EFTA00728341.pdf

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION L.M., ) ) Plaintiff, ) CASE NO.: 502008CA028051XXXXMB AD ) vs. ) ) JEFFREY EPSTEIN, ) ) Defendant. ) ) NOTICE OF PRODUCTION FROM NON-PARTY Pursuant to Florida Rules of Civil Procedure 1.351 YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service of this notice, if service is by facsimile, or 15 days from the date of service, if service is by mail, and if no objection is received from any party, the undersigned will issue the attached subpoena directed to the following entites: 1. Financial Records Custodian — Palm Beach National Bank Who is/are not a party/parties to this suite, to produce the items listed at the time and place specified on the subpoena. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via U.S. Mail and Facsimile this >day of August, 2009 to: Michael Burman, Esq., & Robert D. Critton, Jr., Esq., Burman, Critton, et al., 515 North Flagler Drive, Suite 400, West Palm Beach, FL 33401; Jay Howell, Esq., Jay Howell & Assoc., 644 Cesery Boulevard, Suite 250, Jacksonville, FL 32211; and Jack Alan Goldberger, Esq., Atterbury Goldberger et al., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401. EFTA00728341  Case No. 502008CA028051XXXXMB AD ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale Florida 33394 Telephone Telecopier By: • Bradley J. Edwards 1 - William J. Berger Copies Furnished to: 2 EFTA00728342  IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION L.M., ) ) Plaintiff, ) CASE NO.: 502008CA028051)O=MB AD ) vs. ) ) JEFFREY EPSTEIN, ) ) Defendant. ) ) SUBPOENA DUCES TECUM WITHOUT DEPOSITION (Documents may be mailed in lieu of appearance) THE STATE OF FLORIDA TO: Financial Records Custodian Palm Beach National Bank 125 Worth Avenue Palm Beach, Florida YOU ARE COMMANDED to appear at the law offices of ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301 on or before the September 28, 2009, at 10:30 a.m., and to have with you at that time and place the following: A complete copy of all bank statements, records, applications for loans, mortgages of any kind whatsoever including correspondence to, from or regarding, for each and every account, including savings, trust, and/or any other account whatsoever in the name of or related to: Jeffrey Epstein 358 El Brillo Way West Palm Beach, FL 33480. Date of Birth: 1/20/53 EFTA00728343  PLEASE TAKE FURTHER NOTICE that this subpoena requires production of your complete, entire file contents. You are to produce each and every piece of paper contained in your files regarding the above individual, whether or not prepare by you. This further includes telephone messages, letters from attorneys, letters from the above individual, or from any other source. You are not permitted to edit or delete items. Failure to comply fully may result in court sanctions. These items may be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produces to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the undersigned attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: 1. Appear as specified; or 2. furnish the records instead of appearing as provided above; or 3. object to this subpoena, you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused form this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. Dated: August 1 2009. 2 EFTA00728344  ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort •erdale Florida 33301 Tel: Fax: Email: By: BRAD EDWARDS, ESQ. Florida Bar No.: 542075 3 EFTA00728345