Conference Call with Bert Ocariz

some serious concern. 1. Can we get a copy of the indictment (or can you tell me the nature of the crimes against the girls)? Certainly he should not get a copy of any indictment. 2. When will it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the civil case? I don't think he should get the plea agreement either. 3. Is there any cap or other limitation on attorney's fees that the defendant will pay in the civil case? I can’t imagine he would be entitled to anything other than an hourly fee. 4. What is the contemplated procedure for, and timing of, the payment of attorney's fees and costs? In any event, I need to consider these issues carefully and I cannot agree to any of these issues before we speak. I would suggest we plan on talking tomorrow at 12 pm if you are available. none Original Message ----- From: "Villafana, Ann Marie C. (USAFLS)" 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? HOUSE_OVERSIGHT_012632