EFTA00723007.pdf

AUG-14-09 10:35 FROM-LE0P0LIMIVIN, LEOPOLD-KUVIN., August 14, 2009 Fax and Mail Robert Critton, Esq. Burman Critton, et. al. 515 N. FlagJer Drive Suite 400 West Palm Beach, FL 33401 15615151401 T-461 P.001/001 3-261 CONSUMER JUSTICE ATTORNEYS Re; B.B. v. 'JEFFREY EPSTEIN OUR FILE NO.: 080303 Dear Bob: Thank you for your letter of August 13, 2009. As you are well aware, if a witness appears for n deposition, there is no need to serve them with a subpoena. Since all these witnesses will be available and present at these depositions on these dates, and all the cases have been somewhat consolidated for discovery purposes, there is no need for a Florida subpoena to be served on these individuals. If you really believe it is necessary, I will file a motion to appoint a conunissioner with Judge Hafele, and explain how you are making us jump through procedural hoops that are unnecessary given that fact that the witnesses will already be present. We intend to fully participate in these depositions as we see fit. Sincerely, SPENCER T. KUVIN STK: cc: Jack Goldberger, Esq. 2926 PC3A EIoutavara Suite 200 Palm Beach Garoens . Florida 33410 . 501.515.1400 fax 501.515.1401 CRASHWORTHINESS • MANAGED CARE ABUSE • CONSUMER CLASS ACTIONS • PERSONAL I NIURY • WRONUFUL DEATH EFTA00723007