EFTA01076842.pdf

IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendant. MOTION FOR LEAVE TO SERVE ADDITIONAL INTERROGATORIES Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Fla. R. Civ. P. 1.340, moves for leave to serve additional thirty (30) interrogatories and states: 1. On February 25, 2010, Epstein propounded his Fourth Set of Interrogatories on (attached as Exhibit A). 2. With respect to interrogatories 3 —12,. objected and stated "beyond the limit of Interrogatories allowed pursuant to FRCP 1.340." See Answers to Interrogatories attached as Exhibit B. 3. As the Court is aware, 1. is seeking significant damages in this case. In addition, is a witness in companion cases filed by other plaintiffs against Epstein. 4. III testified that she went to Mr. Epstein's home anywhere from fifty (50) to more than seventy (70) times and brought more than seventy (70) females, some of whom are plaintiffs in companion cases against Epstein. See 9/24/09 Deposition Transcript of El at 74, 164. 5. Due to the nature of the claims, the number of times In claims to have gone to Mr. Epstein's home and the number of girls ■ claims to have brought to Mr. EFTA01076842 Epstein, permitting Epstein to serve additional interrogatories is clearly justified under the circumstances. 6. Moreover, Interrogatory Nos. 3 (past sexual history), 4 — 5 (social networking websites) of Epstein's Fourth Set of Interrogatories seeks information that the Court previously held was discoverable. 7. At the July 16. 2009 hearing on Epstein's Amended Motion to Compel, the Court ordered to produce all information related to social networking sites. Specifically, the Court stated: So my ruling is as follows: I am going to allow first, as dictated by Menke, the voluntary — not voluntary — but the turning over of the social-network site information that is accessible to the site owner or user, meaning the plaintiff, or plaintiffs in this case, either of them or both of them, if they have these types of networking sites, including of what would be shared with others, if those individuals allow other to become what is commonly known as friends. That will be discoverable. See Excerpt of July 16, 2009 Transcript at 36 (attached as Exhibit C). 8. On August 20, 2009, the Court compelled to answer Epstein's interrogatory related to her past sexual history. See August 20, 2009 Order attached as Exhibit D. El petitioned for a writ of certiorari to the Fourth District Court of Appeal regarding said order, which was denied. 9. In addition, Epstein intends to serve interrogatories relating to "common interest" or "pooled information" agreements between and other plaintiffs, which courts have held is discoverable. See Trading Technologies Int'l v. eSpeed, Inc. 2007 WL 1302765 * 2 (a. III. 2007) (noting that if a common interest agreement is memorialized in writing, the opposing party is entitled to a copy of it). Epstein also 2 EFTA01076843  mpanying a Request for Admissions recently served a Fifth Set of Interrogatories acco objected as beyond the limit of (attached as Composite Exhibit E), to which II 1.340. The Request for Admissions and Interrogatories allowed pursuant to FRCP Interrogatories seek information related to CME with Epstein's expert, Dr. ■. ered the Request for Admissions This information is certainly discoverable as III answ for responses to the without objection. The Interrogatories seek explanations Request for Admissions. ogatories. 10. ■ would not be prejudiced by Epstein serving additional interr etion of the trial 11. The allowance of additional interrogatories is in the discr rally liberally allowed. See court and where there is just cause, interrogatories are gene Rich v. Hunter 3 So. 2d 393, 396 (Fla. 1941) the Court enter an order WHEREFORE, Defendant, JEFFREY EPSTEIN, requests ries and grant any additional granting leave to serve an additional thirty (30) interrogato relief the Court deems just and proper. CERTIFICATE OF SERVICE sent by fax and U.S. I HEREBY CERTIFY that a true copy of the foregoing was 2010: Mail to the following addressees on this 27th day of April, BURMAN CRITTON LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West Palm Be ch, FL 33401 ax ert D. Critton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 3 EFTA01076844  Jack Alan Goldberger, Esq. Brad Edwards, Esq. Atterbury Goldberger & Weiss,111. s, Farmer, Jaffe, Weissing, Edward 250 Australian Avenue South Fistos & Lehrman, PL Suite 1400 424 N. Andrews Avenue, Suite 2 Wes FL 33401-5012 le, FL 33301 Fax: Co-Counsel for Defendant Epstein Counsel for Plaintiff Jay Howell, Esq. Jay Howell & Associates,'B. 644 Cesery Boulevard Suite 250 MEL 32211 Phone Fax Co-counsel for Plaintiff 4 EFTA01076845  IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN Defendant. DEFENDANTS NOTICE OF SERVING FOURTH SET OF INTERROGATORIES TO PLAINTIFF Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), files this Notice of Serving Fourth Set of Interrogatories to Plaintiff M., pursuant to Rule 1.340, Florida Rules of Civil Procedure, and request the Plaintiff to answer said interrogatories in writing within thirty (30) days from date of service hereof. Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by U.S. Mail to eel ) the following addressees on thisp_ day of February 2010: Brad Edwards, Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss, M. & Lehrman, PL 250 Australian Avenue South 425 N. Andrews Avenue, Suite 2 Suite 1400 uderdale, FL 33301 West Pam Beach FL 33401-5012 Fax: Co-Counse or Defendant Jeffrey Epstein Counsel for Plaintiff Jay Howell, Esq. Jay Howell & Associates, 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 EXHIBIT k EFTA01076846  Phone Fax Co-counsel for Plaintiff BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 A o e D. Critton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) 2 EFTA01076847  DEFINITIONS AND INSTRUCTIONS 1. The term "Plaintiff' refers to II., and all her agents, employees, g on their behalf. representatives, attorneys, accountants or anyone else actin all his agents, 2. The term "Defendant" refers to Jeffrey Epstein and persons acting or purporting to representatives, employees, assigns, or other person or act on its behalf. conjunctively and 3. The words "and" and "or" shall be construed both r than exclusive. The singular disjunctively so as to make the request inclusive rathe include the singular. shall be construed to include the plural and the plural to written statement or 4. The word "communication(s)" shall mean any oral or more persons, including but not exchange of information of any type between two or conversations, meetings or limited to documents, telephone or face-to-face conferences. kind, including, but 5. The word "document" shall mean any writing of every lope, file cabinet drawer not limited to, any letter, book, record, report, file folder, enve drawing, chart, draft, schedule, label, memorandum, correspondence, communication, computer printout and any other photograph, tape, disc, card, wire, computer program instrument or device from electronic or mechanical recording or transcript of any other to memorialize human thought, which information can be perceived or which is used Plaintiff. The term "document" speech or action in the possession, custody, or control of to that contained on the original also includes copies containing information in addition to in any document. The and all the attachments, enclosures, or documents referred meaning and equal in scope to term "document" is also defined to be synonymous in 3 EFTA01076848  edure 34(a), including, without the usage of this term in Federal Rule of Civil Proc s. A draft or non-identical copy is limitation, electronic or computerized data compilation a separate document within the meaning of this term. person, individual, 6. The word "person" shall mean any natural organization, joint venture, proprietorship, partnership, corporation, association, rnmental body or agency, or business trust or other business enterprise, gove of natural persons or other governmental, public, legal, or business entity, or group entities whether suifurls or otherwise. e to, respond to, 7. The phrase "relate to" shall mean refer to, contain, allud mention, analyze, constitute, comment upon, discuss, show, disclose, explain, or characterize, either directly comprise, evidence, set forth, summarize, support, refute or indirectly, in whole or in part. s to state the 8. "Identify," when used to refer to a natural person, mean following: ss is not know, (a) his or her full name and address (or, if the present addre his or her last known address); employers, each (b) the full name and address of each of his or her each business corporation of which he or she is an officer or director, and in which he or she is a principal; not known, his or (c) his or her present position (or if the present position is the Interrogatory her last known position(s) at the time of the act to which response relates). t to identify the (d) Such other information sufficient to enable Defendan person. natural person 9. "Identify" when used to refer to any entity other than a means to state the following: 4 EFTA01076849  (a) The full name of the entity, the type of the entity (e.g., corporation, partnership, etc.), the address of its principle place of business, its principle business activity, and if it is a corporation, the jurisdiction under which it has been organized and the date of incorporation. 10. "Identify," when used with reference to a Document or Communication means to state the following: (a) the nature of the document (e.g., letter, memorandum, etc), date of creation, author, place of preparation, the name and address of each addressee; (b) The identity of each signatory; (c) The title or heading of the document; (d) the general substance and subject matter; (e) Its present location and custodian (or, if not know, the last known); (f) the identity of each person to whom a copy of the document was sent and each date of Its receipt and date of its transmittal or other disposition; (g) The circumstance of each such receipt and each transmittal or other disposition, including identity of the person transmitting and receiving it. 11. In lieu of identifying any document, Plaintiff may attach a true and correct copy of such document as an exhibit to its response to these Interrogatories, along with an explicit reference to the Interrogatory to which each document is responsive. 12. If the response to all or part of any Interrogatory is not known at the time the initial response is made, please include a statement to that effect, furnish the information that is known or available, and respond to the Interrogatory by amended or supplemental response in writing under oath within ten (10) days of the date on which the complete response becomes known or available. 5 EFTA01076850  FOURTH SET INTERROGATORIES TO PLAINTIFF e numbers, dates of 1. List the names, business addresses, telephone and cell phon and rates of pay employment, immediate supervisor (name and address) you have worked regarding all employers, including self-employment, for whom d by Defendant on since you answered the First Set of Interrogatories propoundesources of income and all or about December 10, 2008; this includes listing any you have received. mental health 2. Identify.' each physician or medical provider (including whom you have professionals, drug or alcohol counselors and therapists) with ify each facility consulted or who has treated or examined you, and, ident ient or outpatient) (including drug or alcohol treatment facilities, whether inpat or treatment that is in where you have received any consultation, examination of consultation, any way related to this case; and state as to each the date n for which you examination or treatment and the injury, condition or other reaso of Interrogatories were examined or treated since you answered the First Set propounded by Defendant on or about December 10, 2008. for the information sought by use of the Please refer to the "Definitions' section of these Interrogatories term •identify." 6 EFTA01076851  ers of all males, excluding 3. List separately the names, addresses and phone numb since you answered the Mr. Epstein, with whom you have had sexual activity about December 10, First Set of interrogatories propounded by Defendant on or of sexual activity, the 2008 up through the current date. Describe the nature tion from the person. date(s) and whether you received money or other considera social networking website 4. Are you w or have ou ever been a member of a , or any similar such as websites? you are currently a a. If so, please list all social networking websites of which previously a member; list all social networking websites of which you were the date you member and state the date you joined each site and cancelled your membership with each site. les" you used for b. Also, please list all usernames, screen names or "hand ber. Also, each social networking site of which you were ever a mem social please provide all uniform resource locators ("URL") for each i e ' of which you are, or were previously a member (i.e. 7 EFTA01076852 5. Are o u r been a member of an online dating website such as or any similar website? a. If so, please list all online dating websites of which you are currently a member, list all online dating websites of which you were previously a member and state the date you joined each site and the date you cancelled your membership with each site. b. Also, please list all usemames, screen names or "handles" you used for each online dating website of which you were ever a member. Also, please provide all URLs for each social networkin website of which you are, or were previously a member (i.e. 6. Do you, or have you ever kept, a diary or journal since 2002? If so, please state whether the diary or joumal was/is kept in hard copy or whether it was/is kept on a computer or other electronic device. a. If the diary or journal was kept in hard copy, describe its physical attributes (i.e. book, collection of loose paper, day planner) and state its current location. 8 EFTA01076853  b. If the diary or journal wasfis kept on a computer or other electronic device, please Identify the computer or electronic device, including the make and model; identify the owner of the computer or electronic device; and state the current location of the computer or electronic device. If the current location is unknown, please state the last known location of the computer or electronic device. c. Identify all individuals, including their full name, current address, home telephone number and cellular telephone number, that have read any portion of the diary or journal. d. Please state whether any copies were made of the diary or journal. If so, state the number of copies made and identify all individuals, including their full name, current address, home telephone number and cellular telephone number, who have, or at any time had, a copy of the diary or journal. 10. Please identify all computers you have used since 2002 and identify the owner of each computer; state the make, model and current location of each computer, if the current location of a particular computer is unknown, state each location in which you used last used each computer. 9 EFTA01076854 11. Please identify your five closest friends for the years 2008 — 2010, including their full name, current address, home telephone number and cellular telephone number. 12. Do you intend to call at trial other females who went to Mr. Epstein's residence? If so, please identify each individual, including their name, current address, home telephone number and cellular telephone number, and identify her counsel. Also, please state the substance of each witness's testimony. 10 EFTA01076855  VERIFICATION By: STATE OF FLORIDA ) ) ss COUNTY OF PALM BEACH ) SWORN TO AND SUBSCRIBED before me this day of 2010 by , who is personally known to me or has produced the following identification which is current or has been issued within the past five years and bears a serial or other identifying number. Print Name Signature NOTARY PUBLIC - STATE OF FLORIDA Commission Number: My commission expires: (Notarial Seal) 11 EFTA01076856  IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502008CA028051XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendant. NOTICE OF SERVICE OF PLAINTIFF'S UNVERIFIED ANSWERS TO DEFENDANT'S FOURTH INTERROGATORIES Plaintiff,.., hereby files her Notice of Service of Ppintifl's Unverified 11024-witr Answers to Fourth Interrogatories propounded by Defendant on-March-2i, 2010. CERTICATE OF SERVICE I HEREBY CERTIFY that daoriginal of the above and a copy of the foregoing has been provided this I - -- day of April 2010 via U.S. Mail and email transmittal to all those on the attached service list Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman,'" 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 By: BRADLEY J. EDWARDS Florida Bar No.: 542075 EXHIBIT21 EFTA01076857  SERVICE LIST Robert D. Critton, Jr. BURMAN, CRITTON, et al. 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 Jay Howell, Esq. Jay Howell & Assoc. 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 Jack Alan Goldberger, Esq. Atterbury Goldberger et al. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401 EFTA01076858  PLAINTIFF'S ANSWERS TO FOURTH INTERROGATORIES phone numbers, dates of 1. List the names, business addresses, telephone and cell employment, immediate supervisor (name and address) and rates of pay regarding all employers, including self-employ ment, for whom you have worked Interrogator ies propounded by Defendant on since you answered the First Set of sources of income or about December 10, 2008; this includes listing any and all you have received. ANSWER: Objection, irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, harassing, without waiving objections or invocations of privilege, Plaintiff has already been deposed since December 2008 on the subject, additionally, she has withdrawn her wage claim. health 2. Identify' each physician or medical provider (including mental with whom you have professionals, drug or alcohol counselors and therapists) you, and identify each facility consulted or who has treated or examined (including drug or alcohol treatment facilities, whether inpatient or outpatient) that Is in where you have received any consultation, examination or treatment consultation, any way related to this case; and state as to each the date of examination or treatment and the injury, condition or other reason for which you First Set of Interrogator ies were examined or treated since you answered the propounded by Defendant on or about December 10, 2008. ANSWER: Fort Lauderdale, FL 33304 Interrogatories 3-12 ANSWERS: Objection, beyond the limit of Interrogatories allowed pursuant to FRCP 1.340. EFTA01076859  CUIT THE FIFTEENTH JUDICIAL CIR • IN THE CIRCUIT COURT OF , FLORIDA AND FOR PALM BEACH COUNTY MB AB CASE NO. 502008CA028051XXXX L.M., Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. MB AB CASE NO. 502008CA028058XXXX E.W., Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. BLE HEARING BEFORE THE HONORA DONALD HAFELE ThursdEa July 16 2009 8:13 III - 9:10 e Palm'Beach County Courthous a West Palm Beach, Florid Reported By: Pamela J. Sullivan, RPR, FPR rida Notary Public, State of Flo Age ncy , Inc. Prose Court Reporting EXHIBIT RT REPORTING AGENCY, INC. (561) 832-7506 (56 1) 832 -75 00 PRO SE COU 6ba eSlae55d-c6fa-4919-84de-87e224(146 laSu ltbr ot(5 01-3 31-radm) mocimnitaityWgnedbyPerne EFTA01076860  Page 34 Page 36 for this whatsoever, for this type of invasive I. And, again, I'm trying my best to balance the 2 discovery, where you get all access to -- whether 2 interests between the individual's privacy rights 3 it's voluntarily turned over or you get to go in 3 and a defendant's right to discover what could lead 4 and actually remove it from the hard drive of a 4 to ditcovery of admissible evidence, when it deals 5 computer -- the social-networking site they chose 5 with damages. 6 to remain private. 6 So my ruling is as follows: Tarn going to 7 TliE COURT: Well, would it have to be removed allow first, as dictated by Menke, the voluntary - from the social activate, or could it be just 8 not voluntary but the turning over of the 9 primed from the netwoda 9 social-network site information that is accessible 10 MR. EDWARDS: I closet know bow the network 10 to the site owner or user, meaning the plaintiff, 11 works and whether you can print every single page 11 or plaintiffs in this case, either of them or both 12 and what that actually does. 12 of them, if they have these types of networking 13 THE COURT: Well, let's find out. I mean, 13 sites, inclusive of what would be dared with 14 you know, I would have preferred Mr. Clifton's 14 others, if those individuals allow others to become 15 amended motion to have been supplemented by an 15 what is commonly knovm as fiends. That will be 16 affidavit of a computer expert, to give the Court 16 discoverable. It will be placed under seal and for 17 information as to how this type of 17 attorneys' eyes only at this time, pending further 18 social-networking information would be extracted in 18 Coun order. 19 the least intrusive means to either plaintiff. 19 MR. EDWARDS: Your Honor. 20 But without that, I'm in the same — I'm In 20 THE COURT: We'll move on now to e-mails sent 21 the dark myself, because I'm not a computer expert 21 and received byplaintiffs. 22 by any means. 22 MR. CRUTCH: From a time standpoint, within 23 MR. EDWARDS: And, Judge, just along those 23 20 days? 24 lines, talking about the Mae case, that was 24 71W COURT: Within 20 days. 25 specifically a case dealing with sexually explicit 25 MR. EDWARDS: And, Your Honor, my only Page 35 Page 37 3. e-maik sent from his computer. And that was the 1 objection to that is the Fifth Amendment privilege 2 computer of the perpetrator. What we're actually 2 that would pertain to my clients and the 3 contemplating now is turning over all of this 3 information on there, as well as all of the other 4 information, that they chose to keep private 4 people who commutate on there and their privacy 5 amongst their own Mends, of the victims of sexual 5 interest, as well, in addition to the fact that the 6 abuse to a registered sex offender. 6 Mae case says, in quotes, in the few cases we 7 THE COURT: Well — 7 have found across the country permitting access, 8 MEL I3DWARDS: And there is not one single 8 all have — all have been in situations where 9 thing they pointed to that is evidence that I know 9 evidence of intentional deletion of data was 10 about — in fact, I don't even know if they ltave a 10 present. And that's not present here. 11 computer. 11 All of the arguments about damages claimed 12 THE ODTJRT: Iwouldn't be doing this, but for 12 and a right for a defendant to defend himself could 13 the fact — or wouldn't even be contemplating doing 13 be made in every, single personal injury case that 14 this, but for the fact that you have to remember a 14 we — thafs ever existed. 15 very, very important point here, respectfully, and 15 THE COURT: I've already trade my ruling, but 16 that lsyour clients have brought a lawsuit against 16 I— 17 the defendant. And by doing that, there is a 17 MR EDWARDS! I understand. 18 certain degree of discovery that must be undertaken 18 THE COURT: — as I said, I'm juxtaposing the 19 for the defendant to defend himself against the 19 language contained on the last page of the slip 20 claims that have been made based on the allegations 20 opinion, that intrusive searching of the entire 21 of loss of enjoyment of live, mental anguish, 23. computer by opposing parties should not be the 22 damages that extend from a psychological standpoint 22 first means of obtaining the relevant information. 23 from an alleged sexual battery. All of tbese 23 And then with the last sentence: "That we do 24 things are necessary, in my view, to be able to . 24 not deny the Board the right to request that the 25 adequately defend those claims. 25 petitioner produce relevant, nonprivileged aMm.s. 10 (Pages 34 to 37) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela SSivan (501483-772A562) eSi ao55d•eatad9 18.84de-fl22W4aba EFTA01076861  IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051XX)0(MB AB Plaintiff, v. JEFFREY EPSTEIN Defendant. NCE WITH COURT ORDER ORDER ON EPSTEIN'S MOTION TO COMPEL COMPLIA TS AND FOR AWARD OF ATTORNEY'S FEES AND COS n To Compel Compliance THIS CAUSE came before the Court on Epstein's Motio ticArst 9una. aea r 221/1 Costs, and the Court having With Court Ordernd For Award Of Attorney's Fees And premises, it is hereby heard argument of counsel and being fully advised in these hereby ORDERED and ADJUDGED that Defendant's Motion is granted/' LS -Cittseit.e siAtat A.424-ennot- -Cn. 4e- -CamCr=")71--. _kyr - .1••••snaaajar wry - - 4&, ce...tre at 10 ati+ .c.vsati as 4:7 tionSavusisa-P Sic", tin-f2 rtei-OefLai‘a 4.. net -14,e_..944,401--c - DONE AND ORDERED at Palm Beach County urthouse, West Palm Beach, Florida, this day of , 200 Circu Judge Copies furnished: ESQ., 515 North Flagler Drive, Suite 400, ROBERT D. CRITTON, JR., ESQ., and MICHAEL J. PIKE, Edwards and Associates, LLC. West Palm Beach, FL 33401 and BRAD EDWARDS, ESQ., Brad Jay Howell & Associates, LL, ESQ., Harrison Street, Suite 202, Hollywood, FL 33020, JAY HOWE GOLDBERGER, ESQ., Atterbury , and JACK A. 644 Cesery Boulevartaauite 250, Jacksonville, FL 32211 1400, West Palm Beach, FL 33401-5012 Goldberger & Weiss, M., 250 Australian Avenue South, Suite EXHIBIT b EFTA01076862  IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051)000MO AB Plaintiff, v. JEFFREY EPSTEIN, Defendant. EPSTEIN'S REQUEST FOR ADMISSIONS TO PLAINTIFF Defendant, JEFFREY EPSTEIN (Epstein"), pursuant to Rule 1.370, Florida Rules of Civil Procedure, requests that Plaintiff.", respond to the following Request for Admissions: 1. Admit that the history you gave to Dr. at your Compulsory Medical Examination on February 15, 2010 ("CME") was completely true and accurate. 2. Admit that you did not omit any facts from the history you gave to Dr. II at your CME. 3. Admit that the background information you gave to Dr. II at your CME was completely true and accurate. 4. Admit that you did not omit any facts from the background information you gave to Dr. III at your CME. 5. Admit that you believe the questions asked of you by Dr. III were fair and reasonable. 6. Admit that you believe the manner in which the CME was conducted with you was professional. erra :le EXHIBIT EFTA01076863  . v. Epstein Re 2 7. Admit that you believe you were treated respectfully and fairly by Dr."" at the CME. 8. Admit that you believe the testing procedures utilized at your CME were fair and reasonable. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. Mail to the following addressees on this lefty of March, 2010: Brad Edwards, Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss,'" & Lehrman, PL 250 Australian Avenue South 424 N. Andrews Avenue, Suite 2 Suite 1400 le, FL 33301 Wes FL 33401-5012 Fax: Co-Counsel for Defendant Jeffrey Epstein ounsel for Plaintiff Jay Howell, Esq. Jay Howell & Associates, 644 Cesery Boulevard Suite 250 32211 Phone Fax Co-counsel for Plaintiff BURMAN CRITTON LUTTIER & COLEMAN, LLP 303 Banyan Bouleva Suite 400 West Palm Beach 01 By: Robert D. Critt Florida Bar 24162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) EFTA01076864  IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50200SCA028051XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendant. EPSTEIN'S NOTICE OF SERVING FIFTH SET OF INTERROGATORIES TO PLAINTIFF Defendant, Jeffrey Epstein, files this Notice of Serving Fifth Set of Interrogatories to Plaintiff In, pursuant to Rule 1.340, Florida Rules of Civil Procedure, and requests the Plaintiff to answer said interrogatories in writing within thirty (30) days from date of service hereof. Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by U.S. Mail to Yh the following addressees on this tday , of March , 2010: Brad Edwards, Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss, a & Lehrman, PL 250 Australian Avenue South 425 N. Andrews Avenue, Suite 2 Suite 1400 Fort Lauderdale, FL 33301 Wes L 33401-5012 Fax: Co-Counsel for Defendant Jeffrey Epstein Counsel for Plaintiff Jay Howell, Esq. Jay Howell & Associates, 644 Gesell,' Boulevard Suite 250 32211 Phone EFTA01076865  Fax Co-counse or Plaintiff BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West Palm B h, FL 33401 ax By: rt Critton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) 2 EFTA01076866  FIFTH SET OF INTERROGATORIES 1. If your response to Request for Admissions No. 1' was anything other than an please explain why you did not admit that the history you gave to Dr. at your Compulsory Medical Examination on