EFTA00723734.pdf

JAN-15-10 15:25 FR0WLE0PMINKUVIN, P.A. 15616151401 14326 P.001/064 F-523 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: a 5O2OO8CAO37319XXXXMB AB Plaintiff, vs. JEFFREY EPSTEIN, Defendant. NOTICE OF INSPECTION/VIDEO OF PROPERTY Plaintiff, notified Defendant, JEFFREY EPSTEIN, pursuant to Fla. R.. Civ. P. 1.350 of her intent to perform a videotaped inspection of the property, 350 El Brillo Way, Palm Beach, Florida, at the agreed date and time of Monday, January 18, 2010 at 10:00 a.m. The inspection will be consistent with the attached court's Order dated December 7, 2009. HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by Fax and U. S. Mail, postage prepaid, this Lay of January, 2010 to Jack A. Goldberger, Esq., ■ M Bruce E. Reinhart, Esq., ■ I Robert D. Critton, Jr., Michael J. Pike, LEOPOLD-KU V IN, By: SP KUV1N, Esq. Florida Bar No.: 089737 EFTA00723734 JAN-15-10 15:25 FROM-IEOPOLD•KUVIN, P A. 15615151401 T-826 P.002/004 F-523 Ca!endued by: Scanned: v217 circulation: Is•••••••••••••• .111 .11• IN THE CIRCUIT COURT OF THE 01•••• ••••••••••••• 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 50200SCA037319XXXXMB AB a Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER ON REOUEST FOR ENTRY UPON LAND THIS CAUSE having come before the Court on October 14, 2009 on Plaintiff's Request for Entry Upon Land, and the Court having heard argument of counsel and considered the matter, it is hereby: ORDERED AND ADJUDGED that Plaintiff's Motion is hereby: GRANTED IN PART AND DENTED IN PART, as follows: 1. This Order pertains to this current litigation as well as the cases filed by Plaintiffs, 2. Plaintiffs' attorneys in these specific actions may conduct a limited-focused pathway video of the Defendant's home which is limited to the entryway into the home by the front door and side door of the home. The video shall only include video of entrances and exits of the entryway into the home by the front door and side door of the home and pathways of the home allegedly utilized by the Plaintiffs and the alleged rooms where these events allegedly took place, with no panning of the cameras, pending further court order and good cause shown. EFTA00723735 JAN-15-10 16:25 FR0WLE0P0ID•KUVIN, P.A. 15615151401 T-826 P:003/004 F-523 3. Counsel for Plaintiffs will instruct the videographer that he/she is not to pan the premises and is simply to videotape the pathway allegedly taken. 4. There will be no sound on the video at the time of video recording, and the video is not to be taken for the purpose of videoing the opulent nature of the home. 5. The video shall only be disclosed to Plaintiffs a,■ and and their counsel. The video shall be remain in the hands of the attorneys for a, and, Plaintiffs' counsel, Mr. Kuvin and Mr. Edwards, are instructed not to disseminate the video to anyone outside of their offices, without further consideration by the court after good cause is shown. This includes, but is not limited to, the media, any attorneys in any of the related Federal or State Court matters and any expert physicians, without further consideration by the court after good cause is shown. 6. Both Mr. Kuvin, Mr. Edwards, Mr. Critton and Mr. Pike may be present at this video inspection, and no other attorneys in any related matters. 7. This inspection/video shall take no longer than 30 minutes without further order or good cause shown. 8. Unless a timely Motion is filed, this inspection will take place within 45 days of the date of this Order, but no sooner than December 21, 2009, which is the end of the current stay in place in the M. and ■ matters. DONE AND ORDERED at , 6 2:4 . 1 4e---4 a, Florida, and this 2 day of e Honbzsible Donald Hefei e Circuit Court Judge Page 2 of 3 EFTA00723736 JAN-15-10 15:26 FROWLEOPelDsKUVIN. P A. 15615151401 T-826 P.004/004 F-523 Conformed Copies Furnished to: Spencer T. Kuvin, Leopold Sc. Kuvin P.A. Jack A. Goldin. er E r ince Reinhart, Esq., D. Clifton, Jr., MI° e e, Page 3 of 3 EFTA00723737 JAN-15-10 1E:40 7. A S cC T —E:: 7 LEOPOLD-KUVIN. CONSUMER JUSTICE ATTORNEYS January 15, 2010 Via Fax and Mail Bruce E. Reinhart, Esq. Bru R inhart P.A. Re: v. JEFFREY EPSTEIN OUR FILE NO.: 080303 Dear Mr. Reinhart: I have not heard from you regarding the scheduling of deposition on January 27, 2010. My assistant Margaret, spoke with Kim last week to either confirm that this deposition would go forward to request a new date. Please advise upon receipt of this letter regarding deposition. Your anticipated cooperation is appreciated. STICinlb Cc: Robert Critten, Esq. Jack Goldberger, Esq. •• lax larapolilkuvin.can PERSONAL INJURY • WRONGFUL DEATH CI1ASI 'WORTHINESS • MANAGED CARE ABUSE • CONSUMER CLASS ACTIONS • EFTA00723738