EFTA00621916.pdf

STEPHEN G. RINEHART TROUTMAN SANDERS LLP 212.704.630Stelephone 212.704.5957 lanimge TROUTMAN Attorneys an Law The Chrysler Building SANDERS 405 Lexington Avenue New `Wk. New York 10174-0700 INADMISSABLE SETTLEMENT COMMUNICATION October 15, 2012 VIA E-MAIL Vincent S. Green, Esq. NEMECEK COLE 15260 Ventura Boulevard, Suite 920 Sherman Oaks, California 91403-5344 Re: Sitrick and Company / Jeffrey Epstein Dear Vince: I am in receipt of your letter dated October 9, 2012. Four weeks ago, Mr. Epstein made a good faith offer to pay Mr. Sitrick's firm a substantial sum of $25,000 to resolve this matter amicably, notwithstanding the fact that the parties never reached an agreement regarding the cost and scope of your client's services. After waiting a full month's time, your client refused to respond other than to set an arbitrary five-thy deadline for Mr. Epstein to pay even more money if he does not want Mr. Sitrick's firm to publicly file a complaint containing privileged and confidential information about Mr. Epstein. Your artificial deadline is unreasonable and unproductive, and your client's threat to disclose privileged and confidential information in a lawsuit is manifestly inappropriate. Mr. Epstein would regard the filing you contemplate as a most serious violation of his attorney-client and work-product privileges, as well as other rights. While no written retainer agreement was entered into in 2011, the hiring of Sitrick by Mr. Epstein's counsel gave rise to a duty on Sitrick's part to maintain the confidentiality of its discussions with counsel and information exchanged with counsel. Mr. Sitrick's filing of a lawsuit would only serve to make public Mr. Sitrick's improper attempt to obtain money from a client by threatening to breach the client's confidences. Should Sitrick file its complaint against Mr. Epstein, Mr. Epstein will pursue all of his remedies in this matter, including without limitation all appropriate equitable and monetary relief against Sitrick for violations of Mr. Epstein's privileges and rights. Mr. Epstein's pursuit of such remedies would undoubtedly expose to public scrutiny Mr. Sitrick's inappropriate threat to ATLANTA BEIJING CHICAGO HONG KONG NEW YORK NORFOLK ORANGE COUNTY PORTLAND RALEIGH RICHMOND SAN DIEGO SHANGHAI TYSONS CORNER VIRGINIA BEACH WASHINGTON, DC EFTA00621916 TROUTMAN SANDERS Vincent S. Green October 15, 2012 Page 2 disclose his client's confidences. We hope this will not be necessary and that your client will provide a reasonable response to the offer Mr. Epstein made four weeks ago. Very truly yours, Stephen G. Rinehart EFTA00621917