IN THE COURT OF THE FIFTEENTH

IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028058XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendant. EPSTEIN'S 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 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, is seeking significant damages in this case. In addition, ■ is a witness in companion cases filed by other plaintiffs against Epstein. 4. ■ has not yet been deposed in this case. On April 2, 2010, Illfailed to appear for deposition despite assurances by her counsel the day before that she would attend the deposition. As a result, Epstein filed a Motion to Compel her deposition. 5. Due to the nature of the claims involved in this case and the damages sought, and since Epstein has yet to deposes, Epstein requests leave to serve an additional 30 interrogatories. 1 EFTA01076802 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 LM 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 i to answer Epstein's interrogatory related to her past sexual history. See August 20, 2009 Order attached as Exhibit D. 9. would not be prejudiced by Epstein serving additional interrogatories. 10. The allowance of additional interrogatories is in the discretion of the trial court and where there is just cause, interrogatories are generally liberally allowed. See Rich v. Hunter, 3 So. 2d 393, 396 (Fla. 1941) WHEREFORE, Defendant, JEFFREY EPSTEIN, requests the Court enter an order granting EPSTEIN leave to serve an additional thirty (30) interrogatories and grant any additional relief the Court deems just and proper. 2 EFTA01076803 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 27th day of April, 2010: Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 424 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Counsel for Plaintiff Jay Howell, Esq. Jay Howell & Associates, III 644 Cesery Boulevard Suite 250 32211 Phone Fax Co-counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, a 250 Australian Avenue South Suite 1400 West L 33401-5012 Fax: Co-Counsel for Defendant Jeffrey Epstein BURMAN CRITTON LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West Palm h. FL 33401 By: Robe P. on, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 David A. Yarema Florida Bar #12492 ax 3 EFTA01076804 MB, Plaintiff, v. JEFFREY EPSTEIN, Defendant. IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028058XXXXMB AB DEFENDANT'S 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-'., 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 the following addressees on this eday of February , 2010: Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 le, FL 33301 Jay Howell, Esq. Jay Howell & Associates, II. 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, E. 250 Australian Avenue South Suite 1400 Wes FL 33401-5012 Fax: Co-Counsel for Defendant Jeffrey Epstein 1 EXHIBIT A- EFTA01076805 Phone Fax Co-counsel for Plaintiff BURMAN, CRITTON, LUTHER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West Pa i ch, FL 33401 By: Fax D. Critton, Critton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) EFTA01076806 DEFINITIONS AND INSTRUCTIONS 1. The term Plaintiff' refers to in, and all her agents, employees, representatives, attorneys, accountants or anyone else acting on their behalf. 2. The term "Defendant" refers to Jeffrey Epstein and all his agents, representatives, employees, assigns, or other person or persons acting or purporting to act on its behalf. 3. The words "and" and "or" shall be construed both conjunctively and disjunctively so as to make the request inclusive rather than exclusive. The singular shall be construed to include the plural and the plural to include the singular. 4. The word "communication(s)" shall mean any oral or written statement or exchange of information of any type between two or more persons, including but not limited to documents, telephone or face-to-face conversations, meetings or conferences. 5. The word "document" shall mean any writing of every kind, including, but not limited to, any letter, book, record, report, file folder, envelope, file cabinet drawer label, memorandum, correspondence, communication, drawing, chart, draft, schedule, photograph, tape, disc, card, wire, computer program computer printout and any other electronic or mechanical recording or transcript of any other instrument or device from which information can be perceived or which Is used to memorialize human thought, speech or action in the possession, custody, or control of Plaintiff. The term "document" also includes copies containing Information in addition to that contained on the original and all the attachments, enclosures, or documents referred to in any document. The term "document" is also defined to be synonymous in meaning and equal in scope to EFTA01076807 the usage of this term in Federal Rule of Civil Procedure 34(a), including, without limitation, electronic or computerized data compilations. A draft or non-identical copy is a separate document within the meaning of this term. 6. The word "person" shall mean any natural person, individual, proprietorship, partnership, corporation, association, organization, joint venture, business trust or other business enterprise, governmental body or agency, or governmental, public, legal, or business entity, or group of natural persons or other entities whether sui juris or otherwise. 7. The phrase "relate to* shall mean refer to, contain, allude to, respond to, comment upon, discuss, show, disclose, explain, mention, analyze, constitute, comprise, evidence, set forth, summarize, support, refute or characterize, either directly or indirectly, in whole or in part. 8. "Identify," when used to refer to a natural person, means to state the following: (a) his or her full name and address (or, if the present address is not know, his or her last known address); (b) the full name and address of each of his or her employers, each corporation of which he or she is an officer or director, and each business in which he or she is a principal; (c) his or her present position (or if the present position is not known, his or her last known position(s) at the time of the act to which the Interrogatory response relates). (d) Such other information sufficient to enable Defendant to identify the person. 9. "Identify" when used to refer to any entity other than a natural person means to state the following: EFTA01076808 (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. EFTA01076809 FOURTH SET INTERROGATORIES TO PLAINTIFF 1. List the names, business addresses, telephone and cell phone numbers, dates of employment, immediate supervisor (name and address) and rates of pay regarding all employers, including self-employment, for whom you have worked since you answered the First Set of Interrogatories propounded by Defendant on or about December 10, 2008; this includes listing any and all sources of income you have received. 2. Identify' each physician or medical provider (including mental health professionals, drug or alcohol counselors and therapists) with whom you have consulted or who has treated or examined you, and identify each facility (including drug or alcohol treatment facilities, whether inpatient or outpatient) where you have received any consultation, examination or treatment that is in any way related to this case; and state as to each the date of consultation, examination or treatment and the injury, condition or other reason for which you were examined or treated since you answered the First Set of Interrogatories propounded by Defendant on or about December 10, 2008. Please refer to the "Definitions' section of these Interrogatories for the information sought by use of the term "identify." EFTA01076810 3. List separately the names, addresses and phone numbers of all males, excluding Mr. Epstein, with whom you have had sexual activity since you answered the First Set of Interrogatories propounded by Defendant on or about December 10, 2008 up through the current date. Describe the nature of sexual activity, the date(s) and whether you received money or other consideration from the person. 4. Are you n w o have ou ever been a member of a social networking website such as or any similar websites? a. If so, please list all social networking websites of which you are currently a member, list all social networking 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 social networking site of which you were ever a member. Also, please provide all uniform resource locators ("URL") for each social networking website of which you are, or were previously a member (i.e. myspace.comljanedoe). EFTA01076811 5. Ar t o riasember 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 soci • 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 journal 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. EFTA01076812 b. If the diary or journal was/is 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. EFTA01076813 11. Please identify your five closest friends for the years 2006 - 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. EFTA01076814 VERIFICATION By: STATE OF FLORIDA COUNTY OF PALM BEACH ) ss 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) EFTA01076815 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502008CA028058XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN. Defendant. NOTICE OF SERVICE OF PLAINTIFF'S VERIFIED ANSWERS TO DEFENDANT'S FOURTH INTERROGATORIES Plaintiff, M., hereby files her Notice of Service of Plaintiffs Answers to Fourth Interrogatories propounded by Defendant on February 25, 2010. CERTICATE OF SERVICE I HEREBY CERTIFY that the original of the above and a copy of the foregoing has been provided this Ir. 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 fax By: BRADLEY J. EDWARDS Florida Bar No.: 542075 EXHIBIT _}) EFTA01076816 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 EFTA01076817 PLAINTIFF'S ANSWERS TO FOURTH INTERROGATORIES 1. List the names, business addresses, telephone and cell phone numbers, dates of employment, immediate supervisor (name and address) and rates of pay regarding all employers, including self-employment, for whom you have worked since you answered the First Set of Interrogatories propounded by Defendant on or about December 10, 2008; this includes listing any and all sources of income you have received. ANSWER: MOM West Palm Beach, FL 2009 ut FL 2009 oconut FL 2009 West Palm Beach, FL 2010 - present 2. Identify' each physician or medical provider (including mental health professionals, drug or alcohol counselors and therapists) with whom you have consulted or who has treated or examined you, and identify each facility (including drug or alcohol treatment facilities, whether inpatient or outpatient) where you have received any consultation, examination or treatment that is in any way related to this case; and state as to each the date of consultation, examination or treatment and the injury, condition or other reason for which you were examined or treated since you answered the First Set of Interrogatories propounded by Defendant on or about December 10, 2008. ANSWER: Victim's Services West Palm Beach, FL Dates reflected in records previously produced. EFTA01076818 Fort Lauderdale, FL 33304 Dates reflected in records. Interrogatories 3-12 ANSWERS: Objection, beyond the limit of Interrogatories allowed pursuant to FRCP 1.340. EFTA01076819 VERIFICATION STATE OF FLORIDA ) ) ss COUNTY OF-PAL-f it. ) brOWCied ,, `t - SWORN TO AND U SCRIBED before me this "3...) day of Hagar) 2010 by l cy COLLY:ffie\ Wl , who is personaWnown to me or has produced the following identr 'cation 14tW460-105-137-`6131thich is current or has been issued within the past five years and bears a serial or other identifying number. !1VP4SIO C auckaL E Nipre-ao 2i i gnature NOTARY PUBLIC - STATE OF FLORIDA Commission Number: My commission expires: (Notarial Seal) IOWA MEMO MY COMMISSION MEOW WIRES. SEP 14, 2012 Boxed %ugh 1st Ws rams EFTA01076820 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051XXXXMB AB Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. CASE NO. 502008CA028058XXXXMB AB Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. HEARING BEFORE THE HONORABLE DONALD HAFELE Thursday, July 16 2009 8:13 - 9:10 Palm'Beach County Courthouse West Palm Beach, Florida Reported By: Pamela J. Sullivan, RPR, FPR Notary Public, State of Florida Prose Court Reporting Agency, Inc. EXHIBIT C, PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan (S01433-772-1662) e61ae66d-066.4919.64de-67e22ed466ba EFTA01076821 Page 34 2. for this whatsoever, for this type of invasive 2 discovery, where you get all access to — whether 3 it's voluntarily turned over or you get to go in 4 and actually remove It from the hard drive of a 5 computer — the sociahnetwaking site they chose 6 to remain private. 7 THE COURT: Well, mold it have to be removed 8 from the social aawadc, or could It be just 9 printed from the network? 10 MR. EDWARDS: 1 daft know bow the network 11 works and whether you can print every single page 12 and what that actually does. 13 THE COURT: Well, let's find out. I mean, 14 you inow,l would have preferred Mr. Crinon's 15 amended motion to have been supplemented by an 16 affidavit of a computer expert, to give the Court • 17 information as to how this type of 18 social-networking information would be extracted in 19 the least intrusive means to either plaintiff 20 But without that, len in the same --I'm in 21 the dark myself, because I'm not a computer expert 22 by any means. 23 MR. EDWARDS: And, Brim just along those 24 lines, talking about the Menke case, that was 25 specifically a case dealing with sexually explicit 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 36 And, again, I'm trying my best to balance the Interests between the individual's privacy rights and a defendant's right to discover what could lead to discovery of admissible evidence, when it deals with damages. So my ruling is as follows: I am going to allow first, es dictated by Menke, the voluntary — not voluntary — but the turning over of the social-network site iefeenation that is accessible to the site owner or user, =aping the plaintiff, or plaintiffs in this case, either of them or both of them, if they have these types of networking sites, inclusive of what would be shared with others, If those individuals allow others to became what is commonly known as friends. That will be discoverable. It will be placed under seal and for attorneys' eyes only at this time, pending further Court order. MR. EDWARDS: Your Honor. THE COURT: Well move on now to e-mails sent and received by plaintiffs. MR. CARTON: From a time standpoint, within 20 days? THE COURT: Within 20 days. MR. EDWARDS: And, Your Honor, my only Page 35 1 email sent from his computer. And that was the 2 computer of the perpetrator. What we're actually 3 contemplating now is turning over all of this 4 information, that they chose to keep private 5 amongst their own friends, of the victims of sexual 6 abuse to a registered sex offender. 7 THE COURT: Well — 8 MR. EDWARDS: And there is not one single 9 thing they pointed to that is evidence that I 10 about — in fkct, 'daft even know if they have a 11 computer. 12 THE COURT: I wouldn't be doing this, but for 13 the fact or wouldn't even be contemplating doing 14 this, but for the fact that you have to remember a 15 very, very important point here, respectfully, and 16 that is your clients have brought a lawsuit against 17 the defendant. And by doing that, there is a 18 attain degree of discovery that must be undertaken 19 for the defendant to defend Manse'f against the 20 claims that have been made based on the allegations 21 of loss of enjoyment of five, mental anguish, 22 damages that extend from a psychological standpoint 23 from an alleged sexual battery. All of these 24 things are necessary, in my view, to be able to 25 adequately defend those Page 37 1 objection to that is the Fifth Amendment privilege 2 that would pertain to my clients and the 3 information on there, as well as all of the other 4 people who communicate on there and their privacy 5 interest, as well, in addition to the fact that the 6 Menke case says, in quotes, in the few cases we 7 have found across the country permitting access, 8 all have — all have been in situations where 9 evidence of intentional deletion of data was 10 present. And that's not present here. 11 All of the arguments about damages claimed 3.2 and a right for a defendant to defend himself could 13 be made in every, single personal injury case that 14 we— that's ever existed. 15 THE COURT: Fee already made my ruling, but 16 I — 17 MR. EDWARD& I understand. 18 THE COURT: — as I said, I'm juxtaposing the 19 language contained on the last page of the slip 20 opinion, that intrusive searching of the entire 21 computer by opposing parties should not be the 22 rust means of obtaining the relevant information. 23 And then with the last sentence: "That we do 24 not deny the Board the tight to request that the 25 petitioner produce relevant, nonprivileged PROSE COURT REPORTING AGENCY, INC. 10 (Pages 34 to 37) Electronically signed by Pamela Sullivan(501433-772,4562) 0510.55d-oeta-4919-84de-ere22ed456ba EFTA01076822 ; • i IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028058XXXXMB AB Plaintiff, JEFFREY EPSTEIN Defendant. ORDER ON EPSTEIN'S MOTION TO COMPEL COMPLIANCE WITH COURT ORDER AND FOR AWARD OF ATTORNEY'S FEES AND COSTS THIS CAUSE came before the Court on Epstein's Motion To Compel Compliance ota,s, With Court Order And t or Award Of Attorney's Fees And Cd§ts, and the Court having heard argument of counsel and being fully advised in these premises, it is hereby ORDERED and ADJUDGED that Defendants Motion is hereby grantedAlthiedt an (aws , IT Ala , jos& ..AQ-4-pohat 4)- 4.24.2... 61,-. 44.4.61/44.4a Loseoi,.egte.4.41zr 41/2#1 a A et-ne -- -Ca7 a-1 )(o -non can sat-tvavealif"-rj aAA DONE AND ORDERED at Palm Beach Cou y C urthouse, West Palm Beach, r aid, Florida, this id) day of lit,, 2009. Copies furnished: ROBERT D. CRITTON, JR., ESQ., and MICHAEL J. PIKE, ESQ., 515 North Flagler Drive, Suite 400, West Palm Beach, FL 33401 and BRAD EDWARDS, ESQ., Brad Edwards and Associates, LLC. 8 Harrison Street, Suite 202, Hollywood, FL 33020, JAY HOWELL, ESQ., Jay Howell & Associates, ., 644 Cesery Boulevar uite 250, Jacksonville, FL 32211, and JACK A. GOLDBERGER, ESQ., e ury Goldberger & Weiss, IS, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012 EXHIBIT I) EFTA01076823