EFTA00598935.pdf

Podhurst Orseck TRIAL & APPELLATE LAWYERS Aaron S. Podhurst Robert Orseck (1934-1978) Robert C. Josefsberg Joel D. Eaton Walter H. Beckham, Jr. Steven C. Marks Karen Podhurst Dern Victor M. Diaz. Jr. Of Counsel Katherine W. Ezell Stephen F. Rosenthal Ricardo M. Martinez-Cid Ramon A. Pasco Alexander T. Rundlet John Gravante, III Carolina Maharbiz March 12, 2010 VIA E-MAIL AND FACSIMILE Robert Critton, Esq. Burman, Critton, Luther & Coleman Re: Jeffrey Epstein - Issue that Arose At Today's Meeting Our File No.: Dear Bob and Michael: At today's meeting Jeffery Epstein raised an issue of my breaking my word. In response I am attaching a copy of your letter of October 19, 2009. Since my integrity appears to be at issue, I would appreciate your showing this letter to your client, Jeffrey Epstein. Very truly yours, RCJ/bp Robert C. J sefsberg Enclosure cc: J. Michael Burman, Esq. l'odhu Miami FL 33130 Miami • Fort Lauderdale www.podhurstrom EFTA00598935  <fr e_.rn et" l& I BURMAN, CRITTON C oe (.) 4a) LUTTIER &COLEMAN, YOUR TRUSTED LLP ADVOCATES A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN. PA.I-2 ADELOSII J. BENAVENTE GREGORY W. COLEMAN. PA PARALEGAVIN.TESTiC.ATENt ROBERT 0 CRITTON. JR. PA I JESSICA CADWELL BERNARD A. LEBEDEKER BOBBIE M. MCKENNA MARK T. LUTTIER. P.A. ASH LIE STOKEN•BARBNc JEFFREY C. PEPIN BITTY STOKES MICHAEL J. PIKE PARALEGALS HEATHER MCNAmARA RUDA RJTA H. BUDNYK DAVID A. YAREMA 0 COUNSEL October 19, 2009 EDWARD M. RICtI IRONDA WARD CERTIFIED CIVIL TRIAL LAMM A. Sncim QvionnumrR 'ADMIRED 10 PRACTICE IN fLOIUDA AND COLORADO IUSTICI COUNSEL Sent by E-Mail Only Robert Josefsberg, Esq. Podhurst Orseck P.A. Miami, FL 33130 Re: Settlement Negotiations Dear Bob: As per our discussion on Se tember 25u1 followed by your e-mail and my e-mail, we are resolvin nd all of your other clients, except for We have also agreed as part of the above settlement to certain additional terms, although it will not be in any of the settlement documents in that the releases and/or settlement agreements are specific to the individuals. We agreed that you would join us (agree that the court has jurisdiction to consider the action, but not necessarily concede Jeffrey Epstein is correct as to points which might be plead) in any declaratory action that is filed. These issues may include: 1. Which version (year) of §2255 is applicable based on the facts alleged; whether the minimum amount of damages under §2255 is S50,000 versus $150,000; whether multiple predicate acts can be plead; whether multiple occurrences (violations) can be plead, whether a plaintiff is entitled to only a single recovery; whether Jeffrey Epstein can test the veracity of a plaintiff; and whether Mr. Epstein can assert statutes of limitation as an affirmative defense. We had also a i I would not represent any additional females who are on the list, other tha whom your firm currently represents. In hindsight, this appears to be an unreasonable request, and therefore that is no longer a condition. We expect that you will continue to represent Ms. Hall and may represent other WEST PALM BEACH. FL 33401 • PHONE WWW.BCLCLAW.COM EFTA00598936 October 19, 2009 Page 2 individuals whom you indicated you had previously contacted. We also would agree to a further tolling agreement for Ms. Hall. We would however expect, that you would not run out and in any way solicit clients Finally, I would expect that neither you nor any other lawyers or staff would share any details of our negotiations or settlements, agreed? If the above is acceptable, please confirm in writing in that these terms were part of our overall settlement negotiations and were and are material to resolution. Cordially 7 rs, Rob D. Critton, Jr. RDC/clz cc: by e-mail Jack Goldberger, Esq. Katherine Ezell, Esq. EFTA00598937