444-02.pdf

Case 9:08-cv-80119-KAM Document 444-2 Entered on FLSD Docket 01/04/2010 Page 1 of 2 J. MICHAEL BURMAN, P.A.u GREGORY W. COLEMAN. P.A. ROBERT D. CRITTON, )R.. P. A. 1 BERNARD A. LEBEDEKER MARKT. lUTTIER. P.A . JEFFREY C. PEPIN MICHAEL J. PIKE HEATHER MCNAMARA RUDA DAVID A. YAREMA 1 FLORIDA 80AR.D CERTIFIED CIVIL TRIAL LAWYER 2 ADMITTED TO PRACTICE IN FLORIDA AND COLOI\ADO Sent by Fax and U.S. Mail Adam Horowitz, Esquire Mermelstein & Horowitz, P.A. 18205 Biscayne Blvd. Suite 2218 Miami, FL 33160 BURMAN , CRITTON LUTTIER&COLEMAN, LLP Y O UR T RU S TED A DVOCATES A LIMITED LIA BILI TY PAR TNE RSH IP November 25, 2009 Re: Jane Doe No. 6 v. Epstein Case No. 08-CIV-80994-Marra-Johnson Dear Adam: ADELQ!JI J. BENAVENTE PARALEGAUINVESTIGATOR JESSICA CADWELL BOBBIE M. MCKENNA ASHLIE STOKEN-BARING BETTY STOKES PARAI.EGAlS RITA H. BUDNYK Of COUNSEL EDWARD M. RICCI SPECIAL CONSUMER JUSTICE COUNSEL Yesterday, our client had an appointment at our office at 4:45 p.m. As you know, my office is only one-half a mile away from the location where the IME of Jane Doe 6 took place. At or around that time , Mr. Epstein was leaving the building where the IME was taking place. It appears that at the time Jeffrey Epstein was exiting the building, your client and your associate were outside smoking a cigarette. Mr . Epstein entered his vehicle and left the building where his office is located and made his way to my office without speaking or acknowledging either person. I learned from Dr. Hall that your client, by and through her lawyer, prematurely terminated the IME. This was not proper. With regard to past agreements, you were obligated to call when you and your client arrived at the building and to call when you and your client were leaving the building. Your associate did not follow that procedure at the IME. Instead, your client and your associate took several smoking breaks without letting anyone know that they had exited the building. This procedure was initiated by and used at your request. Mr . Epstein was leaving the building to attend a meeting with his lawyers. There was no way, without a phone call from your office, that Mr. Epstein could know that your clients were outside smoking cigarettes. 303 BANYAN BOULEVARD • SUITE 400 • WEST PALM BEACH. FL 33401 • PHONE : 561-842 WWW.BCLCLAW.COM EXHIBIT B @BCLCLAW.COM Case 9:08-cv-80119-KAM Document 444-2 Entered on FLSD Docket 01/04/2010 Page 2 of 2 Adam Horowitz, Esquire November 25, 2009 Page2 It is my intention to continue the IME of Jane Doe 6. I would like to do so without having to file a Motion to Compel the completion of the IME. In that regard, I hope to reach some agreement with you regarding same. One possibility is to have Jane Doe complete her IME the day before and/or the day after the ne><jscheduled IME. We must also discuss costs. 1.- ; MJP/asb Enclosures cc: Jack Goldberger, Esq . Robert D. Critton, Esq. ,1 i' Very truly yoti~s : /t ' /0 ! .. __ /