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Extracted Text #

Case 9:08-cv-80119-KAM Document 113-5 Entered on FLSD Docket 05/22/2009 Page 1 of 3 
EXHIBIT E 
to 
Plaintiffs Jane Doe 101 and Jane Doe 102's 
Motion for No-Contact Order 
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Case 9:08-cv-80119-KAM Document 113-5 Entered on FLSD Docket 05/22/2009 Page 2 of 3 
di 
I. MICHAEL BURMAN, PA.' 
GREGORY W. COLEMAN, PA. 
ROBERT D. CRITTON, JR., PA.,
BERNARD LEBEDEKER 
MARX T. LITITIER. PA. 
JEFFREY C. PEPIN 
MICHAEL J. PIKE 
HEATHER McNAMARA RUDA 
PLOIUDA ROARD (=MED 
OVILTIUAL LAWYER 
BURMAN, CRITTON, LUTTIER 
& COLEMAN LLP 
A LIMITED LIABILITY PARTNERSHIP 
Sent by E-Mail and U.S. Mail 
Robert C. Josefsberg, Esq. 
Katherine Ezell, Esq. 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 800 
Miami, FL 33130 
Dear Bob: 
May 21, 2009 
ADELQUI J. BENAVEINTE 
PARALBGAL/INVESIIOAIDIt 
BARBARA M. Me..KENNA 
ASHLJE STOKEN-BARING 
BETTY STOKES 
MRALOGALS 
RITA H. BUDNYK 
OP COUNSEL 
As I advised you yesterday, I am responding to your April 17, 2009 letter. As I 
stated in my e-mail, I think your request is unnecessary. Despite what Roy may have 
said to you, my client has had no contact with any of your clients. To my knowledge, 
the only one who has "breached" any agreement regarding contact is your own client, 
S who, as I advised you in a letter last week, contacted Jack Goldberger's 
office looking for her settlement check. Mr. Goldberger, of course, did not speak with 
her. 
Lawyers who represent Mr. Epstein are well familiar with the Rules of 
Professional Conduct, including Rule 4-4.2. At the same time, I am certain you are 
equally familiar with that Rule. The Comment provides "Parties to a matter may 
communicate directly with each other...". 
To my knowledge, neither Mr. Epstein nor any attomey or agent of those 
attorneys who represent Mr. Epstein, have contacted or attempted to contact your 
clients. Given that it is not Mr. Epstein's intention to have direct contact with your 
clients, it is unnecessary to respond point by point to statements attributed to my co-
counsel. 
L•A•W•Y•E•R 'S 
515 N. FLA/3LBR DRIVE / sutra 400 / WEST PALM BEACH, FLORIDA 33401 
TELEPHONE ([Phone Redacted] FAX ([Phone Redacted] 
mail@belclaw.00m 
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Case 9:08-cv-80119-KAM Document 113-5 Entered on FLSD Docket 05/22/2009 Page 3 of 3 
May 21, 2009 
Page 2 
Rather than to be concerned about what my client is doing, I would ask that you 
advise your clients not to contact Mr. Epstein's lawyers directly. Neither I nor the 
attorneys who represent Mr. Epstein want to be put in a position where we are set up by 
any of your clients. 
RDC/msc 
cc: Roy Black, Esq. 
Jay Lefkowitz, Esq. 
J. Michael Burman, Esq. 
Jack Goldberger, Esq. 
Josefsberg.01 -Lax 
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