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Document DOJ-OGR-00031570

AI Analysis

Summary: The letter, dated March 28, 2008, is from Stuart S. Mermelstein to Lanna Leigh Belohlavek, requesting coordination on depositions in the Jeffrey Epstein case, and suggesting a single deposition for the victims to be used in both the criminal and civil cases.
Significance: This document is potentially important as it reveals the coordination between the State Attorney's Office and the victims' attorneys in the Jeffrey Epstein case, and highlights the efforts to minimize the emotional burden on the victims by limiting the number of depositions.
Key Topics: Coordination of depositions in a criminal and civil case Request for a court order for a single deposition Jeffrey Epstein case
Key People:
  • Stuart S. Mermelstein - Attorney for the victims
  • Lanna Leigh Belohlavek - State Attorney's Office representative
  • Jeffrey Epstein - Defendant in the criminal and civil cases
Document Type
Letter
Date
March 28, 2008
Pages
1
Folder
IMAGES012
Has Handwriting
Yes

Full Text

305-9312200 Herman &Mermelstein P 11:24:37 a.m. 28-03-2008 2/2 HERMAN & MERMELSTEIN PA ATTORNEYS AT LAW Stuart S. Mermelstein Tel 305-931-2200 Fax 305-931-0877 ssm@hermanlaw.com 18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 www.hermanlaw.com March 28, 2008 VIA FACSIMILE Lanna Leigh Belohlavek State Attorney's Office 401 N. Dixie Hwy West Palm Beach, FL 33401 Re: State of Florida v. Jeffrey Epstein, Case No. 2006CF009454AXX Dear Ms. Belohlavek: We have left a number of messages with you to coordinate depositions of our clients in this case, without response. With regard to the depositions of our clients, it is necessary and appropriate for the entry of a court order which would require that one deposition be taken of each of our clients for use in both the criminal case and the civil case. A single deposition is warranted given that the facts of the sexual assault are common to both the civil and criminal cases, and the Defendant, Jeffrey Epstein, is the same in both cases. A single deposition is in the best interests of the emotional well being of the victim. In another case we were involved in where both a civil case and a criminal case were pending, the State Attorney's office filed a motion for protective order in the criminal case pursuant to Fla.R.Crim.P. 3.220(l)(l) asking that the depositions in both the criminal and civil case be conducted at the same time. We would like to coordinate and cooperate with your office with regard to this issue concerning the depositions of our clients. The deposition of is presently scheduled for Wednesday, April 2, 2008. Please let us know how you would like to proceed in this important matter as soon as possible. Very truly yours, Stuart S. Mermelstein SSM/lr 07/26/17 Page 49 Public Records Request No.: 17-295 DOJ-OGR-00031570