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Document DOJ-OGR-00031855

AI Analysis

Summary: The letter is from Jeffrey M. Herman to Jack A. Goldberger, requesting to reschedule a deposition and to conduct a single deposition for both criminal and civil matters related to Jeffrey Epstein's case.
Significance: This document is potentially important as it relates to the representation of Jeffrey Epstein in a criminal case and civil matters, and reveals communication between his attorney and opposing counsel regarding deposition scheduling.
Key Topics: Deposition rescheduling Jeffrey Epstein case Criminal and civil matters
Key People:
  • Jeffrey M. Herman - Attorney representing Jeffrey Epstein
  • Jack A. Goldberger - Opposing attorney
  • Jeffrey E. Epstein - Client of Jeffrey M. Herman
  • Lanna Leigh Belohlavek - Assistant State Attorney

Full Text

305-9312200 Herman &Mermelstein, P 11:43:41 a.m. 20-03-2008 3 /4 HERMAN & MERMELSTEIN PA ATTORNEYS AT LAW Jeffrey M. Herman Tel 305.931.2200 Fax 305.931.0877 jherman@hermanlaw.com 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 www.hermanlaw.com March 20, 2008 Via Facsimile and U.S. Mail Jack A. Goldberger, Esq. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401 Re: State of Florida v. Jeffrey E. Epstein Case No.: 2006CF009454AXX Dear Mr. Goldberger: As you know, we represent in all matters pertaining to Jeffrey Epstein. We understand that you scheduled Ms. for deposition on April 2, 2008. We would like to reschedule the deposition to a date convenient for Ms. : and myself. In addition, we would like to conduct a single deposition to be used for both the criminal and the civil matters. Please let us know if you will agree to this or if we should seek court approval for same. Of course, we understand that the State Attorney's Office will need to agree to this as well, and we have not yet contacted them for approval. Sincerely Jeffrey M. Herman JMH/lr cc: Lanna Leigh Belohlavek, Asst. State Attorney 07/26/17 Page 10 of 94 Public Records Request No.: 17-295