EFTA00314177.pdf

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK GEORGE PETRIDES, Plaintiff, -against- Defendant. NOTICE TO TAKE DEPOSITION DOBRISH MICHAELS GROSS LLP Attorneys for Plaintiff New York, Ncw York 10017 Pursuant to 22 NYCRR B0-1.1, the undersigned. an attorney admitted ro practice in the courts of New York State, certifies that, upon information and belief and reasonable inquiry, the contentions contained in the annexed document are not frivolous. Dated: January 9, 2013 Allison Berea, Esq. Service of a copy of the within Dated.• is herein' admitted. Attorneys for EFTA00314177 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X GEORGE PETRIDES, Index No.: Plaintiff, NOTICE TO TAKE DEPOSITION -against - Defendant. X PLEASE TAKE NOTICE, that pursuant to N.Y. C.P.L.R. 3101(a)(4) and N.Y. C.P.L.R. 3107, the deposition upon oral examination of JEFFREY EPSTEIN of the Epstein Foundation, whose home address is 9 East 71st Street, New York, NY 10021, will be taken on the 29th day of January, 2013 at 2:00 p.m. of that day, at the office of the attorney for the Plaintiff, DOBRISH MICHAELS GROSS LLP at 757 Third Avenue, 15th Floor, New York; NY 10017. The circumstances or reasons such disclosure is sought or required arc as follows: Upon information and belief, the witness possesses information and documents, including prepared records and backup schedules that are material and necessary to the prosecution of this case not reasonably available from any of the other parties in this action. JEFFREY EPSTEIN is required to produce at the examination the following records and papers in his possession, custody, or control: EFTA00314178 1. All records concerning the employment of including but not limited to all contracts, correspondences, benefit records, compensation records and/or reimbursements records. Dated: New York, New York January 9, 2013 DOBRISH MICHAELS GROSS LLP TO: New York, NY 10016 2 By: Allison Berecz, Esq. Attorneys for Plaintiff 757 Third Avenue, 15th Floor New York, NY 10017 EFTA00314179