EFTA00614567.pdf

vE J. MICHAEL BURmAN, P.A.' GREGORY W. COLEMAN. PA ROBERT D. CRITTON. JR. PA I BERNARD A LEtsEDEKER MARK T. LUTHER. PA. MICHAEL J. PIKE MICHAEL L. SCHEVE DEAN T. XENICK DAVID A. YAREMA 'FLORIDA BOARD CtICEIFI/0 CIVIL IRLAL LAWYER 2ADMITTED TO PRACTICE IN FLORIDA AND COLORADO Via E-Mail Jeffrey Epstein Re: LM & EW Dear Jeffrey: BURMAN, CRITTON LUTTIER&COLEMAN, LLP YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP May 28, 2010 ADELREJI J. BENAVENTE PARALKAVinnerrFcATOR JESSICA CADwELL BOBBIE M. MCKENNA ASHLIE SToKEN-BARING BETTY STOKES PARALEGAIS RaTA H. BUDNYK Of COUNSEL EDWARD M. RJCCI Of COUNSEL As you know, on May 25, 2010, Judge Hafele in the LM & EW cases ruled against two discovery requests similar to the ones under Rule 4 Appeal in the Federal Court concerning the exchange of discovery between your criminal lawyers and the USAO, the State Attorney and any local authorities. The request is inclusive of correspondence exchanged between those parties. In the past. I have not received a timely response relative to outstanding subpoenas and discovery which only puts you at risk. In that regard, I was able to obtain extensions of time to respond to same. However, in this instance, we need to obtain appellate counsel (preferably Martin Reeder) to file a writ of cert in the above matter. That must be done within thirty (30) days of the entry of an order. Accordingly, to err on the side of caution, we should immediately retain Martin Reeder to complete what needs to be done on the appellate level. As you know, we would not do the appeal. Bob said you previously authorized retention of Martin for this and he had sent materials to him re: the federal cases. Let me know relative to the hiring of Martin Reeder within the next five days. If we miss the thirty (30) day time period, we forever waive the right to an appeal. Per Marty, we should attempt to protect the information being sought at all cost. 303 BANYAN BOULEVARD . SUITE 400 • WEST PALM BEACH. FL 33401 • PHONE: • FAX: WWW.BCLCLAW.COM EFTA00614567 May 28, 2010 Page 2 Upon your receipt and review of this correspondence please contact me. Ver& truly yours, Michael J. Pike MJP/br cc: Jack Goldberger, Esq. Darren Indyke, Esq. Marty Weinberg, Esq. Robert D. Critton, Jr. EFTA00614568