EFTA00591279.pdf

BURMAN.CRITTON LUTTIER&COLEMAN,LLP YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BURMAN. PA" ADELOVI J. BENAVENTE PAMLEGA1/INVESTIGATOR GREGORY W. COLEMAN. PA ROBERT D. CRITTON. Th.. PA' JESSICA CADWELL BERNARD A. LEBEDEKER BOBBIE M. MCKENNA MARK T. LUTTI ER. PA ASHLIE STOKEN-BARING JEFFREY C PEPIN BETTY STOKES MICHAEL J. PIKE January 7, 2010 PASIALICALS HEATHER MCNAMARA RUDA RITA H. BUDNYK OF COUNSEL DAVID A. YAREMA EDWARD M. RICCI 'NORM A BOARD CERTIFIED CIVIL ULU. LAWYER 2ADMITTEDd73WiC6C1; Mali StECIAL CONSUMER JUSTICE COUNSEL Spencer T. Kuvin, Esq. Leopold-Kuvin, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Re: B.B. v. Epstein Dear Spencer: I am in receipt of your January 4, 2010 letter referencing the deposition of Jerry Goldsmith. To my knowledge, he has no personal knowledge regarding any relevant or material fact in this case. His only involvement was as related by former Palm Beach Chief Michael Reiter at his deposition. If your client had any contact with Mr. Goldsmith through Mr. Epstein, then clearly, the deposition may have some relevance. However, if your sole purpose is to establish that Mr. Goldsmith contacted Chief Reiter on behalf of Mr. Epstein for whatever reason, it is an issue which is not relevant, or material, nor will any associated with it ever be admissible. I would ask that you reconsider takin the deposition of Mr. Goldsmith in that it is a waste of time and money for every' e's respective clients, and it serves no meaningful purpose in the dispute betwee our client and mine. Cordia Rob- Critton, Jr. RDC/clz cc: Jack Goldberger, Esq. 303 BANYAN BOULEVARD • SUITE 400 • WEST PALM BEACH. FL 33401 • PHONE WWW.BCLCILAW.COM EFTA00591279