EFTA00723300.pdf

BURMAN. CRITTON LUTT1ER &COLEMAN, LLP ADVOCATES YOUR TRUSTED A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN. RA." ADELQVI J. SENAVENTE GREGORY W. COLEMAN. PA PARALEGAL/INVESTIGATOR ROBERT D. CRI770N. JP-. PA ' JESSICA CADWELL BERNARD A. LEBEDEKER BOBBIE M. MCKENNA MARK T. LW-DM PA. ASHLIE STOKEN- BARING JEFFREY C PEPIN BETTY STOKES MICHAEL J. PIKE PARALEGALS HEATHER MCNAMARA RUDA December 11, 2009 RITA H. BUDNYK OF COuNSIL DAVID A. YAREMA EDWARD M. RICCI 'FLORIDA WARD CERTIFIED CIVIL TRIAL LAWYER 2ADMITTED TO PRACTICE IN FLORIDA AND COLORADO fat=TR Sent By E-mail Only Jeffrey Epstein Re: B.B. v. Epstein Dear Jeffrey: I know Connie sent you Mr. Kuvin's December 4, 2009 letter and his Motion for Sanctions pursuant to §57.105 Fla. Stat. directed to you and my law firm. The applicable statute allows for sanctions to a prevailing party to the extent any claim or defense made during the course of the civil proceeding or action is determined by the court to be not supported by the material facts necessary to support the claim or defense or not be supported by the application of then existing law to those facts. I believe the motion would not have been filed unless we believed there was a good faith belief for its filing against Mr. Kuvin. As well, I am not certain that the motion which we filed would be deemed to be a "claim or defense" which would be governed by a §57.105 Fla. Stat. However, I want you to understand the risk. I do not intend to do the research, unless you direct me to do so, as to whether or not a motion falls within the claim or defense language of the statute. If you wish us to withdraw the motion which we filed directed to Mr. Kuvin, we will do so. Let me know before Christmas day, otherwise the motion will stand. Cordially yours, 41164 (1 4/9 . &AK k Robert D. Calton, Jr. ( RDC/clz cc: Jack Goldberger, Esq. Darren Indyke, Esq. Michael J. Pike, Esq. 303 BANYAN BOULEVARD • SUITE 400 • WEST PALM BEACH. FL33401 WWW.BCLCLAW.COM • 561-844-6929 PHONE: • • 561.842-2820 FAX: EFTA00723300  BURMAN. CRITTON LUTTIER&COLEMAN.Lu> YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN. PA" ADELQW J. BENAVENTE GREGORY W. COLEMAN. PA PARALEGAL/INVESTIGATOR. ROBERT D. CRITTON. JR.. PA' JESSICA CADWELL BERNARD A. LUSEDEKER BOBBIE M. MCKENNA MARK T. LIMIER. PA ASHLIE STOKEN-BARING JEFFREY C. PENN BETTY STOKES MICHAEL J. PIKE PARALEGALS HEATHER MCNAMARA RUDA RJTA H. BUDNYK DAVID A. YARCMA Of COUNSEL December 11, 2009 EDWARD M. RICO 'FLORIDA BOARD MIMED CIVIL TIDAL LAWYER SPECIAL CONSUMER 2ADMITTED TO PRACTICE IN FLORIDA AND COLORADO JUSTICE COUNSEL Sent by Fax and U.S. Mail John G. White, Ill, Esq. Richman Greer Weil Brumbaugh Mirabito & Christensen 250 Australian Avenue, South, Suite 1504 West Palm Beach, FL 33401 Re: Special Master Fee Dispute Hearing between Jeffrey Epstein and the Podhurst Orseck Firm Dear Jay: As per our conversation approximately four to six weeks ago, you agreed to serve as a fee expert in the above-styled matter. Our firm will be responsible for your fee. Initially, Sid Stubbs was going to be the special master, but we are working on someone new. Sid decided that he had a conflict in that the Town of Palm Beach is involved in some of the discovery issues I will keep you advised. At the current time, I am having a spreadsheet prepared for the approximately $2 million worth of fees that Bob Josefsberg and his firm were seeking from Epstein. The spreadsheet should be of great assistance in attempting to determine reasonable value of the services rendered. Cordially yours, 4Robert 0/ -tur LC. D. Critton, Jr. RDC/clz 303 BANYAN BOULEVARD • SUITE 4O0 • WEST PALM BEACH. FL 33401 • PHONE: AX: 561-8446929 • MAIL WWVV. BC LCLAW.COM EFTA00723301