EFTA00722045.pdf

BURMAN, CRITTON LUTTIER&COLEMAN. LLP YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP I. MICHAEL BURMAN. 12 ADELOVI J. BENAVENTE PARALEGAL/INVESTIGATOR GREGORY W. COLEMAN. ROBERT D. CRITTON. JR. JESSICA CADWELL BERNARD A LEBEDEKER BOBBIE M. MCKENNA MARK T. LUSTIER P.A. ASHLIE STOKEN-BARING MICHAEL J. PIKE BETTY STOKES MICHAEL L. SCHEVE PARALEGALS DEAN T. XENICK July 2, 2010 PITA H. BUDNYK DAVID A. YAREMA Ot COUNSEL EDWARD M. RICCI OF COUNSEL I FLOIUDA ROAM a MIRao CIVIL TRIAL LAWYER 2ADMMED TO PRACTICE IN nom On AND COLORADO Sent by E-Mall Only Bradley J. Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue. Suite 2 Fort Lauderdale, FL 33301 Re: Jane Doe v. Epstein Dear Brad: During depositions you have stated or relied upon documents that apparently emanated from your own discovery of the files of at least the State Attorney or PBPD. Accordingly, please disclose to us any such information. Next, during discovery you have requested, and a Court has allowed, information that Epstein's counsel received from USAO and/or federal law enforcement, we accordingly request that you provide us with any such information you have received in response to any request, exchange of letters, etc.... I will agree to receive them pursuant to a voluntary protective order, one you refused to enter, that they will not be disseminated to any third parties and only used, if at all, during the trial of any of the cases involving your three (3)clients. While we would not ordinarily seek such information, given your production requests and follow-up litigation, we have no alternative except to seek reciprocal discovery that parallels the extent of the court order which we complied with on June 30, 2010. Obviously, we are entitled to such information as you will or seem to imply that same will be used at trial. Cordi urs, Mic J Pike 303 BANYAN BOULEVARD ' SUITE 400 • WEST PALM BEACH, El. 33401 • PHONE'. • FAX: EFTA00722045