# Profoundd archive — Epstein Files # Bates number: EFTA00723091 # Title: 04-AGREEMENT FOR SPECIAL MASTER # Dataset: 9 # Pages: 6 # Images: 6 detected # Tags: epstein, doj, dataset-9, image-described # Source PDF: https://profoundd.com/epstein-docs/EFTA00723091/download # Doc viewer: https://profoundd.com/epstein-docs/EFTA00723091 # # Text below is what Profoundd has extracted from the source PDF. # 'ocr-enriched' tag means OCR was applied to scan-only pages. # Image descriptions are AI-generated factual captions (llava:13b). #---------------------------------------------------------------------- === SUMMARY === -RD c :k__ 04-AGREEMENT FOR SPECIAL MASTER TO DETERMINE AMOUNT OF ATTORNEYS' FEES AND COSTS This Agreement is made this day of , 2009, by and between the "First Party," Jeffrey Epstein ("Epstein"), by and through his attorneys, Burman, Critton, Luther & Coleman, LLP, and the "Second Party,", defined as the attorney representative, Robert C. Josefsberg of the law firm Podhurst Orseck, P.A. ("Podhurst Orseck" ). WHEREAS, there exists an agreement between the United States Attorney's Office ("USAO" === EXTRACTED TEXT === -RD c :k__ 04-AGREEMENT FOR SPECIAL MASTER TO DETERMINE AMOUNT OF ATTORNEYS' FEES AND COSTS This Agreement is made this day of , 2009, by and between the "First Party," Jeffrey Epstein ("Epstein"), by and through his attorneys, Burman, Critton, Luther & Coleman, LLP, and the "Second Party,", defined as the attorney representative, Robert C. Josefsberg of the law firm Podhurst Orseck, P.A. ("Podhurst Orseck" ). WHEREAS, there exists an agreement between the United States Attorney's Office ("USAO") and Epstein known as the Non-Prosecution Agreement dated September 24, 2007 and Addendum dated October 30, 2007 ("collectively referred to as the NPA") (Exhibit "A"). The NPA provides for the appointment of an attorney representative to potentially represent various individuals who were identified and listed by the USAO as victims who might pursue claims against Epstein. A copy of this or any other list of identified individuals was not provided to Epstein as of the date, September 24, 2007, when he signed the NPA, nor on October 30, 2007 when the Addendum was executed. It was first disclosed to Epstein, instead, at the time of his state plea and sentencing on June 30, 2008. The names of individuals on this list represented by Robert C Josefsberg are identified as Composite Exhibit "B" hereto. rWHEREAS, Epstein has an obligation to pay fees and costs to t attorney representative pursuant to the NPA. r, who will 0 °- cSr/ execute the re wing Thereafter, a copy r,i7 of the executed Con aster shall be provided (11.o. 41 fi immedigetrtirtlIC EFTA00723091 WHEREAS, Robert C. Josefsberg of the law firm Podhurst Orseck, P.A. was appointed as the attorney representative on or about September 2008 by the Honorable Edward B. Davis. Robert C. Josefsberg, as lead counsel, began performing his responsibilities immediately thereafter, and, as a result, Podhurst Orseck has incurred attorneys' fees and costs. WHEREAS, some of the attorney representative's bills for claimed fees and costs relating to the representation of the designated victims have been submitted for payment to Epstein through his counsel. $526,466.15 of these claimed fees and costs have been paid by Epstein. WHEREAS, Podhurst Orseck and Epstein disagree as to the amount of fees and costs due and owing and whether certain fees and costs (paid to date and other amounts not paid) are Epstein's responsibility based upon the NPA and correspondence that was exchanged between the USAO, Epstein, and others. WHEREAS, the Parties have jointly selected Sidney A. Stubbs, Esq. to serve as Special Master to make a binding determination with regard to issues associated with past, present, and future disputes and disagreements (unless a court has that jurisdiction) relating to the amount of attorneys' fees and costs due the attorney representative. The Parties agree that this Agreement and special master process is being done pursuant to the NPA. The Parties therefore agree as follows: 1. Sidney A. Stubbs, Esq. shall serve as Special Master to conduct hearings and/or proceedings, obtain documents, and/or resolve issues he deems necessary and pertinent to the determination of the amount of attorneys' fees and costs due and owing Podhurst Orseck by Epstein, pursuant to the NPA, including monies paid in the past, present, and future (unless a court has that jurisdiction). If the Parties cannot agree, Mr. Stubbs' decision shall be written in the form of an order. 2. No Party is required to present expert testimony. However, if expert testimony is presented, it shall be considered by the Special Master, as it would be in federal EFTA00723092 court. 3. The Parties may provide legal memoranda, exhibits, expert witnesses, and any other evidence to support their respective positions. 4. The Federal Rules of Evidence shall govern any proceeding(s). The proceeding(s) shall be deemed confidential, and subject to FRE 408, 410 and all other applicable rules. 5. The decisions made by Sidney A. Stubbs, Esq. shall be final and binding on these Parties, without the ability of any Party to appeal such decisions. Any orcler(s) issued by Sidney A. Stubbs, Esq. awarding fees and costs shall be paid by Epstein within twenty (20) days of the issuance of the order(s). 6. Mr. Stubbs shall be paid his hourly rate upon submission of his bills to counsel for all work, including preparation, research, hearings, and orders, as well as any out-of- pocket expenses. Mr. Stubbs' fees and costs shall be apportioned based upon the amount sought and awarded, i.e. if Podhurst Orseck, P.A. is awarded 50% of the amount sought, Epstein shall be responsible for 50% of Mr. Stubbs' bill. First Party: Second Party: By: Jeffrey Epstein By: ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 Burman, Critton, Luttier & Coleman, LLP 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 Attorneys for Jeffrey Epstein By: ROBERT JOSEFSBERG, ESQ. Florida Bar No. 040856 Podhurst Orseck, P.A. 25 W. Flagler Street, Suite 800 Miami, FL 33130 Attorney Representative EFTA00723093 61-AGREEMENT FOR SPECIAL MASTER TO DETERMINE AMOUNT OF ATTORNEYS' FEES AND COSTS This Agreement is made this day of 10-g•O1 OITA