EFTA00723778.pdf

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA B.B, CASE NO: Plaintiff, 502008CA0373193OOOCNIB AB vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S FIRST SET OF INTERROGATORIES PROPOUNDED ON DEFENDANT. JEFFREY EPSTEIN Plaintiff, B.B. pursuant to Fla. R. Civ. P. 1.340, Florida Rules of Civil Procedure, requests the Defendant, JEFFREY EPSTEIN, to answer under oath in writing within thirty (30) days from the date of service hereof the following: I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U. S. Mail, postage prepaid, this2-iday 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 Banyon Boulevard, Suite 400, West Palm Beach, FL 33401. LE0P0LD-KUVIN, P.A. 2925 PGA Boulevard Suite 200 33410 T. KUVIN, Esq. Florida Bar No.: 089737 EFTA00723778  1. If your answer to Request for Admission #1 is anything other than an unqualified admission, please state in detail the factual basis for your denial. 2. If your answer to Request for Admission #2 is anything other than an unqualified admission, please state in detail the factual basis for your denial. 3, If your answer to Request for Admission #3 is anything other than an unqualified admission, please state in detail the factual basis for your denial. Page 2 of 4 EFTA00723779  4. If your answer to Request for Admission #4 is anything other than an unqualified admission, please state in detail the factual basis for your denial. 5. If your answer to Request for Admission #5 is anything other than an unqualified admission, please state in detail the factual basis for your denial. Page 3 of 4 EFTA00723780  By: JEFFREY EPSTEIN STATE OF )ss: COUNTY OF The foregoing instrument was acknowledged before me this day of , 2010, by , who is personally known to me or has produced as identification, and who did (did not) take an oath: (NOTARY SEAL) NOTARY PUBLIC My commission expires: Page 4 of 4 EFTA00723781  IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: B.B, Plaintiff, 502008CA037319XXXXMB AB vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT, JEFFREY EPSTEIN Plaintiff, BB, requests Pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, within thirty (30) days of the date that Defendant, JEFFREY EPSTEIN, admit the following hereof: occurred at Jeffrey 1. Admit that B.B. suffered emotional trauma as a result of what Epstein's home. having post traumatic stress 2. Admit that Dr. Mary Littlefield's diagnosis of B.B. with home is a correct diagnosis. disorder as a result of what occurred at Jeffrey Epstein's home, B.B. has not faked or 3. Admit from the date of incident at Jeffrey Epstein's occasion. exaggerated her emotional trauma or symptoms on any onal trauma as a result of sexua l 4. Admit that a 15 year old girl can suffer from emoti activity with an adult male over 50 years old. relationships with boys her age 5. Admit that B.B. is having difficulties with intimacy in her in. as a result of the incident that occurred with Jeffrey Epste foregoing was furnished by U. S. I HEREBY CERTIFY that a true and correct copy of the Goldberger, Esq., 250 Australian Mail, postage prepaid, thin day of January, 2010 to Jack A. EFTA00723782  art, Esq., 250 Australian Avenue Avenue, Suite 1400, West Palm Beach, FL 33401; Bruce E. Reinh Critton, Jr., Michael J. Pike, 303 South, Suite 1400, West Palm Beach, FL 33401; Robert D. Banyon Boulevard, Suite 400, West Palm Beach, FL 33401. LEOPOLD-KUVIN, P.A. 2925 PGA Boulevard Suite 200 Beach ns, FL 3 l0 KUVIN, Esq. Florida Bar No.: 089737 Page 2 of 2 EFTA00723783