EFTA01154302.pdf

IN THE CIRCUIT COURT FOR THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA FILE NO. 502008CP003626XXXXMB E.W., Plaintiff, v. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S REQUEST FOR ENTRY UPON LAND Comes Now Plaintiff, EW, by and through undersigned counsel and pursuant to 1.350(a)(3) Fla.R.Civ.P., and requests the following: 1. To enter Defendant Jeffrey Epstein's property located at 358 El Brillo Way, West Palm Beach, FL 33480. 2. Inspect the entire property located at that location, including but not limited to the driveway, the interior of the house, each and every room in the house, the massage table, the backyard, the swimming area and all other areas located on said property. 3. To take video and/or photographs of the property and inspection. According to the Palm Beach County Property Appraiser, this property is approximately 14,223, exclusive of the outside area, and thus it is anticipated that the inspection will take approximately 4 hours. In addition to the undersigned, the inspection will be attended by other lawyers with the law firm of Rothstein Rosenfeldt Adler, a videographer and members of the video team, a photographer and members of the photography team and other persons to assist in the process. These people attending the inspection are available for the inspection to take place on Friday, August 28, 2009 to begin at the property at 10:00 a.m. The undersigned will work with Defendant to agree on a mutually acceptable time and date above is not convenient for Defendant. EFTA01154302  WHEREFORE, the Plaintiff respectfully requests that this Court enter an Order granting it's Request for Entry Upon Land requiring the Defendant, Epstein, to schedule such entry on Friday, August 28, 2009 at 10:00 a.m., or in the alternative, no later than twenty days following entry of the Court's Order granting same. I HEREBY CERTIFY that a copy of the foregoing was served by mail this 10th day of August, 2009 to: Robert D. Critton, Jr., Esq., Burman, Critton, et al., 515 North Flagler Drive, Suite 400, West Palm Beach, FL 33401. ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33394 Telephone (954) 522-3456 Telecopier (954) 527-8663 By. Bradley J. Edwards Florida Bar No. 542075 bedward rra-law.corn William J. Berger Florida Bar No. 197701 wbergererra-law.com H:113rad Edwards1BJE CasesIMiller. Tatum (09-22783) Request for Entry Upon Land.doc 2 EFTA01154303