EFTA00213861.pdf

From: To: Subject: Re: E-mail to Date: The, 29 Jun 2,55:03 +0000 Importance: Normal Inline-Images: bc1c.gif; bestlawyers.jpg; bc1c249e.gif 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 ---See below, my typing skills are limited as I am sure you noted, bob BURMAN, CRITTON LUTTIER&COLEMAN.ar A YOUR. TRUSTED ADVOCATES Robert D.CrlitonJr.- Attorney at Law West Palm Beach I FL 33401 I www.belclaw.com 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 EFTA00213861  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 W I BURMAN, CRITTON LU TT I ER &COLEMAN.up YoeR TRUSTED ADVOCATES Connie Zaguirre, CP, FRP - Assistant for Robert D. Critton, Jr. West Palm Beach I FL 33401 I www.bcIclaw.com 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. added by CodeTwo Exchange Rules www.codetwo.com EFTA00213862