LAW OFFICES

FRANKLIN & CRISCUOLO

SECOND FLOOR
801 NORTHEAST 1 67 m STREET
NORTH MIAMI BEACH, FLORIDA 33162-3729

BARRY S. FRANKLIN""+ TELEPHONE {305) 940-4000

DONALD G. CRISCUOLO* FACSIMILE !305) 940-0940

FLORIDA BAR BOARD CERTIFIED IN

MARITAL AND FAMILY LAW

FELLOW AMERICAN ACADEMY

OF MATRIMONIAL LAWYERS

+ADMITTED IN FL ANO NY

April 11, 2006

Mr. Barnaby Lee Min

The Florida Bar
Rivergate Plaza, Suite M-100
444 Brickell Avenue
Miami, Florida 33131-2404

RE: Complaint by Eric L. Noveshen against Donald G. Criscuolo

The Florida Bar File No. 200670,687(11 HJ

Dear Mr. Lee Min:

This is a response to Mr. Noveshen's latest correspondence dated March 21,

2006. I find the correspondence to be somewhat repetitive. It seems as if Mr.
Noveshen and I simply disagree as to what proper procedure should have been
followed. One thing is true with certainty, I have never dealt directly with Mr.
Noveshen subsequent to the Notice of Appearance filed by his attorney, Terry
Fixel.

As to my dealing directly with Mr. Noveshen by sending him correspondence

dated December 20, 2005, as I previously brought to your attention, pursuant to
Florida Rule of Judicial Administration 2.060(i)(3), Ms. Fixel's services
automatically terminated after the appeal time ran after the divorce and therefore, it
was not improper for me to deal directly with Mr. Noveshen.

With respect to the second letter I wrote to Mr. Noveshen dated January 6,
2006, in the very first paragraph of the letter I advised Mr. Noveshen of the fact
that Ms. Fix el' s prior representation of him automatically terminated. However, I
copied that letter of January 6, 2006 to Ms. Fixel to give her the opportunity to
contact me and advise if she was indeed still representing Mr. Novenshen. She
declined to do that. EXHIBIT

I 10
Eric L Noveshen 436 NE 10th Ave
Ft Lauderdale, FL 33301

May 1, 2006

Mr. Barnaby Lee Min

The Florida Bar
Rivergate Plaza, Suite M-100
444 Brickell Ave.
Miami, Florida 33131

RE: The Florida Bar File No. 200670, 687 (llH)

Dear Mr. Lee Min,

Mr. Criscuolo never ceases to amaze me. There is a major communication problem with Mr.
Criscuolo. Mr. Criscuolo reads one thing and interprets it as another. This is one of the
fundamental reasons there is a problem before the Florida Bar. I never accused Mr.
Criscuolo of forging his client's signature. I specifically wrote, "If you are to look at the
signature on that page it is clearly a forgery of my former wife's signature. Mr. Criscuolo
offered the Florida Bar a forged signature page as defense of him being retained?" I
seriously doubt that Mr. Criscuolo signed the retainer page, but it is clearly not my former
wife's signature on the page in question. For Mr. Criscuolo to offer a forged signature page
to the Florida Bar is completely unheard of. I attached hereto, a copy signature page in
question (Exhibit "A") and a copy of a notarized page by Mr. Criscuolo verifying my former
wife's signature (Exhibit "B''). If you look at the signature on the page in question, clearly
it's a forgery. If.Mr. Criscuolo is so confident that my former wife will testify under oath that
that is her signature on the page in question., I would love to be present for that! I guarantee
that my former wife would testify that that is not her signature on the page in question. We
can always get a handwriting analyst to verify Mr. Criscuolo's claims ifhe is so confident
that it is my former wife's signature on the page in question. All of Mr. Criscuolo's actions
stink ofimpropriety.

I retained my attorney Terry Fixel again so I would not have to deal with threatening letters
from an attorney. Mr. Criscuolo said specifically in his December 20, 2005 letter to me that
"Christina has directed me to immediately file an action with the court and seek an
emergency hearing to compel your compliance. Any legal time spent on that matter will be
paid for by you." There is no way I am going to take such language lightly, so I noticed Mr.
Criscuolo that all future communication will go through Terry Fixel. Everything I did to
retain Terry Fixel was completely proper. The next business day that I could retain Ms. Fixel
was the 27th of December. Nobody worked on the Friday and Monday before and after
Christmas. On Mr. Criscuolo's December 20, 2005 correspondence, his first statement is "as
you know, I represent your former wife, Christina Noveshen." It seems by Mr. Criscuolo's
own written interpretations, that Mr. Criscuolo's assertion in his correspondence ofDecember