IN THE COURT OF THE FIFTEENTH

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 recently served a Fifth Set of Interrogatories accompanying a Request for Admissions (attached as Composite Exhibit E), to which II objected as beyond the limit of Interrogatories allowed pursuant to FRCP 1.340. The Request for Admissions and Interrogatories seek information related to CME with Epstein's expert, Dr. ■. This information is certainly discoverable as III answered the Request for Admissions without objection. The Interrogatories seek explanations for responses to the Request for Admissions. 10. ■ would not be prejudiced by Epstein serving additional interrogatories. 11. 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 leave to serve an additional thirty (30) interrogatories and grant any additional relief the Court deems just and proper. 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: 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 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 424 N. Andrews Avenue, Suite 2 le, FL 33301 Counsel for Plaintiff Jay Howell, Esq. Jay Howell & Associates,'B. 644 Cesery Boulevard Suite 250 MEL 32211 Phone Fax Co-counsel for Plaintiff 4 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss,111. 250 Australian Avenue South Suite 1400 Wes FL 33401-5012 Fax: Co-Counsel for Defendant Epstein EFTA01076845 Counsel for Plaintiff 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. Farmer, Jaffe, Weissing, Edwards, & Lehrman, PL 425 N. Andrews Avenue, Suite 2 uderdale, FL 33301 Jay Howell, Esq. Jay Howell & Associates, 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 Jack Alan Goldberger, Esq. Fistos Atterbury Goldberger & Weiss, M. 250 Australian Avenue South Suite 1400 West Pam Beach FL 33401-5012 Fax: Co-Counse or Defendant Jeffrey Epstein 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, 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 3 EFTA01076848 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 furls 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: 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 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." 6 EFTA01076851 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 w or 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 usernames, 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 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 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: 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. 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: Fort Lauderdale, FL 33304 Interrogatories 3-12 ANSWERS: Objection, beyond the limit of Interrogatories allowed pursuant to FRCP 1.340. EFTA01076859 • IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051XXXXMB AB L.M. , Plaintiff, -vs - JEFFREY EPSTEIN, Defendant. CASE NO. 502008CA028058XXXXMB AB E.W., Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. HEARING BEFORE THE HONORABLE DONALD HAFELE ThursdEa July 16 2009 8:13 III - 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 (561) 832-7500 PROSE COURT REPORTING AGENCY, mocimnitaityWgnedbyPernelaSultbrot(501-331-radm) INC. (561) 832-7506 eSlae55d-c6fa-4919-84de-87e224(1466ba EFTA01076860 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 34 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 social-networking site they chose 6 to remain private. 7 TliE COURT: Well, would it have to be removed from the social activate, or could it be just 9 primed from the netwoda 10 MR. EDWARDS: I closet 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 know, I would have preferred Mr. Clifton'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, I'm 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, Judge, just along those 24 lines, talking about the Mae case, that was 25 specifically a case dealing with sexually explicit Page 36 I. And, again, I'm trying my best to balance the 2 interests between the individual's privacy rights 3 and a defendant's right to discover what could lead 4 to ditcovery of admissible evidence, when it deals 5 with damages. 6 So my ruling is as follows: Tarn going to allow first, as dictated by Menke, the voluntary - 8 not voluntary but the turning over of the 9 social-network site information that is accessible 10 to the site owner or user, meaning the plaintiff, 11 or plaintiffs in this case, either of them or both 12 of them, if they have these types of networking 13 sites, inclusive of what would be dared with 14 others, if those individuals allow others to become 15 what is commonly knovm as fiends. That will be 16 discoverable. It will be placed under seal and for 17 attorneys' eyes only at this time, pending further 18 Coun order. 19 MR. EDWARDS: Your Honor. 20 THE COURT: We'll move on now to e-mails sent 21 and received byplaintiffs. 22 MR. CRUTCH: From a time standpoint, within 23 20 days? 24 71W COURT: Within 20 days. 25 MR. EDWARDS: And, Your Honor, my only Page 35 3. e-maik 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 Mends, of the victims of sexual 6 abuse to a registered sex offender. 7 THE COURT: Well — 8 MEL I3DWARDS: And there is not one single thing they pointed to that is evidence that I know about — in fact, I don't even know if they ltave a computer. THE ODTJRT: Iwouldn't be doing this, but for the fact — or wouldn't even be contemplating doing this, but for the fact that you have to remember a very, very important point here, respectfully, and that lsyour clients have brought a lawsuit against the defendant. And by doing that, there is a certain degree of discovery that must be undertaken for the defendant to defend himself against the claims that have been made based on the allegations of loss of enjoyment of live, mental anguish, damages that extend from a psychological standpoint from an alleged sexual battery. All of tbese things are necessary, in my view, to be able to . adequately defend those claims. 10 11 12 13 14 15 16 17 18 19 20 23. 22 23 24 25 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 commutate on there and their privacy 5 interest, as well, in addition to the fact that the 6 Mae 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 present. And that's not present here. All of the arguments about damages claimed and a right for a defendant to defend himself could be made in every, single personal injury case that we — thafs ever existed. THE COURT: I've already trade my ruling, but I — MR EDWARDS! I understand. THE COURT: — as I said, I'm juxtaposing the language contained on the last page of the slip opinion, that intrusive searching of the entire computer by opposing parties should not be the first means of obtaining the relevant information. And then with the last sentence: "That we do not deny the Board the right to request that the 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•eatad918.84de-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. 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 ticArst 9una. aea r 221/1 With Court Ordernd For Award Of Attorney's Fees And Costs, and the Court having heard argument of counsel and being fully advised in these premises, it is hereby ORDERED and ADJUDGED that Defendant's Motion is hereby granted/' LS -Cittseit.e siAtat A.424-ennot- -Cn. 4e- -CamCr=")71--. at 10 ati+ _kyr - .1••••snaaajar wry - - 4&, ce...tre .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: 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. Harrison Street, Suite 202, Hollywood, FL 33020, JAY HOWELL, ESQ., Jay Howell & Associates, 644 Cesery Boulevartaauite 250, Jacksonville, FL 32211, and JACK A. GOLDBERGER, ESQ., Atterbury Goldberger & Weiss, M., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012 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 ounsel for Plaintiff . 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. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 424 N. Andrews Avenue, Suite 2 le, FL 33301 Jay Howell, Esq. Jay Howell & Associates, 644 Cesery Boulevard Suite 250 32211 Phone Fax Co-counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss,'" 250 Australian Avenue South Suite 1400 Wes FL 33401-5012 Fax: Co-Counsel for Defendant Jeffrey Epstein 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. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Counsel for Plaintiff Jay Howell, Esq. Jay Howell & Associates, 644 Gesell,' Boulevard Suite 250 32211 Phone Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, a 250 Australian Avenue South Suite 1400 Wes L 33401-5012 Fax: Co-Counsel for Defendant Jeffrey Epstein EFTA01076865 Fax Co-counse or Plaintiff BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West Palm B h, FL 33401 By: ax 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 February 15, 2010 ("CME") was completelaye and accurate and describe any false or inaccurate statements given to Dr. M. 2. If your response to Request for Admissions No. 2 was anything other than an admis , please describe the facts or events you omitted from the history given to Dr. M. 3. If your response to Request for Admissions No. 3 was anything other than an admission, pleassil vhy you did not admit that the background information you gave to Dr. at your CME was completelaue and accurate and describe any false or inaccurate statements given to Dr. M. All of the Interrogatories relate to the Request for Admissions served by Defendant on March 12th, 2010. 3 EFTA01076867 4. If your response to Request for Admissions No. 4was anything other than an admission, please expl hat facts or events you omitted from the background information given to Dr. 5. If your response to Request for Admissions No. 5 was anything other than an ad on, please explain why you do not believe the questions asked of you by Dr. M at your CME were not fair or 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 EFTA01076868 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: (Notarial Seal) 5 EFTA01076869