EXHIBIT 4RONALD K. GRANIT AND U.S. MAIL ‘VIA FACSIMILE TRANSMISSION TO (310) 451-6265 November 26, 2008 David J. Altman, Esq. 815 10" Street, Suite D Santa Monica, CA 90403 Re : Altman v. Kovaes, et al. LASC Case No. : BC350542 Subject Matter: —_Implementation of Settlement ‘Dear Mr. Altman: ‘As Mr. Barak has informed you, I will be representing Sei Hak Naing in this matter. Thave not physically received the signed Substitution of Attomey; therefore, I cannot make a formal response to your letter. However, as counsel of record for Vich and Leang Horn, who participated in the Settlement, I can opine as to some of the assertions. First, I believe from a careful reading of the record of the Settlement, the terms included the transfer of title of the real property to Mr. Altman in exchange for the sum of $750,000.00. There were no other specifics agreed upon by the parties on the record. Second, it could be argued by you that Mr. Barak’s gratuitous comment about a Title Insurance Policy could be a requirement of the Settlement, but I believe to the contrary. Third, the requirements set forth by you for a writing and all the various terms and conditions suggested by “Mr. Javaheri” are rit a part ofthe Settlement on the record subject to enforcement by the Court pursuant to CCP § 664.6. Therefore, all of the new terms and conditions you set forth on pages 3 and 4 of your letter are outside the ambit of the Settlement on the record. In regard to your father’s tender of the money, I have not see any proof that the sum of $750,000.00 is on deposit in a financial institution awaiting release to Mr. Naing by way of a wire transfer or issuance of a Cashier’s check (it might be helpful to transmit a copy of a bank statement reflecting such proof). In regard to Mr. Naing’s performance, | transmitted a copy ofRONALD K. GRANIT David Altman, Esq. November 26, 2008 Page 2 a signed Grant Deed duly executed by Mr. Naing on November 11, 2008, which verified his ability to perform, Is it not time to just complete the Settlement without another visit to the Court? Sincerely RO} K. GRANIT, ESQ. RKGal coo Clients David Bates, Esq. Fred Barak, Esq.