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305-9312200 Herman &Mermelstein, P 11:24:?* a.m. 28-03-2008 212 ieee - HERMAN & MERMELSTEIN ra ATTORNEYS AT LAW ; Stuart S. Mermelstein Tel 305-931-2200 Fax 305-931-0877 ssm@hermanlaw.com 18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 www. hermanlaw.com March 28, 2008 VIA FACSIMILE Lanna Leigh Belohlavek State Attomey’s Office 401 N. Dixie Hwy West Palm Beach, FL 33401 Re: State of Florida v. Jeffrey Epstein, Case No. 2006CF009454AKX Dear Ms. Belohlavek: We have left a number of messages with you to coordinate depositions of our clients in this case, without response. With regard to the depositions of our clients, it is necessary and appropriate for the entry of a court order which would require that one deposition be taken of each of our clients for use in both the criminal case and the civil case. A single deposition is warranted given that the facts of the sexual assault are common to both the civil and criminal cases, and the Defendant, Jeffrey Epstein, is the same in both cases. A single deposition is in the best interests of the emotional well being of the victim. In another case we were involved in where both a civil case and a criminal case were pending, the State Attorney’s office filed a motion for protective order in the criminal case pursuant to Fla.R.Crim.P. 3.220(1)(1) asking that the depositions in both the criminal and civil case be conducted at the same time. We would like to coordinate and cooperate with your office with regard to this issue conceming the depositions of our clients. The deposition of is presently scheduled for Wednesday, April 2, 2008. Please let us know how you would like to proceed in this important matter as soon as possible. Very truly yours, Stuart S. Mermelstein SSM/Ir 07/26/17 Page 49 Public Records Request No.: 17-295 DOJ-OGR-00031570