2,000,000 in an account maintained at the Clerk's Office for the United States District Court pending the results of the litigation. Mr. Epstein has always agreed that he is entirely responsible for any settlement-related fees that are not excessive and will take no litigation position inconsistent with that understanding. However, we have contended as a matter of principle that given the unexpected enormity of the claims for legal fees, that absent additional detail on why the invoiced fees were not duplicative and excessive and outside the ambit of Mr. Epstein's NPA obligations, payment should depend on either an agreement with the attorney representative which never occurred or a determination by a neutral third party. Mr. Epstein will pay whatever amount Judge Gold or any selected Master determine he owes under the NPA. Respectfully submitted, By /wg Black. Srebnick. Kornspan & Stumpf. P.A. EFTA00213889