Document DOJ-COURT-302 is a legal notice filed in the United States District Court for the Southern District of Florida concerning a motion for an independent medical examination of the plaintiff, Jane Doe, in a case against Jeffrey Epstein.
This document is a Defendant's Notice for an Independent Medical Examination (IME) of the plaintiff, Jane Doe, scheduled for October 13, 2009. Jeffrey Epstein, the defendant, is requesting the examination to be conducted by Dr. Ryan Hall. The document outlines the details of the examination, including the location at the law firm of Burman, Critton, Luttier and Coleman, LLP, the duration, and the fact that it will be videotaped. The document also clarifies the cost responsibilities and conditions under which the psychiatrist may be called as a witness.
Case 9:08-cv-80119-KAM Document 302 Entered on FLSD Docket 09/15/2009
Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. I --------------- Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 I --------------- DEFENDANT'S NOTICE OF INDEPENDENT MEDICAL EXAMINATION OF PLAINTIFF, JANE DOE (80893) Defendant, JEFFREY E. EPSTEIN, pursuant to Rule 35, Fed. R. Civ. P., notices the Plaintiff for an independent/psychological medical examination and states: 1. An appointment for examination of the Plaintiff has been made with Ryan Hall, M.D. of C.W. Hall, M.D., P.A. at 9:00 a.m. on October 13, 2009 at the law firm of Burman, Critton, Luttier and Coleman, LLP, located at 303 Banyan Boulevard, Ste. 400, West Palm Beach, FL, 33401. The Plaintiff is to wear comfortable clothing and bring a sweater. The examination shall consist of an interview and testing and will likely last until 5:30 p.m. See iefra and Motion attached at DE (301) for scope, time and place of IME. See Exhibits attached as well. Case 9:08-cv-80119-KAM Document 302 Entered on FLSD Docket 09/15/2009
Page 2 of 4 2. Plaintiff has not agreed to this date; however, unless a timely and valid objection to this Notice is made, the Plaintiff is required by this Rule to be in attendance at the above-scheduled examination. 3. Pursuant to Rule 35, if the psychiatrist performing the examination is called as a witness, the psychiatrist shall not be identified as one appointed by the Court. 4. The cost of the examination will be originally borne by the Defendant but is subject to taxation by the Court upon proper motion. 5. The interview will be videotaped. 6. Dr. Halls' specialties and qualifications are attached to the Motion to Compel the IME at DE (301). The time, place, manner, conditions and scope of the examination are attached to the Motion to Compel the IME at DE (301). to the Plaintiffs counsel and, therefore, sufficient no tic Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this /f day of September, 2009 By: R ::-:±_-:::-:;H-:=t:T:-:::0-:-N:-, J:-:::R:-.,--:E:-:::SQ. F 224162 r aw.com Case 9:08-cv-80119-KAM Document 302 Entered on FLSD Docket 09/15/2009
Page 3 of 4 MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561/842-2820 Phone 561/515-3148 Fax (Counsel for Defendant Jeffrey Epstein) Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 3 3160 305-931-2200 Fax: 305-931-0877 [email protected] [email protected] Counsel for Plaintiffs In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 [email protected] Jack Scarola, Esq. Jack P. Hill, Esq. Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone: 954-522-3456 Fax: 954-527-8663 [email protected] Counsel for Plaintiff in Related Case No. 08-80893 Paul G. Cassell, Esq. ProHac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F [email protected] Counsel for Plaintiff in Related Case No. Case 9:08-cv-80119-KAM Document 302 Entered on FLSD Docket 09/15/2009








