EFTA00726180.pdf

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION L.M., ) ) Plaintiff, ) CASE NO.: 502008CA028051XXXXMB AD ) vs. ) ) JEFFREY EPSTEIN, ) ) Defendant. ) ) PLAINTIFF'S REQUEST FOR PRODUCTION TO DEFENDANT COMES NOW, the Plaintiff, L.M., by and through her undersigned counsel, and requests that Defendant, JEFFREY EPSTEIN, produce the original or best copy of the items listed herein below, at the offices of the Plaintiffs undersigned counsel, for inspection and /or copying pursuant to the applicable Florida Rules of Civil Procedure, as follows: 1. The ENTIRE FILE (including all discovery) provided to you by the State Attorney's Office, and/or Palm Beach County Police Department and/or U.S. Attorney's Office and/or the Federal Bureau of Investigation relating to the Defendant, JEFFREY EPSTEIN. 2. All evidence, documents, statements, information, dvds, cds and ALL other information provided to Defendant, Epstein, or his attorneys in discovery by the Palm Beach State Attorney's Office, the Palm Beach Police Department, The FBI or the U.S. Attorney's office. 3. The confidentiality agreement signed by Alfredo Rodriguez related to his employment with Jeffrey Epstein. I HEREBY CERTIFY that a copy of the foregoing was served by mail this/ ay of August, 2009 to: All those on the attached Service List. EFTA00726180 CASE NO.: 502008CA02805DOCC<MB AD ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33394 Telephone Telecopier By: Bradley J. Edwards Florida Bar N . 542 7 iam . erger Florida Bar No. 197701 2 EFTA00726181