EFTA00723518

BURMAN. CRITTON 
LUTTIER &COLEMAN. us 
YOUR TRUSTED 
ADVOCATES 
A LIMITED LIABILITY PARTNERSHIP 
J. MICHAEL BURMAN. P.A.'3 
ADELOVI J. BENAVENTE 
GREGORY W. COLEMAN. P.A. 
PAPAUGAVINvESTIGATot 
Miser D. CRITTON. JR, PA • 
JESSICA CADweu. 
BERNARD A. LEBEDEKER 
BOBBIE M. MCKENNA 
MARKT. LUSTIER PA 
ASHLIE troKEN-BARING 
JEFFREY C. PENN 
BETTY STOKES 
MICHAEL J. PIKE 
PARAuGALs 
HEATHER MCNAMARA RUDA 
FUTA H. BuDNYK 
DAVID A. YAREMA 
or oouNSEL 
'FLORIDA (*AID CILIKTUUD CIVIL TRIAL LAWYER 
1/40Atrilto To prucricE IN FLORIDA ANoCotomoo 
January 5, 2010 
Sent by E-Mail and U.S. Mail 
Joanne O'Connor, Esq. 
Jones Foster Johnston & Stubbs, P.A. 
505 South Flagler Drive, Suite 11 
West Palm Beach, FL 33401 
Re: 
Epstein Matter 
Dear Joanne: 
EDWARD M. RICCI 
THC1AL CORWMIll 
ILISTICT COUNSEL 
I am following up on the Non-Party Town of Palm Beach Police Officers' Motion to 
Quash Subpoena and/or Motion for Protective Order which you served on November 23, 
2009. I never received any objection from the Town of Palm Beach. If one was served, 
please bring it to my attention. 
Before noticing a hearing on your Motion to Quash/Motion for Protective Order, it 
maybe a good idea for you to file a response to the subpoenas by each officer and the 
Town of Palm Beach. That is, if the officer and/or the Town takes a position that no 
documents exist with regard to a particular category, advise me and the court of that fact 
so that we are not arguing about some non-Issue. Please let me know if this approach is 
acceptable to you. Additionally, you referenced in your December 9, 2009 letter "attached 
please find responsive, nonprivileged and nonstatutory protected, document in response to 
the duces tecum served by counsel for Mr. Epstein on the Town of Palm Beach Police 
Department Record Custodian." 
You need to identify what "privileged and statutory protected documents" exist 
which you are specifically not producing. I believe a privilege log is required under the 
circumstances both under case law and certainly local procedure. 
303 BANYAN BOULEVARD • SUITE 400 • WEST PALM BEACH. FL 33401 • PHONE: S61442,2820 • FAX; S614144-6929
WWW.BCLCLAW.COM 
EFTA00723518

Page 2 
January 5, 2010 
Joanne, in looking at what was produced, specifically Administrative Order G.O. 11-
65, I have the amendment effective January 15, 1999 and the amendment effective June 
15, 2009. However, the June 15, 2009 amendment, amended G.O. 11-65 dated August 
29, 2000, and that document was not provided. 
Cordially y 
Robe D. Critton, Jr. 
RDC/clz 
EFTA00723519