EFTA01077421.pdf

BURMAN. CRITTON LUTTIER&COLEM_AN,LLP YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN. P.A.' ADELQUI J. BENAYENTE GREGORY W. COLEMAN. PA PARALEGALtINVESTICATOR ROBERT D. CRITTON. JR. PA I JESSICA CADWELL BERNARD A. LEIEDEKER BOBBIE M. MCKENNA DANIEL LUSTIG ASHUE STOKEN•BARING MARK T. LUITIER. P.A. BETTY STOKES MICHAEL I. PIKE PARALEGALS MICHAEL I..SCHEVE RITA H. BUDNYK Of COUNSEL DEAN t XENICK DAVID A YAREMA EDWARD M. RICCI March 29, 2011 Of COUNSEL I TEDIUM BOARD CERTIFIED CIVIL TRIAL LAWYER (ADMITTED TO PRACTICE IN FLORIDA AND COLORADO Sent by E-Mail Only Joseph L. Ackerman, Jr. Fowler White Burnett, P.A. Phillips Point, West Tower 777 South Flagler Drive, Suite 901 West Palm Beach, FL 33401 Re: Doe v. Jeffrey Epstein et al. Dear Joe: I am enclosing a copy of Mr. Vogeler's demand letter dated March 23, 2011 and my letter to him. I am forwarding a copy of this letter to Jeffrey and Marty Weinberg. Should anyone else need a copy, I will assume that you will forward it to them. I recommend that you contact Mr. Vogeler directly if you want an extension. It seems to me this letter is a shake down/extortion Good Luck. Cordially yo Robe D. Critton, Jr. RDC/clz Enclosures cc: Jeffrey Epstein Martin Weinberg, Esq. 303 BANYAN BOULEVARD • SUITE 400 • WEST PALM BEACH. FL 33401 • PHONE: 561-842-2820 • FAX: 561-84.6929 • MAILMICLCIAW.COM WWW.BCLCLAW.COM EFTA01077421  BURMAN. CRITTON LUTTIER&COLEMAN. us YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN, PALI ADELEWI J. BENAVENTE GREGORY W. COLEMAN. PA PALLALEGAL/INVES11GATOk ROBERT D. CRITTON. JR.. P.A. ' JESSICA CADWELL BERNARD A. LEBEDEKER BOBBIE M. MCKENNA DANIEL LUSTIG ASHLIE STOKEN-BARING MARK T. LUTTIER PA BETTY STOKES MICHAEL) PIKE PARALEGALS MICHAEL L SCHEVE RITA H. BUDNYK DEAN T. XENICK Of COUNSEL DAVID A. YAREMA EDWARD M. RiCCI March 29, 2011 00 COUNSEL I fVAUD,. IOARD CERTIFIED CIVIL TRIAL LAWYER 2ADMITTED TO PR/CrICE IN FLORIDA AND COLCRIADO Sent by Fax alail anc William K. Vogeler, Esq. Gruenbeck Vogeler 9110 Irvine Center Drive Irvine, California 92618 Re: Doe v. Jeffrey Epstein et al. Dear Mr. Vogeler: I received your March 23, 2011 letter on March 28. I know you have a demand deadline of April 1st. I no longer represent Mr. Epstein nor have I since approximately August of 2010. I am, however, forwarding the letter to the appropriate attorneys for Mr. Epstein today and would ask that you grant them an additional ten (10) days within which to respond to your demand. Thank you for your anticipated courtesy. Cordially yo Robert P Critton, Jr. RDC/clz Cc: Joseph L. Ackerman, Jr., Esq. Fowler White Burnett, P.A. 303 BANYAN BOULEVARD • SUITE 400 • WEST PALM BEACH, FL 33401 • PHONE: 561-842-2820 • FAX: 561-844-6929 • FoLAIL€8cLaAw.con4 WWW. BC LC LAW.COM EFTA01077422 A LAW PARTNERSHIP March 23, 2011 CONFIDENTIAL SETTLEMENT COMMUNICATION Robert D. Critton, Jr. Burman, Critton, Luttier & Coleman 303 Banyan Boulevard, Suite 400 West Palm Beach, Florida 33401 Re. Doe v. Jeffrey Epstein et al Dear Mr. Critton: I am writing in an attempt to settle my client's claims against your client Jeffrey Epstein. According to my client, Mr. Epstein offered to pay her and other exotic dancers $10,000 each to perform at your client's home several years ago. A popular dancer at Rachel's Strip Club, my client was chauffered to a party at 358 El Brillo Way in West Palm Beach in early 2006. During the party, my client observed other young women dressed provocatively. Some appeared to be as young as 14 years old. My client was directed to an upstairs bedroom, where she saw Mr. Epstein. She recognized him because she had danced for him at the club before. At his home, Mr. Epstein introduced my client to his guest Prince Andrew. My client then danced for the men, undressing until she was wearing only a bra and panties. Mr. Epstein and Prince Andrew then told my client they wanted to have a threesome. She said she was hired to dance, not to have sex. Mr. Epstein said they would pay her later for dancing, and they prevailed upon her to engage in various sex acts. After the men had satisfied themselves, they invted my client to take a trip with them to the Virgin Islands. She declined their invitation. She was then chauffered back to the strip club. To date, your client has paid my client $2,000 of the promised $10,000. My client has not pursued her claims against your client until this time because she is not proud of the circumstances of that night. She was working as an exotic dancer, but she was treated like a prostitute. To avoid unseemly publicity, my client has asked me to keep her name confidential for purposes of settlement. However, she is prepared to asset her rights in the public courts if necessary. THE IRVINE SPECTRUM 91 10 IRVINE CENTER DRIVE IRVINE. CA PHONE: FAX: WWW.GRUENBECKVOGELER.COM EFTA01077423 Based upon my review of the facts and the law, I believe my client has claims for breach of an oral contract, quantum meruit and various torts. While the statute of limitations apparently has run on tort claims such as fraud, false imprisonment, or sexual assault — and the defense of consent may ultmately prevail against such torts -- the statute on an oral contract is four years. In this case, Mr. Epstein did not specify when they would pay for my client's services. In the absence of a specific date for performance, I hereby make a demand for payment at this time. Please be advised that my client has not agreed to keep confidential her interactions with your client in this regard. Moreover, a confidentiality agreement would not be enforceable to prevent her from being compelled as a witness in any other case. With these considerations, my client will agree to keep confidential her interactions with your client in exchange for a payment of $250,000. Naturally, this confidentiality agreement would extend to my client's interactions with Prince Andrew as well. Accordingly, my client's demand to settle this matter confidentiality is $250,000. This offer shall remain open until April 1, 2011. I look forward to your timely response. William K. Vogel EFTA01077424