Epstein Secrets

R. PA JEFFREY C PEPIN MICHAEL J. PIKE HEATHER MCNAMARA RUDA DAVID A. YAREMA 'NORM A BOARD CERTIFIED CIVIL ULU. LAWYER 2ADMITTEDd73WiC6C1; Mali Spencer T. Kuvin, Esq. Leopold-Kuvin, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Re: B.B. v. Epstein January 7, 2010 ADELOVI J. BENAVENTE PAM

ULU. LAWYER 2ADMITTEDd73WiC6C1; Mali Spencer T. Kuvin, Esq. Leopold-Kuvin, P.A. 2925 PGA Blvd., Suite

this case. His only involvement was as related by former Palm Beach Chief Michael Reiter at his deposition. If your client had any contact with Mr. Goldsmith through Mr. Epstein, then clearly, the deposition may have some relevance. However, if your sole purpose is to establish that Mr. Goldsmith contact

rd day of November, 2009, 6 pursuant to Notice in said cause for theitaking ofsaid 7 deposilion.on behalfof the Plaintiff. 8' 9 OF PLAINTIFF B.B.r 10 SPENCER T. KUVIN. ESQ. LEOPOLiKKUVIN,P.A. 11 2925.*PGA Boulevard, Suite 200 Palm Beach Gardens, Florida ,33410 12 13 .APPEARING ONBEHAEEOF PLAINTIFFS'JANE DOES 2-8: 1

ifthat doesn't work there's an attack on the investigators. I don't know, I don't know. Shouldn't,say that. MR. CRITTON: Form, move to strike. BY MR. KU VIN: Q You were working as a police officer for twenty-eight years and then as a chief — well ■- A And two years prior to that actually. Q Right. During

blems, why did I do that, why am I after.Jeffrey Epstein. A couple of occasions that was the general, topic of the discussion. Q Did you know who Mr. Goldsmith was? A Yes. 1 know them all. Q Lives on the island? A As far as I know, yes. 18 (Pages; 69 to 72.) Pleasanton, Greenhill, Meek and Associates- 561-83

MCDONALD,JOHN R BREKUS,GORDON L KUVIN,SANFORD F HARRINGTON,RICHARD L VILL

DUKCEVICH,VLADO GRUSS,MARTIN GOLDSMITH,C GERALD BROWN,NANCY I MCCARTHY,RIC

D IT LEOPOLD-KUVIN A CONSUMER JUSTICE ATTORNEYS January 7, 2010 V

Dear Bob: Thank you for your letter of January 7, 2010. Initially, I find it interesting that you respond to my request for deposition dates of Mr. Goldsmith while ignoring all of my correspondence regarding the motion you currently have set for January 26, 2010. Regardless, I respectfully disagree with

D IT LEOPOLD-KUVIN A CONSUMER JUSTICE ATTORNEYS January 7, 2010 V

Dear Bob: Thank you for your letter of January 7, 2010. Initially, I find it interesting that you respond to my request for deposition dates of Mr. Goldsmith while ignoring all of my correspondence regarding the motion you currently have set for January 26, 2010. Regardless, I respectfully disagree with

Suite 450, West Palm Beach, FL 33401. LEOPOLD-.KUVIN, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach

B Case No: 502008CA037319)OOOCMB AB Plaintiff, vs. JEFFREY EPSTEIN Defendant. PLAINTIFF'S RE-NOTICE OF TAKING DEPOSITION (Coordinated with Mr. Goldsmith's attornev's office) PLEASE TAKE NOTICE THAT THE UNDERSIGNED' ATTORNEY WILL TAKE THE DEPOSITION OF: NAME: DATE AND TIME: LOCATION: Charles Geral