Podhurst Orseck

Podhurst Orseck TRIAL & APPELLATE LAWYERS Aaron S. Podhurst Robert C. Josefsberg Joel D. Eaton Steven C. Marks Victor M. Diaz. Jr. 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, Luttier & Coleman 303 Banyan Blvd., Suite 400 West Palm Beach, FL 33401 Robert Orseck (1934-1978) Walter H. Beckham, Jr. Karen Podhurst Dern Of Counsel Re: Jeffrey Epstein - Issue that Arose At Today's Meeting Our File No.: 30608 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. Podhurst Orseck, PA. 25 West Flagier Street, Suite 800, Miami, FL 33130 Miami 305.358.2800 Fax 305358.2382 • Fort Lauderdale 954.463.4346 www.podhurstcom EFTA00598938 A\ we-2 fri71/4 e-rn et BURMAN, CRITTON C 1/44-0 LUTTIER&COLEMAN, LLP 0614.--i-t - YOUR TRUSTED ADVOCATES 4.••• A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN. RAP GREGORY W. COLEMAN. PA ROBERT D. CRITTON. JR.. PA I BERNARD A. LEBEDEKER MARK T. LUTTIER. PA JEFFREY C. PEPIN MICHAEL J. PIKE HEATHER MCNAMARA RUDA DAVID A. YAREMA IFLORIDA Daum CWTIFIID MIL HUM LAWYER zAoHirrED TO Enema IN Fusion AND CotORADO Sent by E-Mail Only Robert Josefsberg, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 October 19, 2009 Met- g G. relte C...-; 0 ADELOLII J. MN NTE PARMEGAL/INVESTIGATOIL JESSICA CADwELL BOBBIE M. MCKENNA ASHER MAIN -BARING BETTY STOKES PARALEGALS RJTA H. BUDNYK OF COUNSEL EDWARD M. RiOZI Mitigtffirt Re: Settlement Negotiations Dear Bob: As per our discussion on September 25th followed by your e-mail and my e-mail, ' Jane Doe 101, Jane Doe 102 and 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 reed that ou would not represent any additional females who are on the list, other than vhom your firm currently represents. In hindsight, this appears to be an unreasona e request, and therefore that is no longer a condition. We expect that you will continue to represent Ms. Hall and may represent other 303 BANYAN BOULEVARD • SUITE 400 • WEST PALM BEACH. FL 33401 • PHONE: 561-842-282O • FAX: 561-844-6929 • MAIL.SCLCLAW.COM WWW.BCLCLAW.COM EFTA00598939 October 19, 2009 Page 2 individuals whom you indicated y previously contacted. We also would agree to a further tolling agreement for Ms. 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. EFTA00598940