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Document 001

AI Analysis

Summary: Theodore J. Leopold writes to Jack A. Goldberger expressing concern about the ethics of Goldberger's co-counsel regarding the handling of exhibits during a direct examination, and confirms an agreement to provide copies of the exhibits to the State Attorney and Leopold.
Significance: This document reveals a potential dispute between attorneys regarding the handling of exhibits during a deposition or trial, and may be significant in understanding the dynamics between the attorneys involved in the Jane Doe v. Epstein case.
Key Topics: dispute over exhibits used in direct examination concerns about co-counsel's ethics agreement to provide copies of exhibits
Key People:
  • Theodore J. Leopold - attorney writing the letter
  • Jack A. Goldberger - recipient of the letter and attorney for Jane Doe
  • Michael Tein - co-counsel or associated attorney, cc'd on the letter
  • Lanna Belohlavek - co-counsel or associated attorney, cc'd on the letter
Document Type
Letter
Date
February 21, 2008
Pages
1
Folder
IMAGES012
Has Handwriting
Yes

Full Text

02/20/2008 23:00 FAX RICCI LEOPOLD COMMITTED TO JUSTICE, TRUTH & SAFETY 001 RICCI~LEOPOLD CONSUMER JUSTICE ATTORNEYS February 21, 2008 VIA: FACSIMILE & U.S. MAIL Jack A. Goldberger, Esq. Atterbury, Goldberger, et al 250 S Australian Ave Ste 1400 West Palm Beach, FL 33401-5015 Re: Jane Doe v. Epstein Dear Jack: This letter is written due to the deep and serious concern about the ethics of your co-counsel. Because your co-counsel refused to provide copies of the documents and photographs used in his direct examination of yesterday to the State Attorney or me, which is the professional and customary thing to do, and the fact that he refused to even allow the court reporter to mark the documents as exhibits I am quite fearful we may never see the exhibits again. Therefore I am compelled to write this letter to confirm that you have agreed that you will provide the State Attorney and me copies of all the exhibits, properly identified, that were used during the direct examination. Very truly yours, THEODORE J. LEOPOLD TJL:ms cc: Michael Tein, Esq. (via facsimile and regular mail) Lanna Belohlavek, Esq. (via facsimile and regular mail) 2925 PGA Boulevard Suite 200 Palm Beach Gardens Florida 33410 561.684.6500 fax 561.697.2383 riccilaw.com CRASHWORTHINESS · INSURANCE BAD FAITH · MANAGED CARE ABUSE · PERSONAL INJURY DOJ-OGR-00031537