EFTA00726289.pdf

IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA L.M., CASE NO. 502006CA028051XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendant. EPSTEIN'S REQUEST FOR ADMISSIONS TO PLAINTIFF Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Rule 1.370, Florida Rules of Civil Procedure, requests that Plaintiff, L.M., respond to the following Request for Admissions: 1. Admit that the history you gave to Dr. Hall at your Compulsory Medical Examination on February 15, 2010 ("CME") was completely true and accurate. 2. Admit that you did not omit any facts from the history you gave to Dr. Hall at your CME. 3. Admit that the background information you gave to Dr. Hall at your CME was completely true and accurate. 4. Admit that you did not omit any facts from the background information you gave to Dr. Hall at your CME. 5. Admit that you believe the questions asked of you by Dr. Hall were fair and reasonable. 6. Admit that you believe the manner in which the CME was conducted with you was professional. EFTA00726289 L.M. v. Epstein Page 2 7. Admit that you believe you were treated respectfully and fairly by Dr. Hall at the CME. 8. Admit that you believe the testing procedures utilized at your CME were fair and reasonable. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true co of the foregoing was sent by fax and U.S. Mail to the following addressees on this ["ay of March, 2010: Brad Edwards, Esq. Jack Alan Goldberger. Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss, P.A. rdale, FL 33301 — fax Wes FL 33401-5012 Fax: Co-Counsel for Defendant Jeffrey Epstein Counsel for Plaintiff Jay Howell, Esq. i es, P.A. k nville FL 32211 Phone Fax Co-counsel for Plaintiff rill\ c ek C•LEMAN, LLP West Palm Reach By: Robert D. C Florida Bar Michael J. Pike Florida Bar (Counsel for Defendant Jeffrey Epstein) EFTA00726290 Counsel for Plaintiff Fort Lauderdale, FL 33301 IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA L.M., CASE NO. 502008CA028051XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendant. EPSTEIN'S NOTICE OF SERVING FIFTH SET OF INTERROGATORIES TO PLAINTIFF Defendant, Jeffrey Epstein, files this Notice of Serving Fifth Set of Interrogatories to Plaintiff L.M., pursuant to Rule 1.340, Florida Rules of Civil Procedure, and requests the Plaintiff to answer said interrogatories in writing within thirty (30) days from date of service hereof. Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by U.S. Mail to the following addressees on this Aay of March , 2010: Brad Edwards, Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss, P.A. Wes Im Beach FL 33401-5012 Fax: Co-Counsel for Defendant Jeffrey Epstein Jay Howell, Esq. 32211 Phone EFTA00726291 Fax Co-counsel for Plaintiff BURMAN, CRITTON, LUTTIER West Palm h, FL 33401 Fax By: Florida Bar — Michael J. Florida Bar (Counsel for Defendant Jeffrey Epstein) 2 EFTA00726292 FIFTH SET OF INTERROGATORIES 1. If your response to Request for Admissions No. 11 was anything other than an admission, please explain why you did not admit that the history you gave to Dr. Ryan Hall at your Compulsory Medical Examination on February 15, 2010 ("CME") was completely true and accurate and describe any false or inaccurate statements given to Dr. Hall. 2. If your response to Request for Admissions No. 2 was anything other than an admission, please describe the facts or events you omitted from the history given to Dr. Hall. 3. If your response to Request for Admissions No. 3 was anything other than an admission, please explain why you did not admit that the background information you gave to Dr. Ryan Hall at your CME was completely true and accurate and describe any false or inaccurate statements given to Dr. Hall. All of the interrogatories relate to the Request for Admissions served by Defendant on March 12th, 2010. 3 EFTA00726293 4. If your response to Request for Admissions No. 4was anything other than an admission, please explain what facts or events you omitted from the background information given to Dr. Hall. 5. If your response to Request for Admissions No. 5 was anything other than an admission, please explain why you do not believe the questions asked of you by Dr. Hall at your CME were not fair or reasonable. 6. If your response to Request for Admissions No. 6 was anything other than an admission, please explain why you believe the manner in which the CME was conducted was not processional. 4 EFTA00726294 7. If your response to Request for Admissions No. 7 was anything other than an admission, please explain why you believe you were not treated respectfully or fairly at your CME. 8. If your response to Request for Admissions No. 8 was anything other than an admission, please explain why you believe the testing procedures at your CME were not fair or reasonable. VERIFICATION By: STATE OF FLORIDA ) ) ss COUNTY OF PALM BEACH ) SWORN TO AND SUBSCRIBED before me this day of 2010 by who is personally known to me or has produced the following identification which is current or has been issued within the past five years and bears a serial or other identifying number. Print Name Signature NOTARY PUBLIC - STATE OF FLORIDA Commission Number: My commission expires: (Notarial Seal) 5 EFTA00726295