(no subject)
We are in the process of compiling the letters sent to counsel by representatives of the USAO to comply with the court order to produce by end of business Wednesday. The process is ongoing since they are in the possession of so many different attorneys. Attached is a small sample (19 pages). We have objected to the production on Mr. Epstein's behalf believing they are irrelevant to the civil litigation, certainly inadmissible, and that their production chills the candor of plea negotiations in future cases thus the order violates the spirit of FRE 410 and 408. We have exhausted our objections on Mr. Epstein's behalf, see DE 172 (in 08-80893) regarding an order on our motion for protective order and believe that the USAO should consider intervening to protect its principled interest in the confidentiality of the correspondence. A binder of the compiled letters is being copied for your review if requested and will be supplemented when additional letters are located for production. Please advise where we should deliver them.
Bob
See below, my typing skills are limited as I am sure you noted, bob
BURMAN, CRITTON
BC LUTTIER & COLEMAN, LLP
YOUR TRUSTED ADVOCATES
Robert D. Critton Jr. - Attorney at Law 303 Banyan Boulevard | Suite 400 | West Palm Beach | FL 33401 Phone: (561) 842-2820 | Fax: (561) 253-0164 Direct: 561-515-3135 rcrit@bclclaw.com | www.bclclaw.com
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Can you deliver to our wpb office?
Sure, is it in the flagler tower bldg on the intrcoastal where jones and foster's office is?
Hi Bob — Nothing has arrived yet. I am running off to court now. Can I pick the items up from you or will they be delivered this morning?
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Reach 3401
Were you able to open the information that I sent yesterday? The rest should be here this morning and hope to have it copied and to you by noonish—where will you be? You can come by here or I can have it delivered. Assembling is taking longer than expected, sorry,--- mike who works w me is pulling it together.
Hi Bob - Just got back from court. I was able to open what you sent yesterday. If you could have your courier deliver the items, I would appreciate it. Also, can you tell me your plan for production (i.e., is it going out by FedEx tonight)? So that I can figure out my timetable if I have to file an emergency motion.
Thank you.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
