J. MICHAEL BURMAN. P.A." GREGORY W. COLEMAN, PA ROBERT D. CRITTON. JR.. PA' BERNARD A. LEBEDEKER MARK T. LUTTI EEL PA JEFFREY C. PENN MICHAEL I. PIKE HEATHER MCNAMARA RUDA DAVID A. YAREMA 'FLORIDA BOARD CERTIFIED CIVIL TRIAL LAWYER 2ADMITTE Sent ACTICE IN EMICy. Aar, C/VIDRADO by E-Mail only BURMAN. CRITTON LUTTIER&COLEMAN.LLP YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP October 19, 2009 Re: Settlement Negotiations Dear Bob: ADELOYI J. BENAVENTE PARALEGAVINYESTIGATOR JESSICA CADWELL BOBBIE M. MCKENNA ASHLIE STOKIN•BARING BETTY STOKES PARALEGALS RJTA H. BUDNYK Of COUNSEL EDWARD M. RICO SPICIAL ONSVMER JUSTICE COVNSEt As per our discussion on September 251h followed by your e-mail and my e-mail, we are res • 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. Whether the minimum amount of damages under §2255 is $50,000 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 ould not represent any additional females who are on the list, other tha whom your firm currently represents. In hindsight, this appears to be a equest, and t at is no longer a condition. We expect that you will continue to represent and may represent other individual