EFTA01103285.pdf
IN THE COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO. 502008CA028058XXXXMB AB
E.W.,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
AND FOR SANCTIONS
EPSTEIN'S MOTION TO COMPEL DEPOSITION OF EW
an order compelling
Defendant, JEFFREY EPSTEIN ("Epstein"), moves for
s for sanctions, and states:
Plaintiff, E.W. ("EW"), to appear for deposition, move
mber 11, 2009
1. EW's deposition was originally set for deposition on Septe
t her deposition to November 5
(Notice attached as Exhibit A). Epstein agreed to re-se
counsel, Brad Edwards, was
and 6, 2010 (Notice attached as Exhibit B) since her
.
scheduled for surgery on or around September 11, 2009
y cancelled by
2. The November 5 and 6, 2010 depositions were unilaterall
, Rosenfeldt & Adler firm. See
EW's counsel because of the implosion of the Rothstein
Exhibit C.
November 2, 2009 e-mail from Jacquie Johnson attached as
of Taking Video
3. On March 9, 2010, Epstein again served a Notice
hed as Exhibit D). On all
Deposition of EW to occur on April 2, 2010 (Notice attac
rmed with opposing counsel.
occasions, the deposition dates were coordinated and confi
would be
4. Despite assurances from her counsel on April 1, 2010 that she
2010 (Certificate of Non-
attending, EW failed to appear for her deposition on April 2,
Appearance attached as Exhibit E).
EFTA01103285
5. Brad Edwards, counsel for EW, explained on the record that he arranged
to pick EW up for her deposition at a pre-arranged location the morning of April 2, 2010.
See Exhibit D at 3-4. However, when Mr. Edwards arrived at said location EW was not
there. Id.
6. Mr. Edwards attempted to contact EW "on many occasions this morning
by way of cellphone, and there is no, there has been no answer on the cellphone." Id.
at 4. Mr. Edwards also called a home phone number to no avail. Id.
7. Mr. Edwards apparently learned, through an unidentified "friend" of EW,
that she had to attend to a health issue related to her mother. Id. at 4-5. Yet EW made
no attempt to contact Mr. Edwards and advise of any health issue; instead she again
ignored her deposition notice and failed to appear.
8. In addition to being a plaintiff in the instant case, EW is also an important
witness in related federal companion cases, which are subject to fast approaching
discovery deadlines. Specifically, the discovery cutoff in Jane Doe v. Epstein, Case No.
08-80893-CV-MARRA/JOHNSON was recently extended to April 16, 2010. See DE
#473. EW is an important witness in the foregoing case as she was a close friend of
Jane Doe and possesses relevant information necessary for Epstein to defend the case.
The Court should therefore compel her attendance at deposition on or before April 16,
2010 (although Mr. Edwards has agreed to extend the discovery deadline and provide
another date when EW "may" actually appear).
9. Because of the importance of obtaining EW's testimony in the related
federal matters, Epstein also requests the Court order that if EW fails to appear for
deposition on or before April 16, 2010 (or an agreed date with her attorney who is also
2
EFTA01103286
n) that an order to show cause be
the attorney in the Jane Doe case referenced herei
is attached as Exhibit F.
issued and a show cause hearing set. A proposed order
of Civil Procedure
10. Moreover, EW's callous disregard for the Florida Rules
fees by virtue of the undersigned
has caused Epstein to incur unnecessary attorney's
in has also incurred unnecessary
preparing for and attending the deposition. Epste
.00 (invoices attached as composite
court reporter and videographer costs, totaling $710
Exhibit 6).
des in pertinent part:
11. Rule 1.380(d), Florida Rules of Civil Procedure, provi
to
If a party ... fails (1) to appear before the officer who is
r notic e,
take the deposition after being served with a prope
any
... the court in which the action is pending may take
and (C) of
action authorized under paragraphs (A), (B),
in
subdivision (b)(2) of this rule. ... Instead of any order or
party failin g to
addition to it the court shall require the
by the
act to pay the reasonable expenses caused
failure, which may include attorneys ' fees. ...
(Emphasis added).
in's counsel's
12. Epstein requests the Court require EW to pay Epste
, for preparing the instant
attorney's fees for attending her deposition on April 2, 2010
incurred due to her failure to
motion and attending hearing on same, and for the costs
an award of attorney's fees
attend the April 2, 2010 deposition.' Epstein also requests
, which will include the
for the time it will take to again prepare for EW's deposition
s.
review of hundreds, if not thousands, of pages of document
sts the Court compel
WHEREFORE, Defendant, JEFFREY EPSTEIN, reque
16, 2010 (or date agreed to by
Plaintiff, E.W., to attend her deposition on or before April
Epstein will supply the Court with an affidavit
If the Court grants Epstein's entitlement to attorney's fees,
attesting to the fees incurred and which Epstein is claiming.
3
EFTA01103287
of an ord er to show cause in the event E.W. fails
her counsel), provide for the issuance
tein
0 (or the agreed upon date), award Eps
to appear on or before April 16, 201
and grant
EW 's failure to appear on April 2, 2010
attorney's fees and costs based on
just and proper.
any additional relief the Court deems
CERTIFICATE OF SERVICE
the foregoing was sent by fax and U.S.
I HEREBY CERTIFY that a true copy of
this 8th day of April, 2010:
Mail to the following addressees on
Jack Alan Goldberger, Esq.
Brad Edwards, Esq.
Atterbury Goldberger & Weiss, P.A.
Farmer, Jaffe, Weissing, Edwards, Fistos
250 Australian Avenue South
& Lehrman, PL
Suite 1400
424 N. Andrews Avenue, Suite 2
der dale , FL 333 01 West Palm Beach, FL 33401-5012
For t Lau
Fax:
- fax Co-Counsel for Defendant Jeffrey Epstein
Counse or am
Jay Howell, Esq.
Jay Howell & Associates, P.A.
644 Cesery Boulevard
Suite 250
Jacksonville, FL 32211
Phone
Fax
Co-counsel or Plaintiff
LLP
BURMAN CRITTON LUTTIER & COLEMAN,
303 Banyan Boulev Suite 400
st Palm Bea 3401
By:
Robert D. C
Florida Ba #224162
Michael J. Pike
Florida Bar #617296
David A. Yarema
Florida Bar #12492
4
EFTA01103288
IN THE COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT, IN AND FOR PALM BEACH
COUNTY. FLORIDA
L.M.,
CASE NO. 502008CA028051/OOO{MB AD
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEO DEPOSITION
To: See Service List below
y will take the deposition via video of:
PLEASE TAKE NOTICE that the undersigned attorne
PATE & TIME LOCATION OF DEPOSITION
DEPONENT
Friday Burman Critton Luther & Coleman,
EW
September 11, 2009 LLC
do Brad Edwards, Esq.
303 Banyan Boulevard
Rothstein Rosenfeldt Adler 10:00 a.m.
Suite 400
401 East Las Olas Boulevard West Palm Beach, FL 33401
Suite 1650
Fort Lauderdale, FL 33301
y. Inc., a Notary Public, or any other officer
upon oral examination, before Prose Court Reporting Agenc
The oral examination is being taken for the
authorized by law to take depositions in the State of Florida.
es as are permitted under the applicable
purpose of discovery, for use at trial, or for such other purpos
Statutes of Rules of Court.
has been furnished by electronic mail
I HEREBY CERTIFY that a true copy of the foregoing
Service List this 91 th day of August, 2009.
(e-mail) and U.S. Mail to the addresses listed on the below
BURMAN, CRITTON, LUTHER & COLEMAN
303 Banyan Blvd., Suite 400
West Palm Beach, FL 3340
5611842-2820
BY:
ROBER . CRITTON, JR., ESQ.
Florida ar No. 224162
MICHAEL J. PIKE, ESQ.
Florida Bar. No. 617296
(Counselfor Defendant Jeffrey Epstein)
Courtesy copy: Prose Court Reporting Agency, Inc.
EXHIBIT k
EFTA01103289
L.M. v. Epstein
Page 2
L.M. v. Epstein
Service List
Brad Edwards, Esq. Jack Alan Goldberger, Esq.
Rothstein Rosenfeldt Adler Atterbury Goldberger & Weiss, P.A.
401 East Las Olas Boulevard 250 Australian Avenue South
Suite 1650 Suite 1400
Fort Lauderdale FL 33301 West Palm Beach, FL 33401-5012
Phone: Fax:
Fax: Co• ounse orDefendant Jeffrey Epstein
Counse
Jay Howell, Esq.
Jay Howell & Associates, P.A.
644 Cesery Boulevard
Suite 250
Jacksonville, FL 32211
Phone
Fax
Co-counsel for Plaintiff
EFTA01103290
1+O
IN THE COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
E.W.,
CASE NO. 5020013CA028058,OOO(MB AD
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEO DEPOSITION
To: See Service List below
PLEASE TAKE NOTICE that the undersigned attorney will take the deposition via video of:
DEPONENT DATE & TIME LOCATION OF DEPOSITION
E.W. Thursday, Prose Court Reporting
do Brad Edwards, Esq. November 5, 2009 250 Australian Avenue S., Suite #1500
Rothstein Roseofeldt Adler and Friday, West Palm Beach, FL 33401
401 East Las Olas Boulevard November 6, 2009
Suite 1650 beginning at
Fort Lauderdale, FL 33301 10:00 a.m.
upon oral examination, before Prose Court Reporting Agency, Inc., a Notary Public, or any other officer
authorized by law to take depositions in the State of Florida. The oral examination is being taken for the
purpose of discovery, for use at trial, or for such other purposes as are permitted under the applicable Statutes
of Rules of Court.
I HEREBY CERTIFY that a true copy of the foregoing was sent by electronic mail (e-mail) and by
US Mail to the addresses listed on the below Service List on this 20th day of October 2009.
BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
303 Banyan Blvd., Suite 400
West Palm Beac FL 33401
By:
obert D. Critton, Jr.
Florida Bar #224162
Michael J. Pike
Florida Bar #617296
(Counselfor Defendant Jeffrey Epstein)
EXHIBIT B
EFTA01103291
E.W. v. Epstein
Page 2
g.W. v. Epstein
Service List
Brad Edwards, Esq. Jack Alan Goldberger, Esq.
Brad F,dwards and Associates, LLC Atterbury Goldberger & Weiss, P.A.
2028 Harrison Street 250 Australian Avenue South
Suite 202 Suite 1400
Holl d FL 33020 West Palm Beach. FL 33401-5012
hone Faxes
ax Co-Cotmselfor Defendant Jeffrey Epstein
Counselfor Plaintiff
Jay Howell, Esq.
Jay Howell & Associates, P.A.
644 Cesay Boulevard
Suite 250
Jacksonville, FL 32211
hone
Fax
Co-counselfor Plaintiff
EFTA01103292
Page 1 of 1
Jessica Cadwell
From: Jacquie Johnso
Sent: Monday, November 02, 2009 12:14 PM
To: Jessica Cadwell; Connie Zaguirre
Subject: Deposition of EW
Due to certain circumstances at
RRA — we have no choic
But to cancel the deposition
of EW this week.
Jacquie Johnson
Legal Assistant to
Brad Edwards, Esq.
Partner
Rothstein Rosenfeldt Adler
401 East Las Olas Blvd.
Suite 1650
Fort Lauderdale FL 33301
Tele hone
Fa
EXHIBIT C
4/8/2010
EFTA01103293
IN THE COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
E.W.,
CASE NO. 502008CA028058XXVIMB AD
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEO DEPOSITION
To: See Service List below
the deposition via video of:
PLEASE TAKE NOTICE that the undersigned attorney will take
DATE & TIME LOCATION OF DEPOSITION
DEPONENT
April 2, 2010 at Prose Court Reporting
E.W.
do Brad Edwards, Esq. 9:00 a.m. 250 Australian Avenue S.
Suite #1500
Fanner, Jaffe, Weissing, Edwards,
West Palm Beach,FL 33401
Fistos & Lehrman, P.L.
425 N. Andrews Avenue
Suite #2
Fort Lauderdale,FL 33301
y, Inc., a Notary Public, or any other officer
upon oral examination, before Prose Court Reporting Agenc The oral examination is being taken for the
authorized by law to take depositions in the State of Florida.
as are permitted under the applicable Statutes
purpose of discovery, for use at trial, or for such other purposes
ofRules of Court.
by electronic mail (e-mail) and by
I HEREBY CERTIFY that a true copy of the foregoing was sent . 2010.
9ib day of March
US Mail to the addresses listed on the below Service List on this
BURMAN, CRTITON, urrnER & COLEMAN, LLP
303 Banyan Blvd., Suite 400
West P , FL 3 01
11111Fax
By:
RobedD ritton, Jr.
Florida #224162
Mic J. Pike
Florida Bar #617296
(Counselfor Defendant Jeffrey Epstein)
EXHIBIfp
EFTA01103294
E.W. v. Epstein
Page 2
E.W. v. Epstein
Service List
Brad Edwards, Esq. Jack Alan Goldberger, Esq.
Fanner, Jaffe, Weissing, Edwards, Flstos & Atterbury Goldberger & Weiss, P.A.
Lehrman, P.L. 250 Australian Avenue South
425 N. Andrews Avenue Suite 1400
Suite 2 West Palm Beach, FL 33401-5012
Ft. Lauderdale, FL Fax:
Phone Co-Counselfor Defendant Jeffrey Epstein
Fax
Counse or aitufff
Jay Howell, Esq.
Jay Howell & Associates, P.A.
644 Cesery Boulevard
Suite 250
Jacksonville, FL 32211
hone
ax
Co-counse
Wor Plaintiff
EFTA01103295
Page 3
Page 1
IT 1 PROCEEDINGS
IN THE CIRCUIT COURT OF THE 15M JUDICIAL CIRCU
IN AND FOR PALM BEACH COUNTY, FLORIDA 2
CASE NO. 502008CA028058200CXMII AD 3 MR. CRITTON: All right. We're here for
E.W., 4 the deposition of E.W. which was duly noticed
5 today for 9:O0. We continued with Mr. Edward's
Plaintiff, 6 office yesterday that the deposition was on.
7 He =Daunted they would be here at 9:00 for
8 the deposition.
JEFFREY EPSTEIN, 9 He sent me some -- we had made a request
Decadent. 10 for his Answers to Interrogatories which were
11 due yesterday. They provided me their answers
VIDEO-CONFERENCED VIDEOTAPED DEPOSITION OF 12 and objections to I think it was the fourth set
E.W. 13 of interrogatories. And I have been preparing
14 for nine years -- no, certainly for a couple of
Friday, April 2, 2010
9:20 • 9:22 a.m. 15 days, but Mr. Edwards has just advised me she
16 probably, Ms. E.W. will probably not be here
250 Australia Avenue South 17 today, but I will let him speak for himself.
Suite 1500
West Palm Beach, Florida 33401 18 MR. EDWARDS: Sure. Just so the record is
19 clear, I have had frequent and constant
Reported By:
20 communication with E.W. over the last month.
Cynthia Hopkins, RPR, FM 21 As recently as Wednesday she was in my office
Notary Public, State of Florida 22 for the pre-deposition conference, met for
Prose Court Reporting several hours, was certainly intending on being
JobNo. 1612 23
24 here, communications with E.W. as late as 8:00
25 last night where we made arrangements for her
Page 4
Page 2
1 APPEARANCES: 1 to be at this deposition which included me
2 On behalf of the Plaintiffs, LM., E.W. and 2 picking her up this morning.
Jane Doe: 3 I showed up to the location and she was
3
BRADLEY J. EDWARDS, ESQUIRE 4 not, she was not there. The information that
4 FARMER, JAFFE, WEISSING, EDWARDS 5 has been relayed to me in the last hour is that
FISTOS & LEHRMAN, P.L. 6 there was a health issue related to her mother
5 425 North Andrews Avenue
Suite 2 7 last night that she had to attend to.
6 Fort Lauderdale, Florida 33301 8 I have attempted to contact E.W. on many
Phone: 954,524.2820 9 occasions this morning by way of cellphone, and
7
8 10 there is no, there has been no answer on the
9 On behalf of the Defendant, Jeffrey Epstein: 11 cellphone. And I have also made attempts to
10 ROBERT D. CRITTON, JR., ESQUIRE 12 contact at another home phone where she has
BURMAN, CIUTTON, LUTTEER & COLEMAN, LLP
11 303 Banyan Boulevard 13 stayed recently, and there was no answer at
Suite 400 14 that phone as well.
12 West Palm Beach, Florida 33401 15 So, at this point in time all indications
Phone: 561.842.2820
16 are that she will not be here for her
13
14 ALSO PRESENT 17 deposition today.
15 Sascha Quiinby, Videographa 18 MR. CRITTON: Just for clarification,
16
17 19 Brad, did you actually speak with someone? I
18 20 mean, I know you spoke with E.W. last night
19 21 She was going to come. And then have you, I
20 22 thought you said you spoke with someone to try
21
22 23 to locate her.
23 24 Do you want to disclose who that person
24 is?
25
25
1 (Pages 1 to 4)
(561) 832-7506
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC.
bfd075ea-b36a-4201-a365-853c87821878
Electronically signed by cynthia hooking
EFTA01103296
Page 7
Page 5
1 CERTIFICATE
MR. EDWARDS: Not at this time I don't.
2
2 If the court wants me to disclose, I will, but
3 STATE OF FLORIDA
3 it is a friend of E.W.'s who spoke with her
4 COUNTY OF PALM BEACH
4 later last night than the time when I spoke to
5
5 her.
6
6 MR. CRITTON: Okay. Did you get any 7 I, Cynthia Hopkins, Registered Professional
7 inclination at that time that there was any Reporter and Florida Professional Reporter, State of
8 problem with family or friends? 9 Florida at large, certify that I was authorized to
9 MR. EDWARDS: At the time that I spoke 10 and did stenographically report the foregoing
10 with E.W.? 11 proceedings and that the transcript is a true and
11 MR. CRITTON: No, with the other person. 12 complete record of my stenographic notes.
12 MR. EDWARDS: That conversation happened 13 Dated this 2nd day of April, 2010.
13 within the last hour this morning. 14
14 MR. CRITTON: Okay. All right. We'll 15
15 take a C.N.A., and I actually have been 16
16 preparing for this for a couple of days.
17 E.W. has a lot of information on her. She 17
18 is obviou sly a key witness. She is an 18 Job #1612
19 important witness in a number of cases 19
20 including the Jane Doe case which discovery 20
21 ends on the 16th and Mr. Edwards and I have 21
22 worked out some extensions on that. We may 22
23 have to work out some others to our mutual 23
24 benefit so we can complete the deposition or 24
attempt to take Ms. E.W.'s deposition. 25
25
Page 6
1 So, we'll take a C.N.A. and I will do what
2 I need to do in court. Thank you.
3 MR. EDWARDS: Agreed_
4 (The deposition was concluded.)
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2 (Pages 5 to 7)
(561) 832-7506
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC.
bfd0Th ea-b36a -4201-a368853087821878
Electronically signed by synth's hopidnit t
EFTA01103297
Page 1
IN THE CIRCUIT COURT OP THE 15TH JUDICIAL CIRCLET
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. S0200SCA02005820000.03 AD
Plaintiff.
JEFFREY EPSTEIN,
Defendant.
/
CERTIFICATE OF NON-APPEARANCE
I, Cynthia Hopkins, Registered Professional
Reporter and Notary Public, State of Florida at
Large, was duly designated to lake the deposition of
the witness:
E.W.
I hereby certify that aforesaid witness did
not appear beton me between 900 a.m. and 9:30 a.m.
on the 2nd day of April, 2010. Present was
Robed D. Critton, Jr., Esquire, and Bradley J.
Edwards, Esquire.
Dated this 2nd day ofMail, 2010.
ttal Hopkins,
".: AS
Prose Court Reporting Agency. Inc,
West Palm Beach, Florida
1. (Page 1)
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
24032db3-ead8-484calfdcf14eb399692
Electronically signed by cynthia hopkins
EFTA01103298
THE FIFTEENTH
IN THE COURT OF
AND FOR PALM
JUDICIAL CIRCUIT, IN
BEACH COUNTY, FLORIDA
XXXXMB AB
E.W., CASE NO. 502008CA028058
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
TION TO COMPEL
ORDER ON EPSTEIN'S MO
R SANCTIONS
DEPOSITION OF EW AND FO
Compel
bef ore the Co urt on De fendant Epstein's Motion to
THIS CAUSE came
ent of counsel and being
an d for Sa nct ion s, and the Court having heard argum
Deposition of EW
es, it is hereby
fully advised in these premis
ANTED.
DE RE D an d AD JU DG ED that Defendant's Motion is GR
OR
on or before
(1) EW shall appear for deposition
she is
EW fail s to app ear for deposition on or before
(2) If
2010 at a.m.lp.m to
bef ore the und ers ign ed on
commanded to appear
tion.
be he ld in con tem pt of cou rt for failing to appear for deposi
no t
show cause why she should
her failure to appear
in is en title d to rec ove r fro m EW $710.00 in costs for
(3) Epste
sition on April 2, 2010.
at her properly noticed depo
r attorney's fees from EW due to her failure to attend
(4) Epstein is entitled to recove
ure hearing).
on April 2, 2010 (am ount to be determined at a fut
her properly noticed deposition
Florida,
lm Beach County Co urthouse, West Palm Beach,
DONE AND ORDERED at Pa
day of 2010.
this
Donald Hafele
Circuit Court Judge
01,
400, West Palm Beach, FL 334
Copies furnished:
., and MIC HAE L J. PIK E, ESQ ., 303 Banyan Boulevard, Suite And rew s Ave nue , Suit e 2, Fort
N.
ROBERT D. CRITTON, JR.. ESQ mer, Jaffe. Weissing, Edwards, Fistos & Lehrman, PL. 425 rd, Suite 250. Jacksonville, FL
., Far tes. PA, 644 Cesery Bouleva
BRADLEY J. EDWARDS, ESQ
ELL. ESQ., Jay Howell & Associa Weiss, PA, 250 Australian Avenue South, Suite 1400 West
Lauderdale, FL 33301, JAY HOW Gold berg er &
ER. ESQ.. Atterbury
32211, and JACK A. GOLDBERG
Palm Bea ch, FL 334 01-5 012 .
EXH{BIT F
EFTA01103299
INVOICE
Invoice No. Invoice Date Job No.
E I
I PR OS 5599 4/3/2010 1612
coin Job Date Case No.
UPORTING AGENCY, Bit 412/2010 902008CA028038)00C04BAF
Case Name
E.W. v Epstein
Robert Critton, ESquire Payment Terms
Burman, OBTOR Lutber & Colman, LIP
303 Banyan Boulevard, Suite 400 Due upon receipt
West Pam Beach, FL 33401
Scheduled Deposition of EW. 110.00
110.00
Certification of Non-Appearance 75.00
75.00
Large Conference Room - 1Hour
TOTAL DUE .> > $185.00
We appreciate your business! Payment Is due upon receipt
customersrnke@prosaaa.com
Please contact us with any cares:ions: (561)832-75001
Tax ID: 26-3892897
Please *tack bottom pothon andreturn withpayment.
Job No. : 1612 BD ID : 1-MAIN
Case No. : 502008CA0280S8XXXAMB AF
Robert °Won, Esquire
Borman, Cntton, Luther & Coleman, LLP Case Name : E.W. v Epstein
303 Barryan BoulearO, Suite 400
West Palm Beath, Ft. 33401 5549 Invoice Date :4/3/2010
Invoke NO.
Total Due : $185.00
PAYMENT WITH CREDIT CARD
carcutdersName: EXH!BIT
Card Number:
Remit To: Prose Court Reporting Agency, Inc. lryn oAM Phone*:
One aearlake Centre
250 S. Australian Ave., Suite 1500
West Palm Beach, FL 33401 Card Security Code:
Amount to Charge:
Certriolder's Signature.
EFTA01103300
Invoice
VISUAL
Date Number
EVIDENCE Went Pain'. Fi 3Ws 4/2/2010 29683
Box 6967
Terms
Due on receipt
BURMAN, CRITTON & LUTHER
ROBERT CRITTON
303 BANYAN BLVD
SUITE 400
WEST PALM BEACH, FL 33401
Case / Reference; 7 E.W. vs EPSTEIN
(NY Amount
Services Rendered
Date
4/2/2010 VIDEOTAPED DEPOSITION OF: E.W.
DEPONENT
DEPO CANCELLED DUE TO NO-SHOW BY 1 275.00
Tech Time - 1ST 2 Hours 1 500.00
Portable VideOwnlerencing System - 1/2 day -250.00
Discount PER M.D.
TOTAL: $525.00
r your presentation needs. Remit to:
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Visit: www. visua /evidence. corn P.O. Box 6967
West Palm Beach FL 33405
d Tax ID #
Fax: (561) 655.2896 office@visualevidence.org
Phone: (561) 655-2855
EFTA01103301
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO. 502008CA028058XXXXMB AB
E.W.,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
AND FOR SANCTIONS
EPSTEIN'S MOTION TO COMPEL DEPOSITION OF EW
an order compelling
Defendant, JEFFREY EPSTEIN ("Epstein"), moves for
s for sanctions, and states:
Plaintiff, E.W. ("EW"), to appear for deposition, move
mber 11, 2009
1. EW's deposition was originally set for deposition on Septe
t her deposition to November 5
(Notice attached as Exhibit A). Epstein agreed to re-se
counsel, Brad Edwards, was
and 6, 2010 (Notice attached as Exhibit B) since her
.
scheduled for surgery on or around September 11, 2009
y cancelled by
2. The November 5 and 6, 2010 depositions were unilaterall
, Rosenfeldt & Adler firm. See
EW's counsel because of the implosion of the Rothstein
Exhibit C.
November 2, 2009 e-mail from Jacquie Johnson attached as
of Taking Video
3. On March 9, 2010, Epstein again served a Notice
hed as Exhibit D). On all
Deposition of EW to occur on April 2, 2010 (Notice attac
rmed with opposing counsel.
occasions, the deposition dates were coordinated and confi
would be
4. Despite assurances from her counsel on April 1, 2010 that she
2010 (Certificate of Non-
attending, EW failed to appear for her deposition on April 2,
Appearance attached as Exhibit E).
EFTA01103285
5. Brad Edwards, counsel for EW, explained on the record that he arranged
to pick EW up for her deposition at a pre-arranged location the morning of April 2, 2010.
See Exhibit D at 3-4. However, when Mr. Edwards arrived at said location EW was not
there. Id.
6. Mr. Edwards attempted to contact EW "on many occasions this morning
by way of cellphone, and there is no, there has been no answer on the cellphone." Id.
at 4. Mr. Edwards also called a home phone number to no avail. Id.
7. Mr. Edwards apparently learned, through an unidentified "friend" of EW,
that she had to attend to a health issue related to her mother. Id. at 4-5. Yet EW made
no attempt to contact Mr. Edwards and advise of any health issue; instead she again
ignored her deposition notice and failed to appear.
8. In addition to being a plaintiff in the instant case, EW is also an important
witness in related federal companion cases, which are subject to fast approaching
discovery deadlines. Specifically, the discovery cutoff in Jane Doe v. Epstein, Case No.
08-80893-CV-MARRA/JOHNSON was recently extended to April 16, 2010. See DE
#473. EW is an important witness in the foregoing case as she was a close friend of
Jane Doe and possesses relevant information necessary for Epstein to defend the case.
The Court should therefore compel her attendance at deposition on or before April 16,
2010 (although Mr. Edwards has agreed to extend the discovery deadline and provide
another date when EW "may" actually appear).
9. Because of the importance of obtaining EW's testimony in the related
federal matters, Epstein also requests the Court order that if EW fails to appear for
deposition on or before April 16, 2010 (or an agreed date with her attorney who is also
2
EFTA01103286
n) that an order to show cause be
the attorney in the Jane Doe case referenced herei
is attached as Exhibit F.
issued and a show cause hearing set. A proposed order
of Civil Procedure
10. Moreover, EW's callous disregard for the Florida Rules
fees by virtue of the undersigned
has caused Epstein to incur unnecessary attorney's
in has also incurred unnecessary
preparing for and attending the deposition. Epste
.00 (invoices attached as composite
court reporter and videographer costs, totaling $710
Exhibit 6).
des in pertinent part:
11. Rule 1.380(d), Florida Rules of Civil Procedure, provi
to
If a party ... fails (1) to appear before the officer who is
r notic e,
take the deposition after being served with a prope
any
... the court in which the action is pending may take
and (C) of
action authorized under paragraphs (A), (B),
in
subdivision (b)(2) of this rule. ... Instead of any order or
party failin g to
addition to it the court shall require the
by the
act to pay the reasonable expenses caused
failure, which may include attorneys ' fees. ...
(Emphasis added).
in's counsel's
12. Epstein requests the Court require EW to pay Epste
, for preparing the instant
attorney's fees for attending her deposition on April 2, 2010
incurred due to her failure to
motion and attending hearing on same, and for the costs
an award of attorney's fees
attend the April 2, 2010 deposition.' Epstein also requests
, which will include the
for the time it will take to again prepare for EW's deposition
s.
review of hundreds, if not thousands, of pages of document
sts the Court compel
WHEREFORE, Defendant, JEFFREY EPSTEIN, reque
16, 2010 (or date agreed to by
Plaintiff, E.W., to attend her deposition on or before April
Epstein will supply the Court with an affidavit
If the Court grants Epstein's entitlement to attorney's fees,
attesting to the fees incurred and which Epstein is claiming.
3
EFTA01103287
of an ord er to show cause in the event E.W. fails
her counsel), provide for the issuance
tein
0 (or the agreed upon date), award Eps
to appear on or before April 16, 201
and grant
EW 's failure to appear on April 2, 2010
attorney's fees and costs based on
just and proper.
any additional relief the Court deems
CERTIFICATE OF SERVICE
the foregoing was sent by fax and U.S.
I HEREBY CERTIFY that a true copy of
this 8th day of April, 2010:
Mail to the following addressees on
Jack Alan Goldberger, Esq.
Brad Edwards, Esq.
Atterbury Goldberger & Weiss, P.A.
Farmer, Jaffe, Weissing, Edwards, Fistos
250 Australian Avenue South
& Lehrman, PL
Suite 1400
424 N. Andrews Avenue, Suite 2
der dale , FL 333 01 West Palm Beach, FL 33401-5012
For t Lau
Fax:
- fax Co-Counsel for Defendant Jeffrey Epstein
Counse or am
Jay Howell, Esq.
Jay Howell & Associates, P.A.
644 Cesery Boulevard
Suite 250
Jacksonville, FL 32211
Phone
Fax
Co-counsel or Plaintiff
LLP
BURMAN CRITTON LUTTIER & COLEMAN,
303 Banyan Boulev Suite 400
st Palm Bea 3401
By:
Robert D. C
Florida Ba #224162
Michael J. Pike
Florida Bar #617296
David A. Yarema
Florida Bar #12492
4
EFTA01103288
IN THE COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT, IN AND FOR PALM BEACH
COUNTY. FLORIDA
L.M.,
CASE NO. 502008CA028051/OOO{MB AD
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEO DEPOSITION
To: See Service List below
y will take the deposition via video of:
PLEASE TAKE NOTICE that the undersigned attorne
PATE & TIME LOCATION OF DEPOSITION
DEPONENT
Friday Burman Critton Luther & Coleman,
EW
September 11, 2009 LLC
do Brad Edwards, Esq.
303 Banyan Boulevard
Rothstein Rosenfeldt Adler 10:00 a.m.
Suite 400
401 East Las Olas Boulevard West Palm Beach, FL 33401
Suite 1650
Fort Lauderdale, FL 33301
y. Inc., a Notary Public, or any other officer
upon oral examination, before Prose Court Reporting Agenc
The oral examination is being taken for the
authorized by law to take depositions in the State of Florida.
es as are permitted under the applicable
purpose of discovery, for use at trial, or for such other purpos
Statutes of Rules of Court.
has been furnished by electronic mail
I HEREBY CERTIFY that a true copy of the foregoing
Service List this 91 th day of August, 2009.
(e-mail) and U.S. Mail to the addresses listed on the below
BURMAN, CRITTON, LUTHER & COLEMAN
303 Banyan Blvd., Suite 400
West Palm Beach, FL 3340
5611842-2820
BY:
ROBER . CRITTON, JR., ESQ.
Florida ar No. 224162
MICHAEL J. PIKE, ESQ.
Florida Bar. No. 617296
(Counselfor Defendant Jeffrey Epstein)
Courtesy copy: Prose Court Reporting Agency, Inc.
EXHIBIT k
EFTA01103289
L.M. v. Epstein
Page 2
L.M. v. Epstein
Service List
Brad Edwards, Esq. Jack Alan Goldberger, Esq.
Rothstein Rosenfeldt Adler Atterbury Goldberger & Weiss, P.A.
401 East Las Olas Boulevard 250 Australian Avenue South
Suite 1650 Suite 1400
Fort Lauderdale FL 33301 West Palm Beach, FL 33401-5012
Phone: Fax:
Fax: Co• ounse orDefendant Jeffrey Epstein
Counse
Jay Howell, Esq.
Jay Howell & Associates, P.A.
644 Cesery Boulevard
Suite 250
Jacksonville, FL 32211
Phone
Fax
Co-counsel for Plaintiff
EFTA01103290
1+O
IN THE COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
E.W.,
CASE NO. 5020013CA028058,OOO(MB AD
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEO DEPOSITION
To: See Service List below
PLEASE TAKE NOTICE that the undersigned attorney will take the deposition via video of:
DEPONENT DATE & TIME LOCATION OF DEPOSITION
E.W. Thursday, Prose Court Reporting
do Brad Edwards, Esq. November 5, 2009 250 Australian Avenue S., Suite #1500
Rothstein Roseofeldt Adler and Friday, West Palm Beach, FL 33401
401 East Las Olas Boulevard November 6, 2009
Suite 1650 beginning at
Fort Lauderdale, FL 33301 10:00 a.m.
upon oral examination, before Prose Court Reporting Agency, Inc., a Notary Public, or any other officer
authorized by law to take depositions in the State of Florida. The oral examination is being taken for the
purpose of discovery, for use at trial, or for such other purposes as are permitted under the applicable Statutes
of Rules of Court.
I HEREBY CERTIFY that a true copy of the foregoing was sent by electronic mail (e-mail) and by
US Mail to the addresses listed on the below Service List on this 20th day of October 2009.
BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
303 Banyan Blvd., Suite 400
West Palm Beac FL 33401
By:
obert D. Critton, Jr.
Florida Bar #224162
Michael J. Pike
Florida Bar #617296
(Counselfor Defendant Jeffrey Epstein)
EXHIBIT B
EFTA01103291
E.W. v. Epstein
Page 2
g.W. v. Epstein
Service List
Brad Edwards, Esq. Jack Alan Goldberger, Esq.
Brad F,dwards and Associates, LLC Atterbury Goldberger & Weiss, P.A.
2028 Harrison Street 250 Australian Avenue South
Suite 202 Suite 1400
Holl d FL 33020 West Palm Beach. FL 33401-5012
hone Faxes
ax Co-Cotmselfor Defendant Jeffrey Epstein
Counselfor Plaintiff
Jay Howell, Esq.
Jay Howell & Associates, P.A.
644 Cesay Boulevard
Suite 250
Jacksonville, FL 32211
hone
Fax
Co-counselfor Plaintiff
EFTA01103292
Page 1 of 1
Jessica Cadwell
From: Jacquie Johnso
Sent: Monday, November 02, 2009 12:14 PM
To: Jessica Cadwell; Connie Zaguirre
Subject: Deposition of EW
Due to certain circumstances at
RRA — we have no choic
But to cancel the deposition
of EW this week.
Jacquie Johnson
Legal Assistant to
Brad Edwards, Esq.
Partner
Rothstein Rosenfeldt Adler
401 East Las Olas Blvd.
Suite 1650
Fort Lauderdale FL 33301
Tele hone
Fa
EXHIBIT C
4/8/2010
EFTA01103293
IN THE COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
E.W.,
CASE NO. 502008CA028058XXVIMB AD
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEO DEPOSITION
To: See Service List below
the deposition via video of:
PLEASE TAKE NOTICE that the undersigned attorney will take
DATE & TIME LOCATION OF DEPOSITION
DEPONENT
April 2, 2010 at Prose Court Reporting
E.W.
do Brad Edwards, Esq. 9:00 a.m. 250 Australian Avenue S.
Suite #1500
Fanner, Jaffe, Weissing, Edwards,
West Palm Beach,FL 33401
Fistos & Lehrman, P.L.
425 N. Andrews Avenue
Suite #2
Fort Lauderdale,FL 33301
y, Inc., a Notary Public, or any other officer
upon oral examination, before Prose Court Reporting Agenc The oral examination is being taken for the
authorized by law to take depositions in the State of Florida.
as are permitted under the applicable Statutes
purpose of discovery, for use at trial, or for such other purposes
ofRules of Court.
by electronic mail (e-mail) and by
I HEREBY CERTIFY that a true copy of the foregoing was sent . 2010.
9ib day of March
US Mail to the addresses listed on the below Service List on this
BURMAN, CRTITON, urrnER & COLEMAN, LLP
303 Banyan Blvd., Suite 400
West P , FL 3 01
11111Fax
By:
RobedD ritton, Jr.
Florida #224162
Mic J. Pike
Florida Bar #617296
(Counselfor Defendant Jeffrey Epstein)
EXHIBIfp
EFTA01103294
E.W. v. Epstein
Page 2
E.W. v. Epstein
Service List
Brad Edwards, Esq. Jack Alan Goldberger, Esq.
Fanner, Jaffe, Weissing, Edwards, Flstos & Atterbury Goldberger & Weiss, P.A.
Lehrman, P.L. 250 Australian Avenue South
425 N. Andrews Avenue Suite 1400
Suite 2 West Palm Beach, FL 33401-5012
Ft. Lauderdale, FL Fax:
Phone Co-Counselfor Defendant Jeffrey Epstein
Fax
Counse or aitufff
Jay Howell, Esq.
Jay Howell & Associates, P.A.
644 Cesery Boulevard
Suite 250
Jacksonville, FL 32211
hone
ax
Co-counse
Wor Plaintiff
EFTA01103295
Page 3
Page 1
IT 1 PROCEEDINGS
IN THE CIRCUIT COURT OF THE 15M JUDICIAL CIRCU
IN AND FOR PALM BEACH COUNTY, FLORIDA 2
CASE NO. 502008CA028058200CXMII AD 3 MR. CRITTON: All right. We're here for
E.W., 4 the deposition of E.W. which was duly noticed
5 today for 9:O0. We continued with Mr. Edward's
Plaintiff, 6 office yesterday that the deposition was on.
7 He =Daunted they would be here at 9:00 for
8 the deposition.
JEFFREY EPSTEIN, 9 He sent me some -- we had made a request
Decadent. 10 for his Answers to Interrogatories which were
11 due yesterday. They provided me their answers
VIDEO-CONFERENCED VIDEOTAPED DEPOSITION OF 12 and objections to I think it was the fourth set
E.W. 13 of interrogatories. And I have been preparing
14 for nine years -- no, certainly for a couple of
Friday, April 2, 2010
9:20 • 9:22 a.m. 15 days, but Mr. Edwards has just advised me she
16 probably, Ms. E.W. will probably not be here
250 Australia Avenue South 17 today, but I will let him speak for himself.
Suite 1500
West Palm Beach, Florida 33401 18 MR. EDWARDS: Sure. Just so the record is
19 clear, I have had frequent and constant
Reported By:
20 communication with E.W. over the last month.
Cynthia Hopkins, RPR, FM 21 As recently as Wednesday she was in my office
Notary Public, State of Florida 22 for the pre-deposition conference, met for
Prose Court Reporting several hours, was certainly intending on being
JobNo. 1612 23
24 here, communications with E.W. as late as 8:00
25 last night where we made arrangements for her
Page 4
Page 2
1 APPEARANCES: 1 to be at this deposition which included me
2 On behalf of the Plaintiffs, LM., E.W. and 2 picking her up this morning.
Jane Doe: 3 I showed up to the location and she was
3
BRADLEY J. EDWARDS, ESQUIRE 4 not, she was not there. The information that
4 FARMER, JAFFE, WEISSING, EDWARDS 5 has been relayed to me in the last hour is that
FISTOS & LEHRMAN, P.L. 6 there was a health issue related to her mother
5 425 North Andrews Avenue
Suite 2 7 last night that she had to attend to.
6 Fort Lauderdale, Florida 33301 8 I have attempted to contact E.W. on many
Phone: 954,524.2820 9 occasions this morning by way of cellphone, and
7
8 10 there is no, there has been no answer on the
9 On behalf of the Defendant, Jeffrey Epstein: 11 cellphone. And I have also made attempts to
10 ROBERT D. CRITTON, JR., ESQUIRE 12 contact at another home phone where she has
BURMAN, CIUTTON, LUTTEER & COLEMAN, LLP
11 303 Banyan Boulevard 13 stayed recently, and there was no answer at
Suite 400 14 that phone as well.
12 West Palm Beach, Florida 33401 15 So, at this point in time all indications
Phone: 561.842.2820
16 are that she will not be here for her
13
14 ALSO PRESENT 17 deposition today.
15 Sascha Quiinby, Videographa 18 MR. CRITTON: Just for clarification,
16
17 19 Brad, did you actually speak with someone? I
18 20 mean, I know you spoke with E.W. last night
19 21 She was going to come. And then have you, I
20 22 thought you said you spoke with someone to try
21
22 23 to locate her.
23 24 Do you want to disclose who that person
24 is?
25
25
1 (Pages 1 to 4)
(561) 832-7506
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC.
bfd075ea-b36a-4201-a365-853c87821878
Electronically signed by cynthia hooking
EFTA01103296
Page 7
Page 5
1 CERTIFICATE
MR. EDWARDS: Not at this time I don't.
2
2 If the court wants me to disclose, I will, but
3 STATE OF FLORIDA
3 it is a friend of E.W.'s who spoke with her
4 COUNTY OF PALM BEACH
4 later last night than the time when I spoke to
5
5 her.
6
6 MR. CRITTON: Okay. Did you get any 7 I, Cynthia Hopkins, Registered Professional
7 inclination at that time that there was any Reporter and Florida Professional Reporter, State of
8 problem with family or friends? 9 Florida at large, certify that I was authorized to
9 MR. EDWARDS: At the time that I spoke 10 and did stenographically report the foregoing
10 with E.W.? 11 proceedings and that the transcript is a true and
11 MR. CRITTON: No, with the other person. 12 complete record of my stenographic notes.
12 MR. EDWARDS: That conversation happened 13 Dated this 2nd day of April, 2010.
13 within the last hour this morning. 14
14 MR. CRITTON: Okay. All right. We'll 15
15 take a C.N.A., and I actually have been 16
16 preparing for this for a couple of days.
17 E.W. has a lot of information on her. She 17
18 is obviou sly a key witness. She is an 18 Job #1612
19 important witness in a number of cases 19
20 including the Jane Doe case which discovery 20
21 ends on the 16th and Mr. Edwards and I have 21
22 worked out some extensions on that. We may 22
23 have to work out some others to our mutual 23
24 benefit so we can complete the deposition or 24
attempt to take Ms. E.W.'s deposition. 25
25
Page 6
1 So, we'll take a C.N.A. and I will do what
2 I need to do in court. Thank you.
3 MR. EDWARDS: Agreed_
4 (The deposition was concluded.)
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2 (Pages 5 to 7)
(561) 832-7506
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC.
bfd0Th ea-b36a -4201-a368853087821878
Electronically signed by synth's hopidnit t
EFTA01103297
Page 1
IN THE CIRCUIT COURT OP THE 15TH JUDICIAL CIRCLET
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. S0200SCA02005820000.03 AD
Plaintiff.
JEFFREY EPSTEIN,
Defendant.
/
CERTIFICATE OF NON-APPEARANCE
I, Cynthia Hopkins, Registered Professional
Reporter and Notary Public, State of Florida at
Large, was duly designated to lake the deposition of
the witness:
E.W.
I hereby certify that aforesaid witness did
not appear beton me between 900 a.m. and 9:30 a.m.
on the 2nd day of April, 2010. Present was
Robed D. Critton, Jr., Esquire, and Bradley J.
Edwards, Esquire.
Dated this 2nd day ofMail, 2010.
ttal Hopkins,
".: AS
Prose Court Reporting Agency. Inc,
West Palm Beach, Florida
1. (Page 1)
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
24032db3-ead8-484calfdcf14eb399692
Electronically signed by cynthia hopkins
EFTA01103298
THE FIFTEENTH
IN THE COURT OF
AND FOR PALM
JUDICIAL CIRCUIT, IN
BEACH COUNTY, FLORIDA
XXXXMB AB
E.W., CASE NO. 502008CA028058
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
TION TO COMPEL
ORDER ON EPSTEIN'S MO
R SANCTIONS
DEPOSITION OF EW AND FO
Compel
bef ore the Co urt on De fendant Epstein's Motion to
THIS CAUSE came
ent of counsel and being
an d for Sa nct ion s, and the Court having heard argum
Deposition of EW
es, it is hereby
fully advised in these premis
ANTED.
DE RE D an d AD JU DG ED that Defendant's Motion is GR
OR
on or before
(1) EW shall appear for deposition
she is
EW fail s to app ear for deposition on or before
(2) If
2010 at a.m.lp.m to
bef ore the und ers ign ed on
commanded to appear
tion.
be he ld in con tem pt of cou rt for failing to appear for deposi
no t
show cause why she should
her failure to appear
in is en title d to rec ove r fro m EW $710.00 in costs for
(3) Epste
sition on April 2, 2010.
at her properly noticed depo
r attorney's fees from EW due to her failure to attend
(4) Epstein is entitled to recove
ure hearing).
on April 2, 2010 (am ount to be determined at a fut
her properly noticed deposition
Florida,
lm Beach County Co urthouse, West Palm Beach,
DONE AND ORDERED at Pa
day of 2010.
this
Donald Hafele
Circuit Court Judge
01,
400, West Palm Beach, FL 334
Copies furnished:
., and MIC HAE L J. PIK E, ESQ ., 303 Banyan Boulevard, Suite And rew s Ave nue , Suit e 2, Fort
N.
ROBERT D. CRITTON, JR.. ESQ mer, Jaffe. Weissing, Edwards, Fistos & Lehrman, PL. 425 rd, Suite 250. Jacksonville, FL
., Far tes. PA, 644 Cesery Bouleva
BRADLEY J. EDWARDS, ESQ
ELL. ESQ., Jay Howell & Associa Weiss, PA, 250 Australian Avenue South, Suite 1400 West
Lauderdale, FL 33301, JAY HOW Gold berg er &
ER. ESQ.. Atterbury
32211, and JACK A. GOLDBERG
Palm Bea ch, FL 334 01-5 012 .
EXH{BIT F
EFTA01103299
INVOICE
Invoice No. Invoice Date Job No.
E I
I PR OS 5599 4/3/2010 1612
coin Job Date Case No.
UPORTING AGENCY, Bit 412/2010 902008CA028038)00C04BAF
Case Name
E.W. v Epstein
Robert Critton, ESquire Payment Terms
Burman, OBTOR Lutber & Colman, LIP
303 Banyan Boulevard, Suite 400 Due upon receipt
West Pam Beach, FL 33401
Scheduled Deposition of EW. 110.00
110.00
Certification of Non-Appearance 75.00
75.00
Large Conference Room - 1Hour
TOTAL DUE .> > $185.00
We appreciate your business! Payment Is due upon receipt
customersrnke@prosaaa.com
Please contact us with any cares:ions: (561)832-75001
Tax ID: 26-3892897
Please *tack bottom pothon andreturn withpayment.
Job No. : 1612 BD ID : 1-MAIN
Case No. : 502008CA0280S8XXXAMB AF
Robert °Won, Esquire
Borman, Cntton, Luther & Coleman, LLP Case Name : E.W. v Epstein
303 Barryan BoulearO, Suite 400
West Palm Beath, Ft. 33401 5549 Invoice Date :4/3/2010
Invoke NO.
Total Due : $185.00
PAYMENT WITH CREDIT CARD
carcutdersName: EXH!BIT
Card Number:
Remit To: Prose Court Reporting Agency, Inc. lryn oAM Phone*:
One aearlake Centre
250 S. Australian Ave., Suite 1500
West Palm Beach, FL 33401 Card Security Code:
Amount to Charge:
Certriolder's Signature.
EFTA01103300
Invoice
VISUAL
Date Number
EVIDENCE Went Pain'. Fi 3Ws 4/2/2010 29683
Box 6967
Terms
Due on receipt
BURMAN, CRITTON & LUTHER
ROBERT CRITTON
303 BANYAN BLVD
SUITE 400
WEST PALM BEACH, FL 33401
Case / Reference; 7 E.W. vs EPSTEIN
(NY Amount
Services Rendered
Date
4/2/2010 VIDEOTAPED DEPOSITION OF: E.W.
DEPONENT
DEPO CANCELLED DUE TO NO-SHOW BY 1 275.00
Tech Time - 1ST 2 Hours 1 500.00
Portable VideOwnlerencing System - 1/2 day -250.00
Discount PER M.D.
TOTAL: $525.00
r your presentation needs. Remit to:
Adapting our services to meet
Visit: www. visua /evidence. corn P.O. Box 6967
West Palm Beach FL 33405
d Tax ID #
Fax: (561) 655.2896 office@visualevidence.org
Phone: (561) 655-2855
EFTA01103301