To: Jeffrey EpsteinUeevacationagmail.comj From: drsra Sent Thur 1/20/2011 10:35:50 PM Subject Fw: Status FYI --- On Thu, 1/20/11, Leanne Seibert I MME. wrote: From: Leanne Seibert Subject: Status To: Date: Thursday, January 20, 2011, 1:21 PM Mr. Steele asked me to give you an update on the status. We have confirmed that Joe Fiore works for Ocean Bank, in their Ft. Lauderdale branch. Since he no longer works for plaintiff, we will need to serve him with the subpoena for deposition directly. Prior to taking his deposition, however, we want the rest of the documents from National City Bank. We are serving an additional request for production for all of the underwriting documents relating to the loan. Additionally, we have requested that they provide all of the checks and deposit records for the bank account based on our prior request. If necessary, we will file a motion to compel but we need to attempt to resolve the matter without a motion first. The judge signed the order of recusal. The hearing on the motion for summary judgment will most likely not go forward before a newly assigned judge. We arc waiting until we have received notice of the new judge to decide how best to proceed in that regard. We should have that information by early next week. Law Offices of W. TRENT STEELE Bankruptcy 8902 SE Bridge Rd. Foreclosure Defense Hobe Sound. FL 33455 Real Estate 772.408.6969 (O) Wills. Trusts. 8 Estates 772.781-8969 (F) Business Law Leanne Seibert EFTA_R1_00213198 EFTA01834269