EFTA00793968.pdf

l ila LINK& ROCKENBACH, PA CIVIL TRIAL & APPELLATE LAW 1555 Palm Beach Lakes, Blvd., Suite 930 West Palm Beach, FL 33401 TEL• May 17, 2018 VIA E-MAIL Jeffrey Epstein 610 Red Hook Quarter, 133 St. Thomas, U.S. Virgin Islands 00802 RE: Jean-Luc Brunel and MC2 Model & Talent Miami, LLC v. Jeffrey Epstein and Tyler McDonald d/b/a Yi.org 111h Judicial Circuit Court, Miami-Dade County Case No. 14-21348-CA-01 Dear Jeffrey: Thank you for retaining Link & Rockenbach, PA (the "Finn") as your counsel in the above- referenced matter. We are writing to confirm the terms of the Firm's representation. In addition, the purpose of this letter is to explain our fees and billing procedures and other aspects of our work. 1. Scone of Representation. We are undertaking to represent you in defense of the claims brought by Jean-Luc Brunel and his company, MC2 Model & Talent Miami, LLC. This work will include traditional litigation activities to analyze and defend the claim, including discussing strategies and a settlement position, if appropriate. We are not undertaking to provide advice on criminal, personal estate or tax planning matters, financial planning, domestic relations, asset protection, judgment avoidance techniques or possible claims against other professionals who may be responsible for losses. In addition, the Firm does not give tax advice and has not undertaken to advise you as to the tax consequences of a recovery made in connection with the litigation. The Firm suggests that you seek independent tax advice from attorneys or accountants who are familiar with your tax situation and who are qualified in tax matters. It will be your responsibility to make any tax payments or filings necessitated by the resolution of your claim. We are also not undertaking to provide advice about insurance coverage issues or to investigate the availability of insurance to cover this claim or parties from whom contribution, indemnity or subrogation claims may be asserted. The Firm expects to share information generated in the litigation and take direction from your General Counsel (Darren K. Indyke, PLLC). You agree that the Finn may take direction from and discuss matters with your General Counsel. 2. Rates and Billing; Staffing. My rate is $750 per hour and my partner Kara Rockenbach's rate is $600 per hour. Our associates range from $225 to $475 per hour. Time spent by any law clerk or pare-professional is currently charged EFTA00793968 Jeffrey Epstein May 17, 2018 Page 2 at $225 per hour. Hourly rates may be adjusted from time to time (generally once a year) and may change during the course of our representation. Our attorneys have varying areas of expertise and amounts of experience and different billing rates. In staffing this matter, our goal will be to render the best legal services we can in the most efficient manner. To accomplish this goal we may assign different members of our team to perform various services on different matters or different aspects of the same matter. For example, if another lawyer has worked on a particular issue before, I may ask him or her to undertake a specific task that does not require comprehensive knowledge of the case. We will also bill for disbursements and other services. The disbursements include such things as filing fees, certified or registered mail, postage, telephone, copying costs (100 per page), teleconference call charges, courier services (at local commercial rate), expedited mail delivery (e.g., Federal Express), travel and meal expenses, and the fees and expenses of investigators and experts, if needed. Where possible, we will have vendors bill you directly for such costs or we will send you the bill and request that you pay the vendor directly. These disbursements are billed on an out-of-pocket basis (or at the rates described in parenthesis above) and will be included on each invoice. We also charge for certain additional services rendered by the Firm, including computerized database access and usage (e.g., Westlaw and other databases) at the suppliers' published rates. We bill fees and other services on a monthly basis and payment is due within ten days of your receipt of a statement. You agree to carefully read all billing statements and promptly notify us, in writing, of any claimed errors or discrepancies, within five days from the date of statement. If we do not hear from you in writing, it is presumed that you agree with the correctness, accuracy and fairness of the billing statement. Based on our past relationship, we are not requiring a fee or cost retainer for this matter at this time. 3. Termination. If at any time you want to terminate our services, please notify me in writing. Likewise, if at any time we find that we are unable to continue representing you, we will notify you in writing. We reserve the right to terminate our representation if you fail to comply with the terms of this fee agreement, if we reach a disagreement over the strategy of the case, or as allowed by the Florida Rules of Professional Conduct, and you agree not to contest our withdrawal from any court or administrative proceeding in such an event. As soon as possible after any such termination, a final statement will be prepared and sent to you. 4. Fact Gathering. Use of Professional Judgment. We will perform the legal services which we have agreed to undertake on your behalf in a professional manner and we will keep you informed of all material developments in a reasonable and timely manner. To enable us to do this, you agree to disclose such facts as are requested and as are reasonably necessary for us to perfonn the services for which you have retained us. LINK & ROCKENBACH. PA EFTA00793969 Jeffrey Epstein May 17, 2018 Page 3 Although we may give you our professional judgment regarding a matter, as to the likelihood of a favorable outcome on a particular case, the amount ofa potential recovery, what a clause in a document says, or whether a particular contract or negotiation will result in the desired outcome, we are never able to guarantee any of these. What we will endeavor to do is to give you our best judgment in light of the law and the particular facts made known to us. 5. Electronic Communication. You authorize us to use e-mail, cell phones and other wireless devices in place ofmore traditional methods to communicate with you about this representation. You acknowledge, however, that there is a risk that third parties may improperly intercept these communications. We will, of course, be sensitive to security considerations and take reasonable precautions against the inadvertent disclosure of confidential information to others. You acknowledge, however, that we cannot and do not insure against the risk of such intrusions. 6. Conclusion. After you have had the opportunity to review this proposed fee agreement, please feel free to call me with any comments or questions which you have. If it meets with your approval, kindly sign where indicated below to evidence your agreement with the matters set forth herein and return it to me. We look forward to working with you on this ma V Scott J. SJL/tic I hereby accept the legal representation by Link & Rockenbach, PA as described above. JEFFREY EPSTEIN Date: - LINK&ROCKENBACH,PA EFTA00793970