EFTA00019565

< :.; Alex Conlon < >; Rachel Harris

New York, New York low: (W) (m) ■

Whenever you have a chance, please let us know if you are available to meet on any of the following dates: December 18, January 6, 7, 8, 10, and 16. If none of those dates work, please provide alternate dates and times, and we will try to coordinate schedules and set something up. Looking forward to hearing your thoughts. Regards, Jordy, Ken and Camille

otherwise intractable problem: the program should add a fourth administrator, selected by plaintiffs, and require that all claims decisions are rendered unanimously.

We look forward to discussing this proposal with you. We suggest arranging a time to do so before the protocol is finalized, since it will be important to incorporate the input of an additional administrator into that process. We will, of course, also raise this with the Estate. Roberta ("Robbie") Kaplan, Esq. Kaplan Hecker & Fink L.I.P 350 Fifth Avenue I Suite 7110 New York. New York imi8

Thank you for reaching out to us. We are writing back on behalf of (and copying) certain plaintiffs' counsel who appeared at an SDNY conference last week for sexual abuse survivors of Epstein. We intend no disrespect to you and your colleagues, but, candidly, we have serious concerns about the Estate's purported decision to impose a non-binding settlement process on our clients unilaterally. All of these women still struggle today because of the profound manipulation, objectification, and physical abuse to which Jeffrey Epstein subjected each of them. Regardless of your own significant experience and good intentions, the fact that the Estate chose an administrator without any participation, input, or consideration of our clients' views or wishes is disconcerting, particularly given the personal nature of the claims at issue. We are, of course, interested above all in advancing our clients' interests. As you may know, at a status conference last week in the Southern District, Magistrate Judge Freeman instructed counsel for the Estate and counsel for plaintiffs to engage in good faith discussions about any proposed claim resolution program. We have already directed a request for information on the proposed program to Bennet Moskowitz, and look forward to his response and to a productive dialogue with counsel ahead of the Jan. 10, 2019 deadline set by the Magistrate for an update on the status of our negotiations. Assuming that our settlement discussions with Defendants progress, we look forward to working with you at the appropriate time to design an effective and appropriate settlement program. Roberta ("Robbie") Kaplan, Esq. Kaplan Hecker & Fink I.I.P 350 Fifth Avenue I Suite 7110 New York, New York tott8

Jordy This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client work product or other applicable legal privilege. If you are not the intended recipient of the email. please be aware that any unauthorized review. use. disclosure, dissemination. distribution, or copying of this communication, or any of its contents. is strictly prohibited. If you have received this communication in error. please notify the sender immediately and destroy all copies of the message from your computer system. Thank you. This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client. work product or other applicable legal privilege. If you are not the intended recipient of the email. please be aware that any unauthorized review. use. disclosure. dissemination. distribution. or copying of this communication. or any of its contents. is strictly prohibited. If you have received this communication in error. please notify the sender immediately and destroy all copies of the message from your computer system. Thank you. This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client work product or other applicable legal privilege. If you are not the intended recipient of the email. please be aware that any unauthorized review. use. disclosure, dissemination. distribution. or copying of this communication. or any of its contents. is strict)), prohibited. If you have received this communication in error. please notify the sender immediately and destroy all copies of the message from your computer system. Thank you. This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client work product or other applicable legal privilege. If you are not the intended recipient of the email. please be aware that any unauthorized review. use. disclosure. dissemination. distribution, or copying of this communication. or any of its contents. is strict)), prohibited. If you have received this communication in error. please notify the sender immediately and destroy all copies of the message from your computer system. Thank you.