EFTA00189979Set 9
9p2,135w
into a downward
spiral.
COUNT I
Sexual Assault and Battery against Defendant Epstein
19. Plaintiff B.B. repeats and realleges paragraphs 1 through 18 above.
20. This is a count ... suffer severe and permanent traumatic injuries, including mental, psychological
and emotional damages.
WHEREFORE, Plaintiff, B.B., demands judgment against Defendant, Jeffrey Epstein, for
compensatory damages, costs, attorney's fees, and such ... damages pursuant to Florida Law.
COUNT II
Civil Conspiracy against Defendants Epstein an=
25. Plaintiff B.B. repeats and reallege paragraphs 1 through 18 above.
26. This is a count
https://www.justice.gov/epstein/files/DataSet%209/EFTA00189979.pdf
EFTA01076368Set 9
15p3,397w
them into refusing to act as witnesses in any judicial proceedings against him.
30. Plaintiff, B.B., among many other young women, has been injured in the scope that
the criminal ... life into a downward
spiral.
COUNT I
Sexual Battery against Defendant Epstein
37. Plaintiff B.B. repeats and re-alleges paragraphs 1 through 36 above.
38. This is a count ... Epstein exploited his natural authority and trust as an adult with a
minor.
41. Plaintiff B.B., because of her age at the time of this incident, did not have
https://www.justice.gov/epstein/files/DataSet%209/EFTA01076368.pdf
EFTA00599160Set 9
2010-01-0817p3,349w
Palm Beach, FL 33401
Fax: 561 697 2383 Fax: 561 835 8691
Counsel for Plaintiff B.B. Co-counsel for Defendant Jeffrey
Epstein
BURMAN, CRITTON, LUTTIER
& COLEMAN, LLP
515 N. Flagler ... MOTION FOR LEAVE TO AMEND
TO ADD A CLAIM UNDER RICO AND PUNITIVE DAMAGES
Plaintiff, B.B., by and through undersigned counsel, and files this Motion for Leave to
Procedure
Amend ... Deposition of Palm Beach Police Chief Reiter (Ex. D);
d. Interrogatory responses of Plaintiff, B.B. (Ex. E);
13. Plaintiffs claim for Punitive Damages is further supported because Defendant
invoked
https://www.justice.gov/epstein/files/DataSet%209/EFTA00599160.pdf
NOTICE OF FILING
JEFFREY EPSTEIN
of Filing a
und ersigned counsel, hereby gives Notice
Plaintiff, B.B., by and through her
ant, JEFFREY EPSTEIN.
Proposal for Settlement to Defend ... Defendant.
FROM B.B.
PROPOSAL FOR SETTLEMENT
wing Proposal
undersigned attorneys, serves the follo
The Plaintiff, B.B., by and through her
JEFFREY EPSTEIN, and states:
for Settlement upon the Defendant ... purp
h
.IEFFItEY EPSTEI N resulting from an incident whic
action between the Plaintiff, B.B., and
Y EPSTEIN.
occurred between B.B. and JEFFRE
EIGHTY
for Settlement is THREE I IUNDRED
https://www.justice.gov/epstein/files/DataSet%209/EFTA00604998.pdf
EFTA00731015Set 9
2010-02-0427p10,511w
COMPEL PROPER RESPONSES TO PLAINTIFF'S SUPPLEMENTAL
REQUESTS FOR ADMISSION DATED FEBRUARY 4, 2010
Plaintiff, B.B., by and through undersigned counsel, hereby files this Motion to Compel
Defendant, JEFFREY EPSTEIN ... through the undersigned
ssions, dated February 4, 2010,
F.R.C.P. 1.350, hereby responds to Plaintiff, B.B.'s Request for Admi
as follows:
Plaintiff.
1. Admit that Jeffrey Epstein had a motive
https://www.justice.gov/epstein/files/DataSet%209/EFTA00731015.pdf
EFTA01126028Set 9
2010-02-0428p10,848w
COMPEL PROPER RESPONSES TO PLAINTIFF'S SUPPLEMENTAL
REQUESTS FOR ADMISSION DATED FEBRUARY 4, 2010
Plaintiff, B.B., by and through undersigned counsel, hereby files this Motion to Compel
Defendant, JEFFREY EPSTEIN ... through the undersigned
ssions, dated February 4, 2010,
F.R.C.P. 1.350, hereby responds to Plaintiff, B.B.'s Request for Admi
as follows:
Plaintiff.
1. Admit that Jeffrey Epstein had a motive
https://www.justice.gov/epstein/files/DataSet%209/EFTA01126028.pdf
EFTA00724170Set 9
2010-04-1310p2,005w
because it had been voluntarily dismissed
without prejudice by Plaintiff. The remaining counts of Plaintiff B.B.'s Second Amended
Complaint attempt to allege claims for Count I — 'Sexual Battery against ... through his
undersigned attorneys, files his amended answer and affirmative defenses to Plaintiff
B.B.'s Amended Complaint, and further, moves to strike specified allegations therein.
Rule 1.140, Fla.R.Civ ... infliction of
emotional distress in Count II. Only those factual allegations specific to the Plaintiff B.B.
should remain. According to the complaint allegations, B.B. had one encounter with
EPSTEIN
https://www.justice.gov/epstein/files/DataSet%209/EFTA00724170.pdf
JEFFREY EPSTEIN,
Defendant.
PLAINTIFF'S FIRST SET OF INTERROGATORIES PROPOUNDED ON
DEFENDANT. JEFFREY EPSTEIN
Plaintiff, B.B. pursuant to Fla. R. Civ. P. 1.340, Florida Rules of Civil Procedure,
requests
https://www.justice.gov/epstein/files/DataSet%209/EFTA00723778.pdf
EFTA00598950Set 9
2010-02-057p971w
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 ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598950.pdf
EFTA00724136Set 9
5p1,019w
PLAINTIFF
Defendant, Jeffrey Epstein (hereinafter "Mr. Epstein"), by and through his
undersigned attorneys requests Plaintiff, B.B., pursuant to Rule 1.350, Florida Rules of
Civil Procedure, produce the following within thirty
https://www.justice.gov/epstein/files/DataSet%209/EFTA00724136.pdf
EFTA00724315Set 9
2010-06-234p558w
B.B.,
CASE NO. 502008CA037319XXXXMB AB
Plaintiff,
v.
and
Defendants.
STIPULATION OF DISMISSAL WITH PREJUDICE
Plaintiff, B.B., and Defendant, JEFFREY EPSTEIN, (collectively, Parties"), by
and through their undersigned counsel and pursuant
https://www.justice.gov/epstein/files/DataSet%209/EFTA00724315.pdf
EFTA00605559Set 9
2010-02-041p180w
COMPEL PROPER RESPONSES TO PLAINTIFF'S SUPPLEMENTAL
REQUESTS FOR ADMISSION DATED FEBRUARY 4, 2010
Plaintiff, B.B., by and through undersigned counsel, hereby files this Motion to Compel
Defendant, JEFFREY EPSTEIN
https://www.justice.gov/epstein/files/DataSet%209/EFTA00605559.pdf
EFTA00723784Set 9
2010-01-267p4,467w
will suggest a couple of things,
2 On behalf of the Plaintiff, B.B.:
3 SPENCER T. KUVIN, ESQUIRE 2 number one, the press, both print and
3 audio-visual have
https://www.justice.gov/epstein/files/DataSet%209/EFTA00723784.pdf
EFTA00723061Set 9
2009-08-184p955w
objects to the
August 18, 2009 Notices of Production from Non-Parties served by Plaintiff, B.B. ("BB"),
and states:
1. On August 18, 2009, BB served Notices of Production from
https://www.justice.gov/epstein/files/DataSet%209/EFTA00723061.pdf
EFTA00586446Set 9
2009-09-023p673w
deposition, which was taken by
Spencer Kuvin, Esq.
2. Spencer Kuvin, counsel for Plaintiff, B.B., took my deposition, which began at
approximately 10:00 a.m.
3. Directly after asking
https://www.justice.gov/epstein/files/DataSet%209/EFTA00586446.pdf
EFTA01105354Set 9
2009-09-177p1,571w
Spencer Kuvin, Esq.
., took my deposition, which began at
2. Spencer Kuvin, counsel for Plaintiff, B.B
approximately 10:00 a.m.
Kuvin asked, Ills it true, sir, that you
3. Directly
https://www.justice.gov/epstein/files/DataSet%209/EFTA01105354.pdf