📄 Extracted Text (6,240 words)
IN THE COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO. 502008CA028058XXXXMB AD
Plaintiff,
v.
JEFFREY EPSTEIN
Defendant.
ORDER ON MOTION TO REASSIGN AND/OR TRANSFER
THIS CAUSE came before the Court on Motion to Reassign and/or Transfer, and
the Court having heard argument of counsel and being fully advised in these premises,
it is hereby
ORDERED and ADJUDGED that.Defendant's Motion is herebyeatat)tedi denied
•s--•
DONE AND ORDERED at Palm Beach County Courthouse, tAtin Beach,
G
Florida, this day of , 2009.
tr:AGO ) .1 its
it Our'
c
C•T
David French Vr-
Circuit Judge
Copies furnished:
TTON, JR., ESQ., and MICHAEL J. PIKE, ESQ.,
and BRAD EDWARDS, ESQ., Brad Edwards and Associates,
JAY HOWELL, ESQ., Jay Howell & Associates, PA..
and JACK A. GOLDBERGER, ESQ., Atterbury Goldberger
EFTA00614418
IN THE COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO. 502008CA028051WXMB AD
Plaintiff,
v.
JEFFREY EPSTEIN
Defendant.
ORDER ON MOTION TO REASSIGN AND/OR TRANSFER
THIS CAUSE came before the Court on Motion to Reassign and/or Transfer, and
the Court having heard argument of counsel and being fully advised in these premises,
it is hereby
ORDERED and ADJUDGED that Defendant's Motion is hereby gamed/ denied
DONE AND ORDERED at Palm Beach County Courth st Palm Beach,
Florida, this day of , 2009SAGOO
et -, IREml
VA
r e `0 •
David French' .
Circuit Judge
Copies furnished:
ROBERT D. CRITTON, JR., ESQ., and MICHAEL J. PIKE, ESQ.,
and BRAD EDWARDS, ESQ., Brad Edwards and Associates, LLC
HOWELL, ESQ., Jay Howell & Associates, PA,
and JACK A GOLDBERGER, ESQ., Atterbury Goldberger
EFTA00614419
e g sz
LEOPOLD—KUVIN, ATTORNEYS
CONSUMER JUSTICE
April 10, 2009
Fax and Mail
Robert Critton, Esq.
Michael Pike, Esq.
Burman Critton, et. al.
MEM
Re: inv. JEFFREY EPSTEIN
OUR FILE NO.: 080303
Dear Mike and Bob:
I recently received your Motion to Compel directed to Plaintiff's responses to Request to
Produce. With respect to request #2, I'm not sure what you'd like my client to do, but she does
not have any additional bills to produce to you at this time. She is only required to produce what
she has, and she has done that. Additionally, you have already served subpoenas for these
records, so I'm not sure why you'd waste time on this part of your motion.
As for request #7, I will be happy to supplement this request by attempting to obtain any c*L
of insurance cards that she may have for her health insurance. I will also make sure that my MI
-Plaintiff provides copies of any "union employment identification cards."
With respect to request #17 and #18, much like the Interrogatory you asked in this regard, it is
objectionable and I will see you at hearing. Furthermore, if the request did not already state so,
the response even absent these objections is none.
With respect to request #22, this is incredibly overbroad and invasive. Having said that, if you
are willing to allow me to inspect every and all computers utilized by Jeffrey Epstein at the same
time that you inspect my client's computer, I may be able to come to some agreement. I don't
expect you'll allow this. I find to it extremely hard to understand how you're going to be able to
argue to the Court that my client's entire computer should be subjected to your inspection while
you are unwilling to do the same. Furthermore, the computers in my client's home are used, and
have been used, by numerous individuals, including but not limited to family members, business
associates and friends. Obviously, each of these individuals and corporations have independent
rights to privacy which cannot be infringed.
RIOPOICINUVrt.Com
ACTIONS • PERSONAL INJURY • WRONGFUL DEATH
CRASHWORTHINESS • MANAGED CARE ABUSE • CONSUMER. CLASS
EFTA00614420
April 10, 2009
Page 2 of 2
Finally, your completely irrelevant comments from public websites of random individuals,
including postings of other girls which may have been molested by your client, are completely
irrelevant. While we are commenting on websites, my client happened to notice on your firm's
website that you have resolved sexual harassment cases for $1.5 million. If you would like to
use websites as a guide, maybe we can discuss resolving this case without the need for these
discovery disputes.
I agree with your statement contained within the motion that states that "Plaintiff's
communions and interactions with others is discoverable and admissible." However, the
proper to go about this is by taking depositions, not by digging through her personal
computer.
If you would like to amicably resolve this matter absent a hearing, please do not hesitate to
contact me at your convenience.
T. KUVIN
STK:mlb
EFTA00614421
LEOPOL D-KUVIN.
JUSTICE ATTORNEYS
CONSUMER
April 10, 2009
Fax and Mail
Robert Critton, Esq.
Michael Pike, Esq.
n Critto et. al.
Re: v. JEFFREY EPSTEIN
OUR FILE NO.: 080303
Dear Mike and sob:
8, 2009. Please be advised that
I recently received a copy of your Motion to Compel dated April
ng. As for the content of the
we turn our fax machine off promptly at 5:15 p.m. every eveni
ine whether or not she can provide
motion, I will agree to consult with my client to determ
respect to Interrogatories #15 and
anymore information with response to Interrogatory #2. With
My client has clearly advised, both
#16, I am not sure what additional information you require.
was only over at the house on one
in her responses, and in reference to the Complaint, that she
a Complaint is not a sworn response,
occasion, and she does not remember the exact date. While
client has hereby confirmed and
by referring to the Complaint in answer to Interrogatories, my
in the Complaint by signing
verified, as well as sworn to, the relevant allegations as referenced
off on her answers to Interrogatories.
ogatory is not only objectionable but
Finally, with respect to Interrogatory #19, your Interr
on this one.
disgusting and beneath all human decency. I will see you in Court
e do not hesitate to give me a call at
Should you have any additional questions or concerns, pleas
your convenience.
leopokkAire.com
WRONGFUL DEATH
UMER .CLASS ACTIONS • PERSONAL INJURY •
CRASHWORTHINESS • MANAGED CARE ABUSE • CONS
EFTA00614422
k
BURMAN, CRITTON, LUTTIER
& COLEMAN LLP
A LIMITED LIABILITY PARTNERSHIP ADELQUI.LBENAVENTE
I. MICHAEL BURMAN, PA., rmemeom.I INVBSTIOMOR
GREGORY W. COLEMAN, PA.
ROBERT D. CRITTON, 111., PA' BARBARA M. NkKENNA
BERNARD LEBEDEKER ASHLER STOKEN-BARING
MARK T. LUTTIER, P.A. BETTY STOKES
JEFFREY C. PEPIN PARALEGALS
MICHAEL 1. PIKE April 13, 2009
HEATHER McNAMARA RUDA RUA H. BUDNYK
2 FLORIDA BOARD CERTIFIED OP COMPEL
CVO-TRIAL LAWYER
Sent by Fax and U.S. Mail
Isidro M. Garcia, Esq.
Garcia Law firm P.A.
Re: Doe II v. Epstein, et al.
Case No. 09-80469-Civ-MARRA/JOHNSON
Dear Sid:
Please be informed that MIEM subpoenaed deposition in the
Epstein case on April 16th, 2009 is hereby cancelled.
Rob rt D. Critton, Jr.
RDC/clz
cc: Jack A. Goldberger, Esq.
.A•W'Y'EeR•S
EFTA00614423
eli-72-\•--,.\
a \
? '-
- : 11.-,-.75C..-.:ca...., -4-•-1/4) , ....
.-
BURMAN, CRITTON, LUTTIER
& COLEMAN LLP
J. MICHAEL BURMAN. PA! A LIMITED LIABILITY PARTNERSHIP ADELQUI J. BENAYENTE
GREGORY W. COLEMAN. PA. PARALEGAL/ INVESTIGATOR
ROBERT D. CRITTON. JR.. PA!
BERNARD LEBEDEKER BARBARA M. WHENNA
MARK T. LUTHER. PA. ASHLIE STOKEN-BARINO
JEFFREY C. PEPIN BETTY STOKES
PARALEGALS
MICHAEL J. PIKE
HEATHER MCNAMARA RUDA
FLOIGOA BOARD anrrusso April 13, 2009 RITA H. BUDNYK
OP COUNSEL
CIVIL TRIAL LAWYER
BY HAND DELIVERY
Judge Donald Hafele
Fifteenth Judicial Circuit
Re: Illv. Jeffrey Epstein, et al.
Case No. 502008CA037319XXXX MBAB
4/17/09, 11:30 a.m. — special set for 30 minutes Hearing on Defendant
Epstein's Motion to Dismiss, for More Definite Statement, and to Strike
Directed to Plaintiffs Complaint
Dear Judge Hafele:
Enclosed please find a copy of the case law and Florida Statutes cited in
Defendant Epstein' otion to Dismiss, For More Definite Statement, and to Strike
Directed to Plaintiff .'s Complaint relating to the above-captioned hearing. We have
previously sent you Defendant's Motion and Plaintiffs complaint.
Also enclosed is Notice of Additional Supplemental Authority in Support of the
above-mentioned Defendant, Epstein's Motion to Dismis s.
Robed Critton, Jr., Esq.
RDC/clz
Enclosures
cc: Theodore J. Leopold, Esq. and Spencer T. Kuvin, Esq.
Jack Goldberger, Esq.
•A•W•Y•E •N•S
EFTA00614424
IN THE COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO. 502008CA037319XXXXMB AB
Plaintiff,
v.
Defendants.
CITED CASES AND FLA. STAT.
IN SUPPORT OF
DEFENDANT EPSTEIN'S MOTION TO DISMISS, FOR MORE DEFINITE
STAEMENT, AND TO STRIKE DIRECTED
TO PLAINTIFF'S COMPLAINT
1. Am. Home Assurance Co. v. Plaza Materials Corp., 908 So.2d 360, 374 (Fla.
2005)
2. Miami Herald Pub. Co. v. Ferre, 636 F.Supp. 970 (S.D. Fla. 1985)
3. Mantooth v. Richards, 557 So.2d 646 (Fla. 4th DCA 1990)
4. Lay v. Kremer, 411 So.2d 1347 (Fla. 1st DCA 1982)
5. Wright v. Yurko, 446 So.2d 1162, 1165 (Fla. 5th DCA 1984).;
6. American Diversified Ins. Srvcs., Inc. v. Union Fidelity Life Ins., 439 So.2d 904
(Fla. 3d DCA 1988)
7. Bond v. Koscot Interplanetary, Inc., 246 So.2d 631 (Fla. 4th DCA 1971
8. Churruca v. Miami Jai-Alai, Inc. 353 So.2d 547 (Fla. 1977).
9. Snipes v. West Flaciler Kennel Club, 105 So.2d 164 (Fla. 1958)
EFTA00614425
• v. Epstein
Page 2
10. Buchanan v. Miami Herald Publishing Co., 230 So.2d 9, 12 (Fla. 1969)
11. Baisch v. Gallina, 346 F.3d 366, 373 (2nd Cir. 2003)
12. Fla. Stat. §772.101, et seq., commonly referred to as Florida "RICO."
EFTA00614426
IN THE COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO. 502008CA037319XXXXMB AB
Plaintiff,
v.
JEFFREY EPSTEIN
and
Defendants.
NOTICE OF ADDITIONAL SUPPLEMENTAL AUTHORITY IN SUPPORT OF
DEFENDANT, EPSTEIN'S MOTION TO DISMISS, MORE DEFINITE
STATEMENT, AND TO STRIKE DIRECTED TO PLAINTIFF'S COMPLAINT
PERSONAL INJURY DAMAGES NOT RECOVERABLE UNDER RICO
1. Jackson v. Bellsouth Communications, 372 F.3d 1250 (11th Cir.
2004), cited in Fla. Stat. 772.102, annotated, (analysis applied to claims under
the Federal Rico Act is equally applicable to claims under the Florida Rico
statute).
2. Moore v. Potter, 142 Fed. Appx. WL 1600194 (11Th Cir. 2005).
3. Pilkington v. United Airlines 112 F.3d 1532, 1536 (11th Cir,1997)
4. Stansfield v. Starkey, 269 Cal.Rptr., 337, 348 (Cal. App.3d, 1990)
5. Zimmerman v. HBO Affiliate Group, 834 F.2d 1163, 1169 (3d Cir.
1987).
6. Connor v. Halifax Hospital Medical Center, 135 F. Supp.2d 1198,
1219 (M.D. Fla. 2001).
EFTA00614427
v. Epstein
Page 2
7. Magnum v. Archdiocese of Philadelphia , 253 Fed. Appx. 224 (3d
Cir. 2007).
8. Petrol LTD v. Radulovic, 764 So.2d 878 (Fla. 4th DCA 2000).
DIRECT INJURIES MUST BE SUSTAINED TO PROPERLY ALLEGE RICO
1. O'Malley v. St. Thomas Univ., Inc. 599 So.2d 999, 1000 (Fla. 3d
(DCA 1992).
2. Palmus Y Bambu, S.A. v. E.I. Dupont De Nemours & Company,
881 So.2d 565 (Fla. 3rd DCA 2004).
3. Bivens Gardens Office Bldg., Inc. v. Barnett Banks of Fla., Inc., 140
F.3d 898, 906, 908 (1191 Cir. 1998).
4. Baisch v. Gallina, 346 F.3d 366, 373 (2d Cir. 2003).
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and
U.S. Mail to the Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq.,Leopold-
Kuvin, P.A.,
Counsel for Plaintiff; Jack Alan Goldberger, Esq., Atterbury Goldberger & Weiss,
Co-Counstaerfor Defendant Jeffrey Epstein, on this / Sia of April, 2009
& COLEMAN, LLP
By:
Robert D. Cr
Florida Bar
Michael J. Pik
Florida Bar #617296
(Counsel for Defendant Jeffrey Epstein)
EFTA00614428
IN THE COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO. 502008CA037319)COO(MB AB
Plaintiff,
v.
Defendants.
DEFENDANT'S, JEFFREY EPSTEIN, AMENDED OBJECTION TO PRODUCTION
FROM NON-PARTY, YELLOW CAB
Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), by and through his
undersigned attorneys, pursuant to Rule 1.351, Fla. R. Civ. P., hereby objects to the
Notice of Production from Non-Party directed to Yellow Cab and proposed subpoena,
and amends the objection to the production from Non-Party, Yellow Cab (all attached as
Composite Exhibit "A") and as grounds set forth, would state:
1. Plaintiff, ■ in her answers to interrogatories alleges she was at the
home of Mr. Epstein on one occasion. Answer No. 15 to interrogatories. Within
interrogatory 15, she indicates that "the cab driver (identity unknown) drove.. and
her friend, MEN the Defendant's home." In her complaint, she alleges that in
2005, she was at Mr. Epstein's home on this one occasion.
2. Therefore, if the purpose of the subpoena is to determine the exact date
that ■ andi were at the home of Mr. Epstein on that one occasion, the
subpoena should be so directed to Yellow Cab, i.e. during the year 2005, do you have
EFTA00614429
v. Epstein, et al.
l age 2
any evidence of having carried passengers,. and to the home of Mr.
Epstein?
3. Whereas the duces tecum states:
"You are required to produce a true and accurate copy of
any and all documents of whatever kind '
' ispatch form (sic) or to
for the years 2001 to the present."
How is it relevant or material or calculated to lead to the discovery of admissible
evidence regarding Yellow Cabs that may have been dispatched toMEM or at any
time other than 2005 for one specific trip?
4. Additionally, who may have traveled to or from Mr. Epstein's home during
a specific period of time, other than the Plaintiff an' is irrelevant, immaterial
and not calculated to lead to the discovery of admissible evidence, and as personal
information to third parties who have a right to privacy.
5. This is strictly a "fishing expedition" unrelated to any aspect of this case.
A similar Request to Produce was served in the caa v. Jeffrey E. Epstein and
Case No. 502008CA025129XXXXMB Al, in front of Judge Garrison. A
copy of the objection to the Notice is attached as Exhibit "B" and Judge Garrison's
Order sustaining the objection is attached as "Exhibit "C".
6. Discovery must be related to the subject matter of the pending case.
State Farm v Parrish 800 So. 2d 706 (5th DCA 2001). Exhibit "D"
WHEREFORE, this Defendant moves this Court for an Order sustaining its
objection and quashing the subpoena as written and requiring the Plaintiff, if
appropriate, to serve a very specific subpoena.
EFTA00614430
IIII v. Epstein, et al.
Page 3
Certificate of Service
I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S.
Mail to the following addressees on this 13th day of April 2009:
Theodore J. Leopold, Esq. Jack Alan Goldberger, Esq.
Spencer T. Kuvin, Esq. Atterbury Goldberger & Weiss, P.A.
ISM
Counsel for Plaintiff Co-Counsel for Defendant Jeffrey Epstein
OLEMAN, LLP
Rob rt i n on, r.
Flo da Bar #224162
Michael J. Pike
Florida Bar #617296
(Counsel for Defendant Jeffrey Epstein)
EFTA00614431
IN THE COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO. 502008CA037319XXXXMB AB
Plaintiff,
v.
JE
an
Defendants.
DEFENDANT'S, JEFFREY EPSTEIN, OBJECTION TO PRODUCTION
FROM NON-PARTY, YELLOW CAB
Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), by and through his
undersigned attorney, pursuant to Rule 1.351, Fla. R. Civ. P., hereby objects to the
Notice of Production from Non-Party directed to Yellow Cab, served March 24. 2009.
Pursuant to the rule, a subpoena shall not be served on Yellow Cab under this rule, but
relief may be obtained only through Rule 1.310, Fla. Fla. R. Civ. P.
Certificate of Service
I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S.
Mail to the following addressees on this 31st day of March , 2009:
Theodore J. Leopold, Esq. Jack Alan Goldberger, Esq.
Spencer T. Kuvin, Esq. Atterbury Goldberger & Weiss, P.A.
Counsel for Plaintiff Co-Counsel for Defendant Jeffrey Epstein
effini 'le-
EXHIBIT "An
EFTA00614432
v. Epstein, et al.
Page 2
BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
Robe Critton, Jr.
Flo a Bar #224162
Mi ael J. Pike
Florida Bar #617296
(Counsel for Defendant Jeffrey Epstein)
EFTA00614433
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY,
FLORIDA
CASE NO:
502008CA037319XXXXMB AB
Plaintiff,
vs.
JEFFREY EPSTEIN and■
Defendant.
NOTICE OF PRODUCTION FROM NON PARTY
YOU ARE NOTIFIED that after 10 days from the date of service of this notice, if service
is by delivery, or 15 days from the date of service, if service is by mail and if no objection is
received form any party, the undersigned will issue or apply to the Clerk of the Court for
issuance of the attached subpoena directed to Yellow Cab, who is not a party and whose
principle address a to
produce the items listed at the time and place specified in the subpoena.
HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U. S.
Mail, postage prepaid, thisdday of March, 2009 to Jack A. Goldberger, Esq.,/Bruce E. Reinhart,
Esq. Douglas M. McIntosh, Esq., McIntosh,
Sawran, Peitz & Cartaya, Robert D.
Critton, Jr., Michael I Pike,
LEOPOLD—KUVIN, PA.
By:
Florida Bar No.: 089737
EFTA00614434
15TH
IN THE CIRCUIT COURT OF THE
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
AB
Case No: 502008CA037319XXXXMB
Plaintiff, Florida Bar No: 089737
vs.
EPSTEIN and
Defendant.
UM WITHOUT DEPOSITION
PLAINTIFF'S SUBPOENA DUCES TEC
RECORDS MAY BE MAILED
THE STATE OF FLORIDA:
TO: Yellow Cab,
pold—Kuvin, P.A.,
YOU ARE COMMANDED to appear at Leo
24,
the offices of undersigned counsel, on April
at that time and place the following:
2009, at 9:00 a.m., and to have with you
DUCES TECUM:
and
y of any and documents, of whatever kind
You are to produce a true and accurate cop
for
form or to III
nature, evidencing Yellow Caps dispatched
the years 2001 through the present.
ied at that time. You will not be required to
These items will be inspected and may be cop
ies of
with this subpoena by providing legible cop
surrender the original items. You may comply
before the
whose name appears on this subpoena on or
the items to be produced to the attorney
dition the prep aration of the copies upon the payment
scheduled date of production. You may con
aration. If the cost of production will exceed $50.00,
in advance of the reasonable cost of prep
LEOPOLD-KUV1N, P.A.
33410
2925 PGA Boule vard, Suite 200, Palm Beach Gardena, Florida
(561) 515-1400: (561) 515-1401 (tlicalmik)
EFTA00614435
please contact our office for authorization to proceed with production. You may mail or
deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate
your appearance at the time and place specified.
THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
If you fail to:
(1) Appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
you may be in contempt of court. You are subpoenaed to appear by the following attorney, and
unless excused from this subpoena by this attorney or the court, you shall respond to this
subpoena as directed.
Dated on
EICER T. MJVIN, ESQ.
Page 2 of 2
EFTA00614436
IN THE COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO. 502008CA025129)O3OCMB AI
Plaintiff,
v.
E. EPSTEIN, and
Y
Defendants.
DEFENDANT'S, JEFFREY EPSTEIN, OBJECTION TO NOTICE AND AMENDED
NOTICE OF PRODUCTION AND SUBPOENA DUCES TECUM WITHOUT
DEPOSITION DIRECTED TO YELLOW CAB
Defendant, JEFFREY E. EPSTEIN, (hereinafter "Mr. Epstein") by and through his
attorneys, hereby files his objection to the Notice and Amended Notice of Production
and Subpoena directed to Yellow Cab, attached as Exhibit "A" and Exhibit "B", and
as grounds therefore, would state:
1. The Plaintiff= in her answers to interrogatories, alleges that she was
at the Defendant's home on one occasion in September of 2005. In response to
interrogatory #5, she stated under oath "I arrived at approximately 1:00 p.m. - 2:00 p.m.
and left at 2:00 p.m. - 3:00 p.m.". The only other person who was in the home at the
time were Mr. Epstein, and a cook in Mr. Epstein's kitchen. She
further stated that she was brought to the home la
2. The complaint is a two-count complaint, Count I directed to Mr. Epstein
which alleges sexual battery for having touched the Plaintiff, and Count II against Ms.
EXHIBIT "8 "
EFTA00614437
v. Epstein, et al.
Page 2
3. There was no suggestion whatsoever in the answers to interrogatories nor
in the complaint that "Yellow Cab" has some involvement in this case.
4. On the other hand, the attorneys for also have another case styled
C.M.A. v. Jeffrey Epstein andESIM, Case No.: 08-CV-80811-Marra/Johnson.
It appears that the Plaintiff,■ or her attorneys are attempting to do discovery in
C.M.A through the state court case.
5. Whatever trip receipts, logs, information data and/or records involving pick
ups and deliveries to and from Mr. Epstein's home in Palm Beach from 2001 through
2006, when the Plaintiffs one time incident occurred in September of 2005 when she
was taken to the home by is overly broad, not relevant, nor material nor calculated
to lead to the discovery of admissible evidence.
6. Additionally, who may have traveled to and from Mr. Epstein's home
during that time frame is personal information to third parties who have a right to
privacy.
Certificate of Service
I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S.
Mail to the following addressees on this 11th day of February , 2009:
Jack Scarola, Esq. Jack Alan Goldberger
Jack P. Hill, Esq. Atterbury Goldberger & Weiss, P.A.
Searcy Denney Scarola Bamhart &
Co-Counsel for Defendant Jeffrey Epstein
Counsel for Plaintiff
EFTA00614438
v. Epstein, et al.
Page 3
BURMAN, CRITTON, LUTTfER
•e
Florid. gar #224162
Mich. J. Pike
Florida Bar #617296
(Counsel for Defendant Jeffrey E. Epstein)
EFTA00614439
7
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 50 2008CA025129XXXXMB
Al
Plaintiff(s),
vs.
E. EPSTEIN and
Defendant(s).
NOTICE OF PRODUCTION FROM NON-PARTY
TO: ALL COUNSEL ON THE ATTACHED SERVICE LIST
YOU ARE NOTIFIED that after ten (10) days from the date of service of this
Notice, if service is by delivery, or fifteen (15) days from the date of service, if service is
by mail, and If no objection Is received from any party, the undersigned will issue or
apply to the Clerk of this Court for issuance of the attached Subpoena directed to the
following individual(s) to produce the items listed at the time and place specified in the
Subpoena.
1.
EXHIBIT
EFTA00614440
Mrni Epstein, et al
se No. 50 2008CA025129)0000AB Al
Notice of Production from Non-Party
Page 2
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by U.S. Mall to all Counsel on the attached list, this V day of February,
2009.
Jack Scarola
Florida Bar No.: 189440
Jack P. Hill
Florida Bar No.: 0547808
Shipley, P.A.
Attorneys for Plaintiff(s)
EFTA00614441
A.C. v. Epstein, et al
Case No. 50 2008CA025129XXXXMB Al
Notice of Production from Non-Party
Page 3
COUNSEL LIST
sissi
Attorneys for Jeffrey pste n
Robert Critton, Esquire
Burman Critton Luther & Coleman LIP
Attorneys for Jeffrey Epstein
EFTA00614442
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 50 2008CA025129XXXXMB Al
PIaintiff(s),
vs.
Ail E. EPSTEIN and
Defendant(s).
I.
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA
TO:
YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart &
Shipley, P.A. n
February 27, 2009, and to have with you at that time and place the following:
Duces Tecum: Any and all trip receipts, logs, Information data
varies to and from
Ill inllOISll , from 2001 through
These items will be inspected and may be copied at that time. You will not be
required to surrender the original items. You may comply with this subpoena by
providing legible copies of the items to be produced to the attorney whose name
appears on this subpoena on or before the scheduled date of production. You may
condition the preparation of the copies upon the payment in advance of the reasonable
cost of preparation. You may mail or deliver the copies to the attorney whose name
EFTA00614443
I. v. Epstein, et al
Case No. 50 2C0SCA026129)0000/8 At
SDT Without Deposition
Page2
appears on this subpoena and thereby eliminate your appearance at the time and place
specified above. You have the right to object to the production pursuant to this
subpoena at any time before production by giving written notice to the attorney whose
name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO
TESTIMONY WILL BE TAKEN.
If you fail to:
1) Appear as specified; or
2) Furnish the records instead of appearing as provided above; or
.3) Object to this subpoena,
You may be in contempt of court. You are subpoenaed to appear by the
following attorney, and unless excused from this subpoena by this attorney or the
court, you shall respond to this subpoena as directed.
DATED this day of , 20 .
Jack Scarola
Florida Bar No.: 169440
Jack P. Hill
Florida Bar No.: 0547808
Attorneys for Plaintiff(s)
EFTA00614444
v, Epstein, et al
Case No. 50 2008CA025129XXXXMB Al
SDT Without Deposition
Page3
CERTIFICATION OF RESPONSE TO
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
STATE OF FLORIDA
COUNTY OF
The undersigned, as custodian of records for , certifies that the attached •
documents consisting of pages represents a true copy of all items within my
possession, custody or control which are described in the Subpoena Duces Tecum
Without Deposition served on me in the above styled action and each page is numbered
by me for identification. Production is complete and has been numbered by the
custodian of records.
It is further certified that originals of the items produced are maintained under the
direction, custody and control of the undersigned.
The foregoing Certification was acknowledged before me, an officer duly
authorized in the State and County aforesaid to take• acknowledgments, this
day of 20 , who:
[ ] is personally known to me; or
[ ] has produced as identification; and who:
[ ] did or
[ ] did not, take an oath,
and who executed the foregoing certification, and who acknowledged the foregoing
certification to be freely and voluntarily executed for the purposes therein recited.
Notary Public, State of Florida at Large.
My Commission Expires:
EFTA00614445
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 50 2008CA025129XXXXMB Al
Plaint-W(8),
VS.
E. EPSTEIN and
Defendant(s).
AMENDED NOTICE OF PRODUCTION FROM NON-PARTY
TO: ALL COUNSEL ON THE ATTACHED SERVICE LIST
YOU ARE NOTIFIED that after ten (10) days from the date of service of this
Notice, if service is by delivery, or fifteen (15) days from the date of service, if service is
by mail, and if no objection is received from any party, the undersigned will issue or
apply to the Clerk of this Court for issuance of the attached Subpoena directed to the
following individual(s) to produce the items listed at the time and place specified in the
Subpoena.
1.
EXHIBIT ‘'B
EFTA00614446
M . v. Epstein. et al
Case No. 50 2008CA025129)000(MB Al
Amended Notice of Production from Non-Party
Page 2
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by U.S. Mall to all Counsel on the attached list, this IO day of February,
2009.
Jack Scaro
Florida Bar No.: 189440
Jack P. Hill
Florida Bar No.: 0547808
EFTA00614447
IMO v. Epstein, et al
Case No. 50 2008CA025120)COVMS
Amended Notice of Production from Non-Party
Page 3
COUNSEL LIST
Jack A. Goldberger. Esquire
Attorneys for Jeffrey Epstein
Robert Critton, Esquire
Attorneys for Jeffrey Epstein
EFTA00614448
IN THE CIRCUIT COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO.: 50 2006CA025129)OO0(MB Al
Plaintiff(s),
VS.
E. EPSTEIN and MI
Defendant(s).
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
THE STATE OF FLORIDA
TO:
YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart & Shipley, P.A.,
n March 2, 2009, and to
have with you at that time and place the following:
Duces Tecum: Any and all trip receipts, logs, information d
liveries to and from
from 2001 through 2006; and
Any and all trip receipts, logs, information data and/or records
involvi
and/or from roug
These items will be Inspected and may be copied at that time. You will not be required
to surrender the original items. You may comply with this subpoena by providing legible copies
of the items to be produced to the attorney whose name appears on this subpoena on or before
the scheduled date of production. You may condition the preparation of the copies upon the
EFTA00614449
I v. Epstein, et al
No. 50 2008CA025129)0O0(MB Al
SDT Without Deposition
Page2
payment in advance of the reasonable cost of preparation. You may mail or deliver the copies
to the attorney whose name appears on this subpoena and thereby eliminate your appearance
at the time and place specified above. You have the right to object to the production pursuant to
this subpoena at any time before production by giving written notice to the attorney whose name
appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE
TAKEN.
If you fail to:
1) Appear as specified; or
2) Furnish the records instead of appearing as provided above; or
3) Object to this subpoena,
You may be in contempt of court. You are subpoenaed to appear by the following
attorney, and unless excused from this subpoena by this attorney or the court, you shall
respond to this subpoena as directed.
DATED this day of , 20 .
Jack Scarola
Florida Bar No.: 169440
Jack P. Hill
Florida Bar No.: 0547808
ey, P.A.
Attorneys for Plaintiff(s)
EFTA00614450
v. Epstein, et al
Case No. 50 2008CA025129)00C(MB N
SDT Without Deposition
Page3 •
CERTIFICATION OF RESPONSE TO
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
STATE OF FLORIDA
COUNTY OF
The undersigned, as custodian of records for , certifies that the attached documents
consisting of pages represents a true copy of al items within my possession, custody or
control which are described in the Subpoena Duces Tecum Without Deposition served on me in
the above styled action and each page is numbered by me for identification. Production is
complete and has been numbered by the custodian of records.
It is further certified that originals of the items. produced are maintained under the
direction, custody and control of the undersigned.
The foregoing Certification was acknowledged before me, an officer duly aut
ℹ️ Document Details
SHA-256
1e973dad2a8305b2f3e5e59c81aeebab3527a17ffca5b5f3fff49d36a92fdb50
Bates Number
EFTA00614418
Dataset
DataSet-9
Document Type
document
Pages
37
Comments 0