DOJ-OGR-00031570.jpg
604 KB
Extraction Summary
3
People
3
Organizations
4
Locations
2
Events
3
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
604 KB
Summary
Attorney Stuart S. Mermelstein of Herman & Mermelstein PA sends a letter via facsimile to Lanna Leigh Belohlavek at the State Attorney's Office regarding the case State of Florida v. Jeffrey Epstein. Mermelstein requests coordination for client depositions, arguing for a single deposition per client to be used in both the civil and criminal cases to protect the victims' emotional well-being. He notes that a deposition is scheduled for April 2, 2008, and urges a prompt response.
People (3)
| Name | Role | Context |
|---|---|---|
| Stuart S. Mermelstein | Attorney |
Author of the letter, representing clients in the case against Jeffrey Epstein.
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| Lanna Leigh Belohlavek |
Recipient of the letter, works at the State Attorney's Office.
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|
| Jeffrey Epstein | Defendant |
Named as the Defendant in the case State of Florida v. Jeffrey Epstein, Case No. 2006CF009454AXX.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| HERMAN & MERMELSTEIN PA | law firm |
The law firm that sent the letter, represented by Stuart S. Mermelstein.
|
| State Attorney's Office | government agency |
The office where the recipient, Lanna Leigh Belohlavek, works. Mentioned as having previously filed a motion for a pr...
|
| State of Florida | government entity |
The plaintiff in the case against Jeffrey Epstein.
|
Timeline (2 events)
2008-04-02
A deposition of one of the clients is scheduled for this date.
client of Stuart S. Mermelstein
Ongoing legal case State of Florida v. Jeffrey Epstein, Case No. 2006CF009454AXX.
Florida
Locations (4)
| Location | Context |
|---|---|
|
The address of the law firm HERMAN & MERMELSTEIN PA.
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|
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Location of the law firm HERMAN & MERMELSTEIN PA.
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|
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The address of the State Attorney's Office.
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Location of the State Attorney's Office.
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Relationships (3)
Mermelstein, an attorney for victims, is writing to Belohlavek at the State Attorney's Office to coordinate legal proceedings in a shared case.
Mermelstein represents clients (victims) in a legal case against the defendant, Jeffrey Epstein.
The State of Florida is the plaintiff in the criminal case against the defendant, Jeffrey Epstein.
Key Quotes (2)
"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."Source
— Stuart S. Mermelstein
(Justification for requesting a court order to require only one deposition per client for use in both the criminal and civil proceedings against Jeffrey Epstein.)
DOJ-OGR-00031570.jpg
Quote #1
"A single deposition is in the best interests of the emotional well being of the victim."Source
— Stuart S. Mermelstein
(Further reasoning for why a single deposition should be conducted, focusing on the impact on the victim.)
DOJ-OGR-00031570.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (1,845 characters)
305-9312200 Herman & Mermelstein, P 11:24:24 a.m. 28-03-2008 2/2
HERMAN & MERMELSTEIN PA
ATTORNEYS AT LAW
ATTORNEYS AT LAW
Stuart S. Mermelstein
Tel 305-931-2200
Fax 305-931-0877
ssm@hermanlaw.com
Tel 305-931-2200
Fax 305-931-0877
ssm@hermanlaw.com
18205 Biscayne Boulevard
Suite 2218
Miami, Florida 33160
www.hermanlaw.com
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
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)(1) 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 [redacted] 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,
[Signature]
Stuart S. Mermelstein
[Signature]
Stuart S. Mermelstein
SSM/lr
07/26/17
Page 49
Public Records Request No.: 17-295
DOJ-OGR-00031570
Page 49
Public Records Request No.: 17-295
DOJ-OGR-00031570
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