EPSTEIN
page 4 / 431 . OCR, unverified
instances of sexual abuse involving the Client and Jeffrey Epstein, Ghislaine Maxwell. and/or any
others participating in or in any way connected to Jeffrey Epstein's sex trafficking insofar as those
causes of action or claims arc against or involve the Federal Bureau of Investigation, the Department
of Justice, and/or other city, state, and/or federal government entities' failure to investigate Jeffrey
Epstein and his co-conspirators.. This includes all causes of action or claims—including criminal,
civil, and other—arising from these allegations or instances, whether in connedion with one or more
individual or multi-party case(s) or class aCtion(s). These causes of adion and claims are defined
collectively as the "Claims."
The Client has not retained any other attomey(s) in connection with the Claims. The Client
previously retained counsel to pursue claims against the Epstein estate, JP Morgan/Deutsche Bank.
and perhaps others relating to Epstein's sex trafficking operation. The retention of those attorneys
has either been concluded or do not encompass/apply to the Claims.
Although we arc not currently aware of claims relating to your image(s), in the event that such claims
exist, the Client also hires the Firm to provide legal services concerning all past, present, and future
legal causes of action or claims associated with, corollary to, or arising from all photographic, digital,
film or any other image(s) or likeness of the Client located anywhere worldwide. This includes all
legal causes of adion—including copyright, tort. equity, and civil—arising from the creation,
distribution, and possession of the Client's child sex abuse material ("CSAM"), images, videos, or
likeness by any person, corporation, or other public, private, or nonprofit entity or syndicate
anywhere in the world.
The phrase "legal causes of adion" also includes, if applicable, all restitution requested. ordered, or
paid which is associated with, corollary to, or arising from any actual or potential criminal cause of
action in which the Client is, could, or might be named a victim. These causes of adion and claims
are also included in the "Claims."
I
The Firm will provide those legal services reasonably required to represent the Client including fad
and law investipation. draftinp nleadinps. settlement efforts. and other services un to and includinp
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EFTA00037141
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parking, mileage, transportation, airfare, meals and incidentals, and hotel costs; investigation
expenses; consultants, expert witness, professional mediator, arbitrator and/or special master fees;
postage (at cost); and computerized legal research. Expenses also include the cost of retaining
specialized legal counsel necessary for the Firm to pursue the Client's Claims including, for example,
bankruptcy counsel and trusts and estates counsel.
Expenses also include the cost of investigators, consultants, and expert witnesses. The Firm will seleU
the expert witnesses, consultants, and investigators, and notify the Client of the individuals or firms
hired and, where feasible, an estimation of their charges.
If there are multiple ongoing and potential future cases concerning the Claims, the Client
acknowledges that the Firm may retain some or all of the Amount Recovered in one case in order to
pay past and current Expenses as well as retaining funds for future Expenses.
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diWARDIDEATISMINEFIXELISD515, LITIGATION EXPENSES.
SANCTIONS
Notwithstanding any other provision in this Agreement whether express or implied, the Client agrees
that any award of attorney's fees or Expenses, whether by settlement, mediation, arbitration award,
judgment, or otherwise, belongs exclusively to the Firm. The receipt of awarded attorney's fees or
Expenses will be credited against the total amount owed by the Client under this Agreement.
Therefore, the Client agrees that the attorney's fees and Expenses payable to the Firm pursuant to this
Agreement shall be the greater of: (i) the amount otherwise owed to the Firm under this Agreement;
or (ii) the amount of the awarded attorney's fees and Expenses.
The Client agrees that any attorney's fees or Expenses awarded as part of discovery or other
extraordinary motion praaicc or sanaions proceedings is not considered part of the Amount
Recovered and belongs exclusively to the Firm as additional compensation for extraordinary time and
effort.
NOTE: If an award of attorney's fees or Expenses is received or sought on the Client's behalf, the
Client understands that the amount awarded is the amount the court, mediator, or arbitrator believes
the party is entitled to recover. This does not determine the amount of attorney's fees or Expenses the