EFTA00612072.pdf

LEOPOLD-KUVINL, CONSUMER JUSTICE ATTORNEYS May 6, 2010 CERTIFIED MAIL RETURN RECEIPT REQUESTED Maritza Milagros Vasquez 1263 S.W. 21st Terrace Miami, FL 33145 Re: Jeffrey Epstein Dear Ms. Vasquez: Enclosed please find a copy of Re-notice of Taking your Deposition which is now scheduled for Tuesday, June 15, 2010 beginning at 10:00 a.m. Please be advised that you are still under subpoena and your appearance at this deposition is mandatory. Should you have any questions, please don't hesitate to contact me at your convenience. 2925 PGA Boulevard v Suite 200 n Palm Beach Gardens •• Florida 33410 is 561.515.1400 n fax 561.515.1401 r- leopoicartivin.com CRASHWORTHINESS • MANAGED CARE ABUSE CONSUMER CLASS ACTIONS • PERSONAL INJURY • WRONGFUL DEATH EFTA00612072  UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA C. L. Case No: 10-80447-cv-Marrallohnson Plaintiff, vs. JEFFREY EPSTEIN Defendant. PLAINTIFF'S RE-NOTICE OF TAKING VIDEO DEPOSITION PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF: NAME: DATE AND TIME: LOCATION: Maritza Milagros Vasquez June 15, 2010 Intelligent Office, 701 Brickell 10:00 AM Avenue, Suite 1550, Miami, FL 33131 upon an oral examination before Videographer and a Notary Public or officer authorized by law to take depositions in the State of Florida. The oral examination will continue from day to day until completed. The depositions are being taken for purposes of discovery, for use at trial or are being taken for such other purposes as are permitted under the Rules of the Court. WE HEREBY CERTIFY that a true and correct copy of this Notice was mailed this 7 day of /4 F2010 to Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm Beach, FL 33401; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 303 Banyon Boulevard, Suite 400, West Palm Beach, FL 33401. LEOPOLD-KUVIN, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 (561) 515-1 (561) 51 By: in, Esq. Cc: Prose Court Reporting Florida Bar No: 089737 Visual Evidence EFTA00612073  Farmer, Jaffe, Weissing, !14r, a, • Class Action Edwards, Fistos a Lehrman, P.L. Persona:Injury Wroiigki Dnitti COtliffierCial Litigatien PiusncE.com May 7, 2010 Honorable Donald W. Hafele Main Judicial Complex Palm Beach County Courthouse 205 North Dixie Highway, Room 11.1204 West Palm Beach, Florida 33401 Re: LM. v. Jeffrey Epstein / Case No. 502008CA028051XXXXMB AB -and- E.W. v. Jeffrey Epstein / Case No. 502008CP003626XXXXMB Dear Judge Hafele: Enclosed please find copies of Plaintiffs' proposed Agreed Orders concerning the hearing on Defendant, Jeffrey Epstein's Motion for Partial Summary Judgment on Count I of Plaintiff's Second Amended Complaint that took place on April 9, 2010, in the above-captioned matters. Should both of these Agreed Orders meet with Your Honor's approval, please execute same in both matters and provide conformed copies to all counsel in the enclosed prepaid self- addressed envelopes provided. If you have any questions, please feel free to call. hank you for your time and attention to this matter. armer, J es as stated GMF/nas cc: Robert D. Critton, Esq. ✓ Jay Howell, Esq. Jack Goldberger, Esq. 425 North Andrews Avenue • Suite 2 • Fort Lauderdale, Florida 33301 954.524.2820 office 954.524.2822 fax EFTA00612074  IN THE CIRCUIT COURT OF THE 15Th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502008CA028051XXXXMB AB L.M., Plaintiff. v. JEFFREY EPSTEIN, Defendant. AGREED ORDER ON DEFENDANT, JEFFREY EPSTEIN'S MOTION FOR PARTIAL SUMMARY JUDGMENT ON COUNT I OF PLAINTIFF'S SECOND AMENDED COMPLAINT THIS CAUSE came on to be heard on April 9, 2010 upon Defendant, Jeffrey Epstein's Motion for Partial Summary Judgment on Count I of Plaintiffs Second Amended Complaint; the Court having reviewed and considered the motion and the record and otherwise being fully advised in the premises, it is hereby ORDERED AND ADJUDGED that: During the hearing, Plaintiffs counsel indicated a desire to amend the Complaint. As such, the Court will deny as moot Defendant, Jeffrey Epstein's Motion for Partial Summary Judgment on Count I of Plaintiffs Second Amended Complaint at this time so as to allow the Plaintiff, L.M. to file an Amended Complaint within twenty (20) days of the date of this Order. Thereafter, Defendant. Jeffrey Epstein shall have twenty (20) days to file a responsive pleading. DONE AND ORDERED at Palm Beach County Courthouse, Palm Beach County, Florida, this day of 2010. HONORABLE DONALD W. HAFELE Circuit Court Judge COoleS furnished to• Gary M. Farmer, Jr., Esq. Bradley J. Edwards. Esq. Robert D. Critton, Jr., Esq. Jay Howell, Esq. Jack Alan Goldberger, Esq. EFTA00612075  IN THE CIRCUIT COURT FOR THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY. FLORIDA CASE NO. 502008CP003626XXXXMB E.W., Plaintiff, v. JEFFREY EPSTEIN, Defendant. AGREED ORDER ON DEFENDANT. JEFFREY EPSTEIN'S MOTION FOR PARTIAL SUMMARY JUDGMENT ON COUNT I OF PLAINTIFF'S SECOND AMENDED COMPLAINT THIS CAUSE came on to be heard on April 9, 2010 upon Defendant, Jeffrey Epstein's Motion for Partial Summary Judgment on Count I of Plaintiffs Second Amended Complaint; the Court having reviewed and considered the motion and the record and otherwise being fully advised in the premises, it is hereby ORDERED AND ADJUDGED that: During the hearing, Plaintiffs counsel indicated a desire to amend the Complaint. As such, the Court will deny as moot Defendant, Jeffrey Epstein's Motion for Partial Summary Judgment on Count I of Plaintiff's Second Amended Complaint at this time so as to allow the Plaintiff, E.W. to file an Amended Complaint within twenty (20) days of the date of this Order. Thereafter, Defendant, Jeffrey Epstein shall have twenty (20) days to file a responsive pleading. DONE AND ORDERED at Palm Beach County Courthouse, Palm Beach County, Florida, this day of , 2010. Copies furnished to: HONORABLE DONALD W. HAFELE Gary M. Farmer, Jr., Esq. Circuit Court Judge Bradley J. Edwards. Esq. Robert D. Craton, Jr., Esq. Jay Howell, Esq. Jack Man Goldberger, Esq. EFTA00612076