mirror-epstein-docs/results/IMAGES012/DOJ-OGR-00031853.json

{
  "document_metadata": {
    "page_number": "8",
    "document_number": "17-295",
    "date": "February 22, 2008",
    "document_type": "Letter",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "LEWIS TEIN PL ATTORNEYS AT LAW February 22, 2008 Copy Via Facsimile Theodore Leopold Ricci-Leopold \"Consumer Justice Attorneys\" 2925 PGA Boulevard, # 200 Palm Beach Gardens, Florida 33410 Dear Mr. Leopold: Yesterday's fax from you is more of the same misrepresentation of the record and self-serving grandstanding that you engaged in throughout Wednesday's deposition. Anyone who reads the transcript will see the desperate tactics you used. You had no standing to object on any basis other than privilege. Despite that, you made improper speaking objections, mischaracterized the record and coached your client's answers. Ms. deposition proves beyond any doubt that the intervener's complaint that you filed against Mr. Epstein for $50,000,000.00 [sic] is frivolous and violates Fed. R. Civ. P. 11. Beyond your stunts and meritless allegations, you clearly lied to us about your availability for the deposition, necessitating Mr. Goldberger's changing his vacation plans. Finally, your letter, like your reckless and libelous accusations, is nonsense. The deposition exhibits - including the photos that your client posted on the Internet of herself in various states of undress simulating intercourse, fellatio and violent gang rape - were numerically stamped and bar-coded. You well know that we provided the court reporter with color copies, which will be attached to the deposition transcript. You also know that both you and Ms. Belohlavek agreed to that procedure before you left the deposition room. If you have any question about the authenticity of the photographs when you receive the exhibits, you can ask your client about the evidence she destroyed last week after she was already under subpoena. I hope that in the future you can comport yourself within the bounds of professionalism. Very truly yours, Michael R. Tein cc: Jack Goldberger, Esq. Lanna Belohlavek, Esq. Page 8 of 94 Public Records Request No.: 17-295 3059 GRAND AVENUE - SUITE 340 COCONUT GROVE, FLORIDA 33133 TELEPHONE (305) 442-1101 · FACSIMILE (305) 442-6744 · WWW.LEWISTEIN.COM 07/26/17 DOJ-OGR-00031853",
  "text_blocks": [
    {
      "type": "printed",
      "content": "LEWIS TEIN PL ATTORNEYS AT LAW",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "February 22, 2008 Copy Via Facsimile Theodore Leopold Ricci-Leopold \"Consumer Justice Attorneys\" 2925 PGA Boulevard, # 200 Palm Beach Gardens, Florida 33410 Dear Mr. Leopold:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Yesterday's fax from you is more of the same misrepresentation of the record and self-serving grandstanding that you engaged in throughout Wednesday's deposition. Anyone who reads the transcript will see the desperate tactics you used. You had no standing to object on any basis other than privilege. Despite that, you made improper speaking objections, mischaracterized the record and coached your client's answers. Ms. deposition proves beyond any doubt that the intervener's complaint that you filed against Mr. Epstein for $50,000,000.00 [sic] is frivolous and violates Fed. R. Civ. P. 11. Beyond your stunts and meritless allegations, you clearly lied to us about your availability for the deposition, necessitating Mr. Goldberger's changing his vacation plans.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Finally, your letter, like your reckless and libelous accusations, is nonsense. The deposition exhibits - including the photos that your client posted on the Internet of herself in various states of undress simulating intercourse, fellatio and violent gang rape - were numerically stamped and bar-coded. You well know that we provided the court reporter with color copies, which will be attached to the deposition transcript. You also know that both you and Ms. Belohlavek agreed to that procedure before you left the deposition room. If you have any question about the authenticity of the photographs when you receive the exhibits, you can ask your client about the evidence she destroyed last week after she was already under subpoena.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "I hope that in the future you can comport yourself within the bounds of professionalism.",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "Michael R. Tein",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "Very truly yours, Michael R. Tein cc: Jack Goldberger, Esq. Lanna Belohlavek, Esq.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "Page 8 of 94 Public Records Request No.: 17-295 3059 GRAND AVENUE - SUITE 340 COCONUT GROVE, FLORIDA 33133 TELEPHONE (305) 442-1101 · FACSIMILE (305) 442-6744 · WWW.LEWISTEIN.COM 07/26/17 DOJ-OGR-00031853",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Theodore Leopold",
      "Michael R. Tein",
      "Jack Goldberger",
      "Lanna Belohlavek",
      "Mr. Epstein"
    ],
    "organizations": [
      "Ricci-Leopold \"Consumer Justice Attorneys\"",
      "Lewis Tein PL"
    ],
    "locations": [
      "Palm Beach Gardens, Florida",
      "Coconut Grove, Florida"
    ],
    "dates": [
      "February 22, 2008",
      "07/26/17"
    ],
    "reference_numbers": [
      "17-295",
      "DOJ-OGR-00031853"
    ]
  },
  "additional_notes": "The document appears to be a letter from Michael R. Tein to Theodore Leopold regarding a deposition and allegations against Mr. Epstein. The letter is on Lewis Tein PL letterhead and includes contact information for the firm. The document has been stamped with a page number and a public records request number."
}