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This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

EFTA01154302

2 pages
Page 1 / 2
IN THE CIRCUIT COURT FOR THE 
FIFTEENTH JUDICIAL CIRCUIT IN AND FOR 
PALM BEACH COUNTY, FLORIDA 
FILE NO. 502008CP003626XXXXMB 
E.W., 
Plaintiff, 
v. 
JEFFREY EPSTEIN, 
Defendant. 
PLAINTIFF'S REQUEST FOR ENTRY UPON LAND 
Comes Now Plaintiff, EW, by and through undersigned counsel and pursuant to 
1.350(a)(3) 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 property 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 14,223, 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 with the law firm of Rothstein Rosenfeldt Adler, 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 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. 
EFTA01154302
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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 copy of the foregoing was served by mail this 10th day of 
August, 2009 to: Robert D. Critton, Jr., Esq., Burman, Critton, et al., 515 North Flagler Drive, 
Suite 400, West Palm Beach, FL 33401. 
ROTHSTEIN ROSENFELDT ADLER 
Attorneys for Plaintiff 
401 East Las Olas Blvd., Suite 1650 
Fort Lauderdale, Florida 33394 
Telephone (954) 522-3456 
Telecopier (954) 527-8663 
By. 
Bradley J. Edwards 
Florida Bar No. 542075 
bedward 
rra-law. corn 
William J. Berger 
Florida Bar No. 197701 
wbergererra-law.com 
H:113rad Edwards1BJE CasesIMiller. Tatum (09-22783) Request for Entry Upon Land.doc 
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EFTA01154303