EFTA00614533.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON Plaintiff, Vs. JEFFREY EPSTEIN, et al. Defendant. Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 PLAINTIFF'S NOTICE OF SERVICE OF EXPERT INTERROGATORIES TO DEFENDANT Plaintiff, Jane Doe, hereby files this Notice of Service of Expert Interrogatories to Defendant, Jeffrey Epstein, pursuant to Rule 33 of the Federal Rules of Civil Procedure, and would request that the Defendant answer in writing and under oath, the attached Expert Interrogatories within thirty (30) days from the date of service hereof. CERTICATE OF SERVICE I HEREBY CERTIFY that the original of the above and a copy of the foregoing has C.; c`. been provided this I day of May 2010 via U.S. Mail and email transmittal to all those on the attached service list. EFTA00614533  Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale Florida 33301 Telephone Facsimile Florida Bar No • 54207 E-mail: and Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: Facsimil • E-Mail: 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 EFTA00614534  PLAINTIFF'S EXPERT INTERROGATORIES 1. Please identify each person whom you expect to call as an expert witness at trial, providing his/her name, street address and telephone number and state the subject matter on which each expert identified is expected to testify, the substance of the facts and opinions to which each expert is expected to testify and a summary of the grounds for each opinion. 2. State in detail the educational background, training and/or experience of each person identified above which qualifies him/her as an expert and identify for each person listed above the field of their expertise. (You may attach a current CV in lieu of answering the question.) EFTA00614535 3. Please give a detailed list of all publications which each expert identified above has authored, or co-authored and the name of the publication in which the article has appeared, or the name of the publisher who has published the article and enough information about the publication to enable this Plaintiff to obtain it. 4. Please state the state, county, city and court style of the case, and case number of every case that each of the experts listed above has been identified either by answers to expert interrogatories or by the fact that they have presented themselves and given a deposition in the three (3) years preceding the date of these interrogatories. EFTA00614536 5. Please state the scope of employment in the pending case and the compensation for such service. 6. Please state the expert's general litigation experience, including the percentage of work performed for plaintiffs and defendants. EFTA00614537 7. Please state the identity of other cases, within a reasonable time period, in which the expert has testified by deposition or at trial. 8. Please state an approximation of the portion of the expert's involvement as an expert witness, which may be based on the number of hours, percentage of hours, or percentage of eamed income derived from serving as an expert witness. 9. Please state the names, business and residence addresses, and business and residence telephone numbers of any expert witnesses who have been retained or especially employed by you or your attomeys in anticipated or preparation for trial and who are not expected to be called as witnesses at trial. EFTA00614538  JURAT PAGE AFFIANT STATE OF FLORIDA ) ) SS: COUNTY OF ) The foregoing instrument was acknowledged before me this day of , 2010 by who is personally known to me/who provided the following as identification and who did/did not take an oath. Notary Public My Commission Expires: EFTA00614539