Memorandum

Memorandum Ta Flk ane Dom ei & 2 v. United Statm1 From. Re Call with Date luny A 2019 On lute II. 2019. and I had atall with which beets' *plum "nth 30 minute,. Dua I all as. tallow-up to a call I peresoutly had with in which I ridtrated that we were interested an iSentihniut the victims he nerrmented in the Jeffrey [parr :natter and atte111111IN whether am of those individuals n w d to speak with vs./oat canna: fermiars in the C 'RA s w d hoyatra. reelitously indicated that he had 16 <Iwrta from that matter, he maintained contsn with some at doe c'enorm but had not had tonaiirt with others in many yewn t hat mg the lure 1 I , all. he %lentilred the iolkmenat twits 'dual* a. the who Walled hIMIllt OOPOIN lion with the/mann mane/ 1. 7 A 9 10 Ile 12. 13 14 15 16 3501.014-070 Page I of 2 CT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, EFTA 00091273 EFTA01245421 Of the 15 arguably current clients, was able to reach six individuals to discuss our query. All six of those individuals declined to speak with us. He explained that all of them held the view that they would like to see Jeffrey Epstein prosecuted for his crimes, but that they are not willing to speak with law enforcement or otherwise participate in any criminal or civil litigation because any participation could compromise their anonymity, which is the thing they most highly value. Several victims had what he described as "FTSD," and he said they do not want to discuss the matter with law enforcement, nor do they want family or friends to know about their involvement with Epstein. The victims preferred that speak for them because they do not want Epstein to know more about them or their communication with law enforcement. It is for these reasons as well that they have declined invitation to join and/or support the civil CVRA lawsuit. All 16 of 's clients availed themselves of the processes set forth in the NPA. They retained a, who was selected and paid for through the procedures in the NPA, filed lawsuits pursuant to the federal statute set forth in the NPA, and Epstein did not contest liability as required by the NPA. The only issue was the amount that each of them could or should receive from Epstein. indicated that he and his team would continue to try and reach the remaining individuals and get their input on the outstanding question. We communicated that the deadline for our filing is June 24 and he indicated that he would get back to us before that date to convey any additional communications from the victims that he represents (or represented at that time). We offered to help him locate any victims for whom he did not have current contact information and pass that contact information to him to make his job easier. He said he would let us know if he needed assistance and thanked us for our efforts. 3501.014-070 Page 2 of 2 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00091274 EFTA01245422