EFTA02745507

Extracted Text #

Case 9:08-cv-80119-KAM Document 228-1 Entered on FLSD Docket 07/29/2009 Page 1 of 1 
1. MICHAEL BURMAN. PA.,
GREGORY W. COLEMAN, PA. 
ROBERT D. CRITTON.JR.. PA" 
BERNARD LEREDEKER 
MARX T. =TIER. PA. 
JEFFREY C. PEPPN 
PA/CHAD-1. PIKE 
HEATHER MCNAMARA RUDA 
FLORIDA BOARD CERTIFIED 
Civic/nowt LAWYER 
BURMAN, CRITTON, LUTTIER 
& COLEMAN LLP 
A LIMITED UABILLTY PARTNERSHIP 
July 23, 2009 
Sent via E-Mail and US. Mail 
Jack II Esq. 
Searcy Denney Scarola Barnhart & Shipley, PA 
2139 Palm Beach Lakes Blvd. 
West Palm Beach, FL 33409 
Re: C.M.A. v. Epstein, et al. 
Dear Jack: 
ADELINE). BENAVENIE 
MMAUNALI ridvallOARX 
BARBARA M. McKENNA 
ASHLIE STOKENBARING 
BETTY STOKES 
MRALECIALS 
RITA H. BUDNYK 
01. COUtala 
Please be advised that I intend to schedule the depositions of Susan Pope and Dr. Serge 
Thys as witnesses in C.M.A.'s case within the next ten (10) days. Would you please provide me 
with a date(s) that will work with your schedule? Also, will you agree to a compulsory 
psychological/psychiatric exam of C.M.A. within the next two (2) weeks? 
If you intend to file protective orders regarding the above matters, please advise, and I 
will go ahead and notice the depositions and file a motion with the court regarding the exam 
paving the way for you to file your protective orders and response. 
As you know, we have deadlines in this case that are rapidly approaching and it is my 
intention to get things moving as soon as we can. Please let me know your position as soon as 
possible. 
RDC/clz 
cc: Richard Willits, Esq. 
Jack A. Goldberger, Esq. 
L•A•W•Y•E•R•S 
515 N. FLAOLER DRIVE / SUITE 400 / WEST PALM BEACH, FLORIDA 33401 
TELEPHONE ([Phone Redacted] PAX ([Phone Redacted] 
mailebelelaw.tom ...XHIBIT 
EFTA02745507