EFTA00724180.pdf
LEOPOLD-KUVINL,
CONSUMER JUSTICE ATTORNEYS
May 6, 2010
CERTIFIED MAIL RETURN
RECEIPT REQUESTED
Re: Jeffrey Epstein
Dear .=
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.
fl
CRASHWORTHINESS • MANAGED CARE ABUSE
3 fax
CONSUMER CLASS ACTIONS • PERSONAL INJURY • WRONGFUL DEATH
EFTA00724180
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
C. L. Case No: 10-80447-cv-Marra/Johnson
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:
• DATE AND TIME: LOCATION:
June 15, 2010
10:00 AM
upon an oral examination before Vidcographer 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.
i.
WE HEREBY CERTIFY that a true and correct co
to Jack A. Goldberger,
; Bruce E. Reinhart, Esq.,
• Robert D. Critton, Jr., Michael J. Pike,
of this Notice was mailed this 7
LEOPOLD-KUVIN, P.A.
By:
ce s. yin, Esq.
Cc: Prose Court Reporting Florida Bar No: 089737
Visual Evidence
EFTA00724181
Farmer, Jaffe, Weissing,
Ian Action
Edwards, Fistos Et Lehrman, P.L.
Pe rsor.a: Injury
Wrotig10 Death
Commercial Litiganon
OJUSTICE.00M
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. 502008CA02t3051)OO(MB AB -and-
E.W. v. Jeffrey Epstein / Case No. 50200SCP003626XXXXMB
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
End es as stated
GMF/nas
cc: Robert D. Critton, Esq. ✓
Jay Howell, Esq.
Jack Goldberger, Esq.
EFTA00724182
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.
EFTA00724183
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.
EFTA00724184
CONSUMER JUSTICE ATTORNEYS
May 6, 2010
CERTIFIED MAIL RETURN
RECEIPT REQUESTED
Re: Jeffrey Epstein
Dear .=
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.
fl
CRASHWORTHINESS • MANAGED CARE ABUSE
3 fax
CONSUMER CLASS ACTIONS • PERSONAL INJURY • WRONGFUL DEATH
EFTA00724180
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
C. L. Case No: 10-80447-cv-Marra/Johnson
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:
• DATE AND TIME: LOCATION:
June 15, 2010
10:00 AM
upon an oral examination before Vidcographer 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.
i.
WE HEREBY CERTIFY that a true and correct co
to Jack A. Goldberger,
; Bruce E. Reinhart, Esq.,
• Robert D. Critton, Jr., Michael J. Pike,
of this Notice was mailed this 7
LEOPOLD-KUVIN, P.A.
By:
ce s. yin, Esq.
Cc: Prose Court Reporting Florida Bar No: 089737
Visual Evidence
EFTA00724181
Farmer, Jaffe, Weissing,
Ian Action
Edwards, Fistos Et Lehrman, P.L.
Pe rsor.a: Injury
Wrotig10 Death
Commercial Litiganon
OJUSTICE.00M
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. 502008CA02t3051)OO(MB AB -and-
E.W. v. Jeffrey Epstein / Case No. 50200SCP003626XXXXMB
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
End es as stated
GMF/nas
cc: Robert D. Critton, Esq. ✓
Jay Howell, Esq.
Jack Goldberger, Esq.
EFTA00724182
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.
EFTA00724183
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.
EFTA00724184