EFTA00207660.pdf

From: "Robert D. Critton Jr.11 To: Subject: RE: E-mail P Date: Wed, 30 Jun 2010 20:05:22 +0000 Importance: Normal Priority: normal Inline-Images: image001.gif; image002.jpg; bc1c.gif; bestlawyersjpg MIE -Having the dots being scanned, are you ok w/ pdf or hard copies delivered before 5? bob BURMAN, CR1TTON LUTTIER&COLEMAN.ms A YOUR TRUSTED ADVOCATES Robert D. Clifton Jr. - Attorney at Law 1ST ED IN Ill Best Lawyers THE WORLD'S PREMIER GUIDE This e-mail contains legally privileged and confidential information intended only for the individual or entity named within the message. Should the intended recipient forward this message to another person or party, that action could constitute a waiver of the attorney/client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited. If this communications was received in error, please notify us by reply e-mail and delete the original message. Disclaimer added by CodeTwo Exchange Rules www.codetwo.com From: Sent: Wednesday, June 30, 2010 11:51 AM To: Robert D. Critton Jr. Subject: RE: E-mail to Marie 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. EFTA00207660 Assistant U.S. Attorney From: Robert D. Critton Jr. [mallto:rcrIt@bcIdaw.com] Sent: Wednesda June 30 2010 9:29 AM To: Cc: is ae . ice Subject: RE: E-mail to Marie 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, bob BURMAN. CRITTON LUTTIER&COLEMAN.us YOUR TRUSTED ADVOCATES Robert D. Critton Jr. - Attorney at Law LISTED IN Best Lawyers THE WORLD'S PREMIER GUIDE This e-mail contains legally privileged and confidential information intended only for the individual or entity named within the message. Should the intended recipient forward this message to another person or party, that action could constitute a waiver of the attorney/client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited. If this communications was received in error, please notify us by reply e-mail and delete the original message. Disclaimer added by CodeTwo Exchange Rules www.codetwo.com From: To: Robert D. Critton Jr. Subject: RE: E-mail to Marie 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 EFTA00207661 From: Robert D. Critton Jr. Sent: Tuesday, June 29, 20 To Subject: RE: E-mail to Marie Sure, is it in the flagler tower bldg on the intrcoastal where jones and foster's office is? WA BURMAN, CRITTON LUTTIER&COLEMAN.ms YOUR TRUSTED ADVOCATES Robnt D. Clifton Jr. - Attorney at Law IST ED IN SI Best Lawyers* THE WORLD'S PREMIER GUIDE This e-mail contains legally privileged and confidential information intended only for the individual or entity named within the message. Should the intended recipient forward this message to another person or party, that action could constitute a waiver of the attorney/client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited. If this communications was received in error, please notify us by reply e-mail and delete the original message. Disclaimer added by CodeTwo Exchange Rules www.codetwo.com From: Sent: ues ay, une , : To: Robert D. Critton Jr. Subject: Re: E-mail to Marie Can you deliver to our wpb office? From: Robert D. Critton Jr. < To: Sent: Tue Jun 29 13:25:56 2010 Subject: FW: E-mail to Marie I --See below, my typing skills are limited as lam sure you noted, bob EFTA00207662 W .4 BURMAN, CRITTON LUTTIER &COLEMAN,u, YOUR TRUSTED ADVOCATES Rohortiltrlitonk.-AnornAl I aw LISTED IN Best Lawyers® THE WORLD'S PREMIER GUIDE This e-mail contains legally privileged and confidential information intended only for the individual or entity named within the message. Should the intended recipient forward this message to another person or party, that action could constitute a waiver of the attorney/client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited. If this communications was received in error, please notify us by reply e-mail and delete the original message. Disclaimer added by CodeTwo Exchange Rules www.codetwo.com From: Connie Zaguirre, CP, FRP Sent: Tuesday, June 29, 2010 1:23 PM To: Robert D. Critton Jr. Subject: E-mail to Marie 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 EFTA00207663 BURMAN, CRITTON TT LU IER&COLEMANILP : YOUR TRUSTED ADVOCATES Connk Ziguirre. CP. FRP -Assistant for Robert D. Crinon, Jr. This e-mail contains legally privileged and confidential information intended only for the individual or entity named within the message. Should the intended recipient forward this message to another person or party, that action could constitute a waiver of the attorney/client privilege. If the reader of this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited. If this communications was received in error, please notify us by reply e-mail and delete the original message. Disclaimer added by CodeTwo Exchange Rules www.codetwo.com EFTA00207664