EFTA00723775.pdf

JAN-29-10 16:48 FROM-LEOPOLD.KUVIN, P.A. T-995 P.001/003 F-961 IN THE CIRCUIT COURT OF THE 1STH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE Nth Plaintiff; 502008CA037319XXXXIVIB AB va. JEFFREY EPSTEIN, Defendant. NOTICE 01? 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 Wackenhut Corporation. who is not a party and whose principle address is 4200 Wackenhut Drive, Palm Beach Gardens, FL 33410. HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U. S. Mail, postage prepaid, thisjjday of January, 2010 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 Banyan Boulevard, Suite 400, West Palm Beach, FL 33401. LE0P0LD-KUVIN, P.A. 2925 PGA Boulevard Suite 200 s, FL 410 By: SP . KUVIN, Esq. Flori No.: 089737 EFTA00723775 JAN-29-10 16:48 FR0II-LECIP0LMIJV IN , P. A . T-005 P.002/003 F-967 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No: 502008CA-037319)OOOMB AB Plaintiff, vs. Florida Bar No: 089737 JEFFREY EPSTEIN Defendant. PLAINTIFF'S SUBPOENA FOR DEPOSITION DUCTS TECUM THE STATE OF FLORIDA: TO: Wackenhut Corporation, 4200 Wackenhut Drive, Palm Beach Gardens, FL 33410 YOU ARE COMMANDED to appear at the offices of LEOPOLD-KUYIN, P.A., 2925 PGA BOULEVARD, SUITE 200, PALM BEACH GARDENS, FL 33410 February 26, 2010, at 9:00 A.M. and to have with you at that time and place the following: DUCES TECUM: You are to produce a true and accurate copy of any and all documents of work performed for Jeffrey E. Epstein with the address of 358 EL BRILLO WAY, PALM BEACH, FLORIDA 33480. This request includes, but is not limited to any correspondence, e-malls, service logs, reports, proposals, photographs, video tapes, names of security personnel, time records for employees working for this individual or location and any and all other documents related to this individual or location. 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 LEOPOLD—KLIVIN, • Cs...Pi MPhil, MI* 2515 PGA farina% EFTA00723776 JAN-29-10 16:49 FROM-LEOPCILAKUVIN, P.A. T-905 P.003/003 F-967 in advance of the reasonable cost of preparation. If the cost of production will exceed $50.00, 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: (I) Appear as specified; or (2) runtish 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 FOR T By: . UVIN, ESQ. Fl. Bar No.: 089737 Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Pa FL 33410 T: F: III Page 2 of 2 EFTA00723777