Case 9:09-cv-80591-KAM Document 28-2 Entered on FLED Docket 05/26/2009 Page 1 of 4 Podhurst Orseck TRIAL & APPELLATE Aaron S. Podhurst Robert alpiefsberg Joel D. Steven C. Marks Victor M. S Jr. Katherine W. Ezell Stephen P. Rosenthal Ricardo M. Martinez-Cid Ramon A. Rasco Alexander T. Rundlet John Gravante, RI Carolina Maharblz LAWYERS Robert Chuck (1934-1978) Walter H. Beckham, Jr. Karen Podhurst Dem Of Counsel May 15, 2009 Robert D. Critton, Jr., Esq. Burman Critton Luttier & Coleman 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401-2918 Jack Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Re: Preservation of Evidence Relevant to Actions for Civil Remedies Pursuant to 18 U.S.C. §2255 Gentlemen: As you know, we represent a number of the young women on the list of names provided to Messrs. Goldberger and Tein by the U.S. Attorney's Office regarding the Jeffrey Epstein NonProsecution Agreement and Addendum. In order to bo crystal clear as to whom wo represent, we have attached a list of our present clients. By this letter, we want to ensure that discoverable information relating to each of their civil actions is being properly preserved, as is required under Rule 34 of the Federal Rules of Civil Procedure. You are required to take the neceqqary steps to preserve all paper documents, tangible objects (including, but not limited to, film, videos, DVDs, photographs, whether in hard copy, negatives or digital images), and electronically stored information related to any threatened action by my clients, whether found inside or outside of the United States, including any information held by third parties. Although we may bring a motion for an order preserving documents and other data from destruction or alteration, your client's obligation to preserve documents and other data discovery in this case arises independently from any order on such motion. As you know, the Non-Prosecution Agreeme