EFTA00314177.pdf
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
GEORGE PETRIDES,
Plaintiff,
-against-
Defendant.
NOTICE TO TAKE DEPOSITION
DOBRISH MICHAELS GROSS LLP
Attorneys for
Plaintiff
New York, Ncw York 10017
Pursuant to 22 NYCRR B0-1.1, the undersigned. an attorney admitted ro practice in the courts of
New York State, certifies that, upon
information and beliefand reasonable inquiry, the contentions contained in the annexed
document are notfrivolous.
Dated: January 9, 2013
Allison Berea, Esq.
Service of a copy of the within is herein' admitted.
Dated.•
Attorneysfor
EFTA00314177
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
X
GEORGE PETRIDES,
Index No.:
Plaintiff, NOTICE TO TAKE
DEPOSITION
-against -
Defendant.
X
PLEASE TAKE NOTICE, that pursuant to N.Y. C.P.L.R. 3101(a)(4) and N.Y. C.P.L.R.
3107, the deposition upon oral examination of JEFFREY EPSTEIN of the Epstein Foundation,
whose home address is 9 East 71st Street, New York, NY 10021, will be taken on the 29th day of
January, 2013 at 2:00 p.m. of that day, at the office of the attorney for the Plaintiff, DOBRISH
MICHAELS GROSS LLP at 757 Third Avenue, 15th Floor, New York; NY 10017. The
circumstances or reasons such disclosure is sought or required arc as follows:
Upon information and belief, the witness possesses information and documents, including
prepared records and backup schedules that are material and necessary to the prosecution of this
case not reasonably available from any of the other parties in this action.
JEFFREY EPSTEIN is required to produce at the examination the following records and
papers in his possession, custody, or control:
EFTA00314178
1. All records concerning the employment of including but not
limited to all contracts, correspondences, benefit records, compensation records
and/or reimbursements records.
Dated: New York, New York
January 9, 2013
DOBRISH MICHAELS GROSS LLP
By: Allison Berecz, Esq.
Attorneys for Plaintiff
757 Third Avenue, 15th Floor
New York, NY 10017
TO:
New York, NY 10016
2
EFTA00314179
COUNTY OF NEW YORK
GEORGE PETRIDES,
Plaintiff,
-against-
Defendant.
NOTICE TO TAKE DEPOSITION
DOBRISH MICHAELS GROSS LLP
Attorneys for
Plaintiff
New York, Ncw York 10017
Pursuant to 22 NYCRR B0-1.1, the undersigned. an attorney admitted ro practice in the courts of
New York State, certifies that, upon
information and beliefand reasonable inquiry, the contentions contained in the annexed
document are notfrivolous.
Dated: January 9, 2013
Allison Berea, Esq.
Service of a copy of the within is herein' admitted.
Dated.•
Attorneysfor
EFTA00314177
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
X
GEORGE PETRIDES,
Index No.:
Plaintiff, NOTICE TO TAKE
DEPOSITION
-against -
Defendant.
X
PLEASE TAKE NOTICE, that pursuant to N.Y. C.P.L.R. 3101(a)(4) and N.Y. C.P.L.R.
3107, the deposition upon oral examination of JEFFREY EPSTEIN of the Epstein Foundation,
whose home address is 9 East 71st Street, New York, NY 10021, will be taken on the 29th day of
January, 2013 at 2:00 p.m. of that day, at the office of the attorney for the Plaintiff, DOBRISH
MICHAELS GROSS LLP at 757 Third Avenue, 15th Floor, New York; NY 10017. The
circumstances or reasons such disclosure is sought or required arc as follows:
Upon information and belief, the witness possesses information and documents, including
prepared records and backup schedules that are material and necessary to the prosecution of this
case not reasonably available from any of the other parties in this action.
JEFFREY EPSTEIN is required to produce at the examination the following records and
papers in his possession, custody, or control:
EFTA00314178
1. All records concerning the employment of including but not
limited to all contracts, correspondences, benefit records, compensation records
and/or reimbursements records.
Dated: New York, New York
January 9, 2013
DOBRISH MICHAELS GROSS LLP
By: Allison Berecz, Esq.
Attorneys for Plaintiff
757 Third Avenue, 15th Floor
New York, NY 10017
TO:
New York, NY 10016
2
EFTA00314179