EFTA00723300

J. MICHAEL BURMAN. RA." 
GREGORY W. COLEMAN. PA 
ROBERT D. CRI770N. JP-. PA ' 
BERNARD A. LEBEDEKER 
MARK T. LW-DM PA. 
JEFFREY C PEPIN 
MICHAEL J. PIKE 
HEATHER MCNAMARA RUDA 
DAVID A. YAREMA 
'FLORIDA WARD CERTIFIED CIVIL TRIAL LAWYER 
2ADMITTED TO PRACTICE IN FLORIDA AND COLORADO 
Sent By E-mail Only 
Jeffrey Epstein 
Re: 
B.B. v. Epstein 
Dear Jeffrey: 
BURMAN. CRITTON 
LUTT1ER &COLEMAN, LLP 
YOUR 
TRUSTED 
ADVOCATES 
A LIMITED LIABILITY PARTNERSHIP 
December 11, 2009 
ADELQVI J. SENAVENTE 
PARALEGAL/INVESTIGATOR 
JESSICA CADWELL 
BOBBIE M. MCKENNA 
ASHLIE STOKEN- BARING 
BETTY STOKES 
PARALEGALS 
RITA H. BUDNYK 
OF COuNSIL 
EDWARD M. RICCI 
fat =TR 
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. 
RDC/clz 
cc: 
Jack Goldberger, Esq. 
Darren Indyke, Esq. 
Michael J. Pike, Esq. 
Cordially yours, 
41164 (1/49 . &AK k 
Robert D. Calton, Jr. ( 
303 
BANYAN BOULEVARD • SUITE 400 
• 
WEST PALM BEACH. FL 33401 
• 
PHONE: 561.842-2820 
• 
FAX: 561-844-6929 
• 
WWW.BCLCLAW.COM 
EFTA00723300

J. MICHAEL BURMAN. PA" 
GREGORY W. COLEMAN. PA 
ROBERT D. CRITTON. JR.. PA' 
BERNARD A. LUSEDEKER 
MARK T. LIMIER. PA 
JEFFREY C. PENN 
MICHAEL J. PIKE 
HEATHER MCNAMARA RUDA 
DAVID A. YARCMA 
'FLORIDA BOARD MIMED CIVIL TIDAL LAWYER 
2ADMITTED TO PRACTICE IN FLORIDA AND COLORADO 
BURMAN. CRITTON 
LUTTIER&COLEMAN.Lu> 
YOUR TRUSTED 
ADVOCATES 
A LIMITED LIABILITY PARTNERSHIP 
December 11, 2009 
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 
ADELQW J. BENAVENTE 
PARALEGAL/INVESTIGATOR. 
JESSICA CADWELL 
BOBBIE M. MCKENNA 
ASHLIE STOKEN-BARING 
BETTY STOKES 
PARALEGALS 
RJTA H. BUDNYK 
Of COUNSEL 
EDWARD M. RICO 
SPECIAL CONSUMER 
JUSTICE COUNSEL 
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, 
4  0/-tur LC.
Robert 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