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Correspondence · June 15, 2009

Defense counsel letter proposing mediation of Epstein fee disputes, June 2009

Letter from one party's attorney to opposing counsel agreeing to appoint a neutral mediator to resolve outstanding fee payment issues in the Epstein matter.Machine-written summary

EFTA00194711

BURMAN, CRITTON, LUTTIER & COLEMAN LLP

J. MICHAEL BURMAN, P.A.¹

GREGORY W. COLEMAN, P.A.

ROBERT D. CRITTON, JR., P.A.¹

BERNARD LEBEDEKER

MARK T. LUTTIER, P.A.

JEFFREY C. PEPIN

MICHAEL J. PIKE

HEATHER McNAMARA RUDA

¹ FLORIDA BOARD CERTIFIED

CIVIL TRIAL LAWYER

A LIMITED LIABILITY PARTNERSHIP

June 15, 2009

ADELQUI J. BENAVENTE

PARALEGAL / INVESTIGATOR

BARBARA M. McKENNA

ASHLIE STOKEN-BARING

BETTY STOKES

PARALEGALS

RITA H. BUDNYK

OF COUNSEL

Sent by E-mail and U.S. Mail
Robert Josefsberg, Esq.
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800 Miami, FL 33130

Re: Epstein Matter

Dear Bob:

On June 8, 2009, Kathy Ezell wrote a letter to me regarding outstanding fee payment issues. At page 3, she stated that she was not adverse to an earlier proposal that had been discussed amongst the parties to rely on a Special Master to resolve outstanding fee-related issues. We agree with Kathy’s “proposal” that we rely on a Special Master to resolve all outstanding fee issues. Let’s work during our Wednesday meeting to select an appropriate Special Master and let’s agree to see whether, in the interim, we can resolve these issues even before they are submitted to the S.M.

Cordially yours,

RDC/clz

Robert D. Critton, Jr.

cc: Jack Goldberger, Esq.

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