EFTA00598950.pdf

IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA B.B., CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. an and Defendants. EPSTEIN'S REQUEST FOR ADMISSIONS TO PLAINTIFF Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Rule 1.370, Florida Rules of Civil Procedure, requests that Plaintiff, B.B., respond to the following Request for Admissions: 1. Admit that the history you gave to Dr. Hall at your Compulsory Medical Examination on February 5, 2010 ("CME") was completely true and accurate. 2. Admit that you did not omit any facts from the history you gave to Dr. Hall at your CME. 3. Admit that the background information you gave to Dr. Hall 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. Hall at your CME. 5. Admit that you believe the questions asked of you by Dr. Hall were fair and reasonable. 6. Admit that you believe the manner in which the CME was conducted with you was professional. EFTA00598950  7. Admit that you believe you were treated respectfully and fairly by Dr. Hall 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 Lay of March, 2010: Theodore J. Leopold, Esq. Jack Alan Goldberger, Esq. Spencer T. Kuvin, Esq. Atterbury Goldberger & Weiss, P.A. Leopold-Kuvin, P.A. 250 Australian Avenue South 2925 PGA Blvd., Suite 200 Suite 1400 Palm Beach Gardens, FL 33410 West Palm Beach, FL 33401-5012 Fax: 561 697 2383 Fax: 561-835-8691 Counsel for Plaintiff Co-Counsel for Defendant Jeffrey Epstein BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan B d., Suite 400 West Palm h, FL 33401 (561) 84 (561) 5 ax By: rt D. Critton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) 2 EFTA00598951  IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA B.B., CASE NO. 502008CA037319YJ0O(MB AB Plaintiff, v. JEFFREY EPSTEIN and Defendants. EPSTEIN'S NOTICE OF SERVING SECOND SET OF INTERROGATORIES TO PLAINTIFF Defendant, Jeffrey Epstein, files this Notice of Serving Second Set of Interrogatories to Plaintiff B.B., 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 e copy of the foregoing was sent by U.S. Mail to the following addressees on thislf day of March , 2010: Brad Edwards, Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss, P.A. & Lehrman, PL 250 Australian Avenue South 425 N. Andrews Avenue, Suite 2 Suite 1400 Fort Lauderdale, FL 33301 West Palm Beach, FL 33401-5012 954-524-2820 Fax: 561-835-8691 954-524-2822 - fax Co-Counsel for Defendant Jeffrey Epstein brad@pathtojustice.com Counsel for Plaintiff Jay Howell, Esq. Jay Howell & Associates, P.A. 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 EFTA00598952 904-680-1234 Phone 904-680-1238 Fax Co-counsel for Plaintiff BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West Palm Be h, FL 33401 (561) 842- (561) 5 By: . Critton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) 2 EFTA00598953  FIFTH SET OF INTERROGATORIES 1. If your response to Request for Admissions No. 11 was anything other than an admission, please explain why you did not admit that the history you gave to Dr. Ryan Hall at your Compulsory Medical Examination on February 5, 2010 ("CME") was completely true and accurate and describe any false or inaccurate statements given to Dr. Hall. 2. If your response to Request for Admissions No. 2 was anything other than an admission, please describe the facts or events you omitted from the history given to Dr. Hall. 3. If your response to Request for Admissions No. 3 was anything other than an admission, please explain why you did not admit that the background information you gave to Dr. Ryan Hall at your CME was completely true and accurate and describe any false or inaccurate statements given to Dr. Hall. 1 All of the interrogatories relate to the Request for Admissions served by Defendant on March 12th, 2010. 3 EFTA00598954 4. If your response to Request for Admissions No. 4 was anything other than an admission, please explain what facts or events you omitted from the background information given to Dr. Hall. 5. If your response to Request for Admissions No. 5 was anything other than an admission, please explain why you do not believe the questions asked of you by Dr. Hall at your CME were not fair and reasonable. 6. If your response to Request for Admissions No. 6 was anything other than an admission, please explain why you believe the manner in which the CME was conducted was not processional. 4 EFTA00598955 7. If your response to Request for Admissions No. 7 was anything other than an admission, please explain why you believe you were not treated respectfully or fairly at your CME. 8. If your response to Request for Admissions No. 8 was anything other than an admission, please explain why you believe the testing procedures at your CME were not fair or reasonable. 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: (Notary Seal) 5 EFTA00598956