benefit substantially from the foregoing and will want to engage in mutually beneficial discussions. I am attaching a draft of a Complaint which Mr. Baise will file through local counsel if we cannot reach a mutually beneficial agreement. Please contact me at your earliest convenience. Very truly your

e discussed above and otherwise describes Defendants' alleged role in Hoffenberg's scheme. (Moskowitz Decl. at Ex. C). • On December 5, 2013, Mr. Baise, counsel for Plaintiffs in this matter, appeared before Judge Sweet and identified Defendant Epstein as a "critical player" in I3See Section 1I(b).