EFTA00723066

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA B.B Case No: 502008CA037319XXXXMB AB Plaintiff vs. JEFFREY EPSTEIN Defendant PLAINTIFF'S RE-NOTICE OF HEARING YOU ARE HEREBY NOTIFIED that Plaintiff shall call up for hearing the following: DATE: September 15, 2009 TIME: 8:45 AM JUDGE: The Honorable Donald Hafele —Courtroom 11B ADDRESS: Palm Beach Circuit Court MATTER: PLAINTIFFS REQUEST FOR ENTRY UPON LAND I hereby certify that a good faith effort has been made to resolve the issues herein, or same shall be made prior to the hearing. I HEREBY CERTIFY that a true and coma copy of the foregoing was served by U.S. Mail this da of Se. ber 2009 to: Jack A. Goldberger, Esq., Bruce E. Reinhart, Esq., Rilt D. Critton, Jr., Michael J. Pike, LEOPOLD-KUV1N P.A. By: SPEN IN Florida Bar No: 089737 LEOPOLD-KUVIN, P.A. =IM „IER• EFTA00723066 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-80380, 98-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 REQUEST FOR COPIES TO PLAINTIFF. JANE DOE COMES NOW the Plaintiff, by and through the undersigned attorneys, hereby requests that Plaintiff, JANE DOE, produce to her by mailing to Jack P. Hill, Esquire, , immediately upon receipt, any and all records received pursuant to their Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action, directed to the following Medical Record Custodian: Leonard A. Baird, Ph.D. EFTA00723067 Jane Doe. vs. Epstein, et al. Case No. 08-CV-80119-CIV-MARRNJOHNSON Request for Copies 2 I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to all Counsel on the attached list, this - " rtp day of September, 2009. Jack Scarola Florida Bar No.: 169440 Jack P. Hill Florida Bar No.: 0547808 Scarola Barnhart & Shipley, P.A. Phone: Fax: Attorneys for Plaintiff, C.M.A. EFTA00723068 Jane Doe. vs. Epstein, et al. Case No. 08-CV-80119-CIV-MARRNJOHNSON Request for Copies 3 COUNSEL LIST Richard H. Willits, Esquire Richard H. Willits. P.A Phone: Fax: Robert Critton, Esquire Michael J. Pike, Esquire Burman Critton Luttier & Coleman LLP Jack A. Goldberger, Esquire Atterbu Goldber er & Weiss, P.A. Phone: ax: Bruce E. Reinhart, Esquire Bruce E. Reinhart P.A. Phone: Fax: Stuart S. Mermelstein, Esquire Adam D. Horowitz, Esquire Horowitz. P.A. EFTA00723069 Jane Doe. vs. Epstein, et al. Case No. 08-CV-80119-CIV-MARRA/JOHNSON Request for Copies 4 Brad Edwards, Esquire Phone: Paul G. Cassell, Esquire Robert C. Josefsberg, Esquire Katherine W. Ezell, Esquire EFTA00723070 AO SSA (Rev. 01)09) Subpoena to Testify at a Deposition or to Produce Dccianents in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of Florida Jane Doe. Plaintiff v. Civil Action No. 08-CIV-MARRNJOHNSON Jeffrey Epstein (If the action is pending in another district, state where: Defendant SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To: Medical Records Custodian, Leonard A. Baird, Ph.D., • . . . trendy:6v: YOU ARE COMMANDED to appear at the time, dite, and place set forth below to testify at a deposition to be taken in this civil action. If you are en organization that is not a party in this case, you must designate one air more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or those set forth'in an attachment Naze: MO otters. Date and Time: 09/22/2009 9:00 am The deposition win be recorded by this method: Of Production: You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and penult their inspection, copying, testing, or sampling of the material: 'The entire medical records of Jeffrey Epstein (DOB 1/20/53) Including al psychological tests, charts, test results, xrays, MRis, scans, Intake Forms, opinions, diagnosis, letters to or from Jeffrey Epstein or any third party or parties, prescriptions, etc. In short, the entire file. The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, aro attached. Date: i iire 6 sPi 2-007 CLERK OF COURT • OR Signature eIClerk or Deputy Clerk Attorney's signature The name, address, e-mail, and telephone number of the attorney representing (name ofparty) , who issues or requests this subpoena, are: Brad Edwards E . Rothstein Rosenfeld) Adler EFTA00723071 AU b$A (Rev. DINS) Subpoena to Testify at a Deposal on cc to Product Documents in a Civil Aaron (Page 2) Civil Action No. 08-CIV-MARRNJOHNSON PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) This subpoena for (name ofindividual and title, Ifany) was received by me on (dale) Cl I personally served the subpoena on the individual at (place) on (date) ;:or Cl I the, subpoena at the individual's residence or usual place ofabode with (name) , a person of suitable age and discretion who resides there, on (dale) , and mailed a copy to the individual's last known address; or Cl I served the subpoena on (name ofindividual) , who is designated by law to accept service of process on behilf of (name oforganisation) on (dale) ; or Cl I returned the subpoena uneaccutcd because ; or Cl Other (Teci)y): Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of My fees are S for travel and S for services, fora total of S 0.00 I declare under penalty of perjury that this information is true. Date: Server's signature Printed Arne and ride Server's address Additional information regarding attempted service, etc: EFTA00723072 AD SSA (Rev. 01/09) Subpoena lo Testify at a Deposition or to Produce Documents in a Civil Action (Page 3) Federal Rule of Civil Procedure 45 (c), (d), and (e) (Effective 12/1/07) (c) Protecting a Person Subject to a Subpoena. (d) Duties in Responding to a Subpoena. (1) Avoiding Undue Burden or Repents; Sanctions. A party or (1) traducing Documents or Electronically Stored Information. attorney responsible for issuing and serving a subpoena must take These procedures apply to producing documents or electronically reasonable steps to avoid imposing undue burden or expense on a stored information: person subject to the subpoena The issuing cant must enforce this (A)Docrunears. A person responding to a subpoena to produce duty and impose an appropriate sanction — which may include lost documents must produce them as they are kept in the ordinary earnings and reasonable attorney's fees — on a party or attorney course of business or must organize and label them to correspond to who bits to comply. the categories in the demand: (2) Command to Produce Materials or Permit Inspection. (B) Pornfor Producing Elecitookalty Stored Information Not :(A) Appearance Not Required. A person commanded to produce Specified. Ira subpoena does not specify a form for producing documents, electronically stored information, or tangible things, or electronically stored information, the person responding must to permit the inspection of premises, need not appear in person at the produce it in a form or thrms in which it is ordinarily maintained or plait ofproduction or inspection unless also commanded to appear in a reasonably usable form or forme for a deposition, hearing, or trial. (C)Electronkally Stored Information Produced in Only One (B) Objections. A person commanded to produce documents or Font The person responding need not produce the same tangible things or to permit inspection may serve on the party or electronically stored information in more than one form. attorney designated in the subpoena a written objection to • (D)Inaccessible Electronically Stored Information. The person inspecting, copying, testing or sampling any or all of the materials or responding need not provide discovery of electronically doted to inspecting the premises —a to producing electronically stored information from sources that the person identifies as reasonably information in the foam or forms requested. The objection must be accessible because of undue burden or cost. On motion to compel served before the earlier of the time specified for compliance or 14 discovery or for a protective order, the person responding must show' days after the subpoena is served. If an objection is made, the that she information is not reasonably accasibk because of undue following rules apply: burden or cost. If that showing is made, the omit may nonotheles•s (I) At anytime, oo notice to the commanded person, the saving order discovery from such sources if the requesting party shows. • patty may move the issuing court for an order compelling production good cause, considering the 1h:interims ofRule 26(b)(2XC). The or inspection. court may specify conditions for the discovery. (II) These acts may be required only as directed in the order, and (2) Claiming Privilege or Protection. the order mustprotect a person who is neither a party nonparty's (A)Informarion Withheki. A person widtholdingsubpoenaed officer from significant expense resulting from compliance. information under a claim that it Is privileged or subject to (3) Quashingor Modifying a Subpoena. protection as trial-preparation material must: (A) When Required. On timely motion, the issuing court must (I) expressly make the claim; and quash or modik/ a subpoena that' (it) describe the nature of the withheld documents, (1) fails to allow a reasonable time to comply; communications, or tangible things in a manna that;without (ii) requires a person who is neither a party nor a party's officer revealing information itselfprivileged or protected,: wiII enable the to travel more than 100 miles from where that person resides, is parties to assess the claim. employed, or regularly transacts business in person — except that, (B) information Produced. If information produced in response to a . subject to Rule 45(cX3)(B)(iift, the person may be commanded to subpoena is subject to a claim of privilege or of protection as Mal- attends trial by traveling from any such place within the state where preparation material, the person making the claini may notify any the trial is held; party that received the inframiation of the claim and the basis for it. (fit) requires disclosure of privileged or other protected matter, if ARer being notified, a party must promptly return, sequester, or no exception or waiver applies; or destroy the specified information and any copies it has; must not use (iv) subjects a person to undue burden. or disclose the information until the claim is resolved; must take (B) When Permitted. To protect a person subject to or affected by reasonable steps to retrieve the information if the party disclosed it a subpoena,be issuing court may, on motion, quash or modify the before being notified; and may promptly present the information to subpoena if it requires: the court under seal for a determination of the claim. The person (i) disclosing a trade secret or other confidential research, who produced the information must preserve the information until development, or commercial information; the claim is resolved. (11) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from (e) Contempt. The issuing corm may hold in contempt a person the expert's study that was not requested by a party; or who, having been saved, fails without adequate excuse to obey the (111) a person who is neither a party nor a party's officer to incur subpoena A nonparty's failure to obey must be excused if the substantial expense to travel more than 100 miles to attend trial. subpoena purports to require the nonparty to attend or produce at a (C) Specrfying Conditions as an Alternative. In the circumstances place outside the limits ofRule 45(cX3XAXii). described in Rule 45(c)(3)II), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party: () shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and Oft ensures that the subpoenaed person will be reasonably compensated. EFTA00723073 "A" SCHEDULE any R Is , s c a n s , Xrays and cluding M reports, m p le te m edical file in ta k e F o rm, notes, s, *The c o o sti c test result , In fr o m third partie other d ia g n o r ed al ic c o rr e s p o ndence to E p s te in , referrals, m opinions, Jeffrey e to or from le on: es p on d e n c corr lete fi , your comp bills, in short in Jeffrey Epste /20/53 : 1 Date of Birth ned counsel) ance to the undersig d in lieu of appear may be maile (*Documents EFTA00723074