EFTA00723008.pdf

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No: 502008CA037319XX)O34B AB Plaintiff vs. JEFFREY EPSTEIN Defendant PLAINTIFF'S NOTICE OF HEARING YOU ARE HEREBY NOTIFIED that Plaintiff shall call up for hearing the following: DATE: August 20, 2009 TIME: 8:45 AM JUDGE: The Honorable Donald Hafele —Courtroom 11 B ADDRESS: Palm Beach Circuit Court 205 N. Dixie Highway West Palm Beach, FL 33401 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 correct copy of the foregoing was served by U.S. Mail this,[ day of August, 2009, to: Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Hagler Drive, Suite 400, West Palm Beach, FL 33401. LEOPOLD—KUV1N, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 (561) 515-1400 (561) 515-140 .1 ) By: SP Florida Bar No: 089737 LEOPOLIPICOVIN, P.A. 2925 PGA Boulevard, Suite 200, WA Beach Garcl,m9, FL 334)0 1561) 515-1400; (561) 515-1401 (facsimile) EFTA00723008 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO: 502008CA0373191OOOCMB AB PLAINTIFF'S REQUEST FOR ENTRY UPON LAND Comes now, Plaintiff, BB, by and through her undersigned counsel and pursuant to 1.350(aX3) Fla.R.Civ.P., and requests the following: 1. To enter Defendant Jeffrey Epstein's property located at 358 El Brillo Way, West Palm Beach, FL 33480. 2. Inspect the entire aropertv located at that location, including but not limited to the driveway, the interior of the house, each and every room in the house, the massage table, the backyard, the swimming area and all other areas located on said property. 3. To take video and/or photographs of the property and inspection. According to the Palm Beach County Property Appraiser, this property is approximately 14, 233, exclusive of the outside area, and thus it is anticipated that the inspection will take approximately 4 hours. In addition to the undersigned, the inspection will be attended by other lawyers, a videographer and members of the video team, a photographer and members of the photography team and other persons to assist in the process. These people attending the inspection are available for the inspection to take place on Friday, August 28, 2009, to begin at EFTA00723009 the property at 10:00 a.m. The undersigned will work with Defendant to agree on a mutually acceptable time and date above is not convenient for Defendant. WHEREFORE, the Plaintiff respectfully requests that this Court enter an Order granting it's Request for Entry Upon Land requiring the Defendant, Epstein, to schedule such entry on Friday, August 28, 2009, at 10:00 a.m., or in the alternative, no later than twenty days following entry of the Court's Order granting same. I HEREBY CERTIFY that a true and correct copy of the foregoing was served by U.S. Mail on this the / 3 day of August, 2009, to Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm Beach, FL 33401; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Flagler Drive, Suite 400, West Palm Beach, FL 33401. LEOPOLD--KUV1N, P.A. 2925 PGA Boulevard Suite 200 Palm Beac (561)515- (561)515- By: S CER T. KUVIN, Esq. Florida Bar No.: 089737 Page 2 of 2 EFTA00723010