EFTA00723778.pdf

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA B.B, CASE NO: Plaintiff, 502008CA0373193OOOCNIB AB vs. 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 the Defendant, JEFFREY EPSTEIN, to answer under oath in writing within thirty (30) days from the date of service hereof the following: I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U. S. Mail, postage prepaid, this2-iday of January, 2010 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, 303 Banyon Boulevard, Suite 400, West Palm Beach, FL 33401. LE0P0LD-KUVIN, P.A. 2925 PGA Boulevard Suite 200 33410 T. KUVIN, Esq. Florida Bar No.: 089737 EFTA00723778 1. If your answer to Request for Admission #1 is anything other than an unqualified admission, please state in detail the factual basis for your denial. 2. If your answer to Request for Admission #2 is anything other than an unqualified admission, please state in detail the factual basis for your denial. 3, If your answer to Request for Admission #3 is anything other than an unqualified admission, please state in detail the factual basis for your denial. Page 2 of 4 EFTA00723779 4. If your answer to Request for Admission #4 is anything other than an unqualified admission, please state in detail the factual basis for your denial. 5. If your answer to Request for Admission #5 is anything other than an unqualified admission, please state in detail the factual basis for your denial. Page 3 of 4 EFTA00723780 By: JEFFREY EPSTEIN STATE OF )ss: COUNTY OF The foregoing instrument was acknowledged before me this day of , 2010, by , who is personally known to me or has produced as identification, and who did (did not) take an oath: (NOTARY SEAL) NOTARY PUBLIC My commission expires: Page 4 of 4 EFTA00723781 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA B.B, CASE NO: Plaintiff, 502008CA037319XXXXMB AB vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT, JEFFREY EPSTEIN Pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, Plaintiff, BB, requests that Defendant, JEFFREY EPSTEIN, admit the following within thirty (30) days of the date hereof: 1. Admit that B.B. suffered emotional trauma as a result of what occurred at Jeffrey Epstein's home. 2. Admit that Dr. Mary Littlefield's diagnosis of B.B. with having post traumatic stress disorder as a result of what occurred at Jeffrey Epstein's home is a correct diagnosis. 3. Admit from the date of incident at Jeffrey Epstein's home, B.B. has not faked or exaggerated her emotional trauma or symptoms on any occasion. 4. Admit that a 15 year old girl can suffer from emotional trauma as a result of sexual activity with an adult male over 50 years old. 5. Admit that B.B. is having difficulties with intimacy in her relationships with boys her age as a result of the incident that occurred with Jeffrey Epstein. I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U. S. Mail, postage prepaid, thin day of January, 2010 to Jack A. Goldberger, Esq., 250 Australian EFTA00723782 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, 303 Banyon Boulevard, Suite 400, West Palm Beach, FL 33401. LEOPOLD-KUVIN, P.A. 2925 PGA Boulevard Suite 200 Beach ns, FL 3 l0 KUVIN, Esq. Florida Bar No.: 089737 Page 2 of 2 EFTA00723783