EFTA00723007.pdf

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