W. CHESTER BREWER, JR., ATTORNEY AT LAW SUITE 1400 250 AUSTRALIAN AVENUE SOUTH WEST PALM BEACH, FLORIDA 33401-50M TELEPHONE (561) 6554777 FAX (561) 835-8691 June 30, 2009 Darren Indyke, Esquire 457 Madison Avenue, 4'h Floor New York, New York 10022 Sent Via E-Mail Re: Palm Beach Marine Construction v. Epstein Dear Darren: I received a telephone call from Alex Lian today. I had thought that he was calling to discuss our proposal for settlement but no such luck. Mr. Lian would like to take Doug Schoettle's deposition and he questioned me about Doug's availability. I am assuming that he is still making periodic trips to the Palm Beach area but I do not know this. Could you please check with him and see if he will be in the area any time in the foreseeable future. Thank you for your help. Very Truly Yours, W. Chester Brewer, Jr. WCB/cg EFTA00727360