EFTA00743010.pdf

From: Jeffrey Epstein <jeevacationggmail.com> To: ' > Subject: Fwd: Date: Fri, 04 Dec 2009 04:38:37 +0000 Forwarded message From: Robert D. Critton Date: Thu, Dec 3, 2009 at 6:10 PM Subject: To: Jeffrey Epstein <jecvacation:itomail.com> Cc: Darren Ind ke , Martin Weinberg >, "Michael J. Pike" This is the semi final version. So need comments to finalize. However I think that berger and adler should not yet be sued. There are not enough facts at his time to support and I think a 57.105 motion will be filed which places the filing lawfirm and je at risk for sanctions and potential suit. je, you may not care, but I do as to my firm. I also now have given a copy of the complt to my other partners. The unanimous opinion is that we are material witnesses to the acts alleged, more so than je and therefore have an immediate conflict; my partner coleman has that issue in another case currently; he also is on the bd of governors for the fia bar and sits on the big grievance comm. And is dealing w roth and others and thinks we are also conflicted there as well. So I will finish the complt so that it can be filed on Monday, but some other firm will need to file. Think you said roy 's civil attys could do. He obviously feels strongly about filing from what I have seen and is familiar w the facts. I will coordinate, let me know, bob Robert D. Critton, Jr. Burman, Critton, Luttier & Coleman, LLP 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 EFTA00743010 The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. EFTA00743011