EFTA00601977.pdf

09/16/2010 114:45 FAX 5616845816 SEARCY DENNEY litoolioto it2911874/mep IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), VS. SCOTT ROTHSTEIN, BRADLEY J. EDWARDS, individually, and individually, Defendant(s). NOTICE OF PROPOUNDING EXPERT INTERROGATORIES TO PLAINTIFF/COUNTERDEFEN'DANT, JEFFREY EPSTEIN Defendant/Counterplaintiff, Bradley J. Edwards, hereby gives notice that pursuant to 16 Rule 1.340(e), Florida Rules of Civil Procedure, Expert Interrogatories numbered 1 through haile been directed to PlaintifFCounterdefendant, Jeffrey Epstein, this UPI day of ISfAuther 2010. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Fax and U.S. Mail to all Counsel on the al this day of &cir:2___W 2010. ar No.: 169440 y Denney Scarola Barnhart & Shipley, P.A. 9 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 EFTA00601977 09/18/2010 14:46 FAX 5616845816 SEARCY DENNEY 0002/010 Edv/ards adv. Epstein Case No.: 502009CA040800)000CMEAG Expert Interrogatories To Jeffrey Epstein COUNSEL LIST Jack A. Goldberger, Esquire Attirbury, Goldberger & Weiss, P.A. 25 Australian Avenue South, Suite 1400 Wdst Palm Beach, FL 33401 rneys for Jeiirey Ga1y M. Farmer, Esq. Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fo I Lauderdale, FL 33301 Chrlistopher E. Knight, Esq. Joseph L. Ackerman, Esq. FoWler White Burnett, P.A. 777 S Flagler Drive, Suite 901 West Palm Beach, FL 33401 Attomeys for Jeffrey Epstein Marc S. Nurik, Esq. Law Offices of Marc S. Nurik On E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 8fileys IoI Jcott 1Co EFTA00601978 09/16/2010 14:48 FAX 5818845816 SEARCY DENNEY 143003/010 Echkards adv. Epstein Case No.: 502009CA0408003OOOCMBACI Fain Interrogatories To Jeffrey Epstein EXPERT INTERROGATORIES TO JEFREY EPSTEIN State the name, address and profession of each person whom you expect to call as an expert witness at trial or for any other purposes in this cause. 2. I With regard to each listed above, state his/her background, education and experience which qualify him/her to testify as an expert in his/her area of expertise; and/or in lieu thereof please provide a copy of each expert's most recent curriculum vitae. 3. Give the name or title of each paper which each expert has authored in the field of his/her expertise. EFTA00601979 08/16/2010 114:47 FAX 5616846816 SEARCY DENNEY 0004/010 Eth1rards adv. Epstein Case No.: 502009CA040800XXXXREIAG Expert Interrogatories To Jeffrey Epstein 4. State the name, volume and page number of the publication in which each article or paper listed above can be found. State the substance of the facts to which each expert listed is expected to testify. 6. I Give a complete list of all documents, depositions, exhibits, plans, drawings, ordinances or statutes which each expert has used in basing his/her opinion. EFTA00601980 09/16/2010 14:47 FAX 5816845816 SEARCY DENNEY 0005/010 Edwards adv. Epstein Case No.: 502009CA040800)OOOCKDAG Expert Interrogatories To Jeffrey Epstein 7. State the opinion to which the experts aforementioned are expected to testify. 8. i Give a summary of the grounds of each opinion stated. 9. Has the expert listed above practiced or worked in his/her field during the past five years? 10. If so, please state: a. Whether the expert was self-employed, employed by someone else or associated as a partner. b. Each address where the expert practiced or was employed. EFTA00601981 09/16/2010 14:47 FAX 5616845816 SEARCY DENNEY WO08/010 Echlards adv. Epstein Case No.: 502009CA040800)OOOCMBAG EA:ert Interrogatories To Jeffrey Epstein c. The dates the expert was with each employer. d. The type of duty the expert performed with each employer. 11.' If the expert has not practiced or worked in his/her field during the last five years, what was his/her employment during this time? 12. Did the expert submit a report setting forth his/her opinions or conclusions reached from his/her examination or any tests he/she conducted? a. If so, state the date the report was submitted. b. The name or other means of identification of the person to whom this report was submitted. c. The name and address of the person who has present custody of the report. EFTA00601982 09/16/2010 14:47 FAX 5616845816 SEARCY DENNEY !di007/010 adv. Epstein No.: 502009CA040800)OOOCMBAG Expert Interrogatories To Jeffrey Epstein 13.! Did the expert submit any other reports based upon tests, examinations or analyses of documents that he/she conducted in which he/she did not render an opinion? a. if so, state description of each report that was made. b. The date that each report was made. c. The name or other means of identification of the person to whom each report was submitted. d. The name and address of the person who has present custody of said report. EFTA00601983 09/16/2010 14:48 FAX 6616845816 SEARCY DENNEY goovolo Edwards adv. Epstein Case, No.: 502009CA040800,OOOO4BAG Exiieg Interrogatories To Jeffrey Epstein REQUEST TO PRODUCE EXPERT REPORTS 14 Attach a copy of any reports made by each expert on the basis of his/her tests, examinations or analyses to your answers to these Interrogatories. 15. Is the expert to be compensated for his/her work and efforts in connection with this action? a. If so, how much is the expert to be paid? b. If the expert has been paid, then give the basis for payment, such as hourly rate, weekly rate, etc. EFTA00601984 09/16/2010 14:48 FAX 5616845816 SEARCY DENNEY 0009/010 Edwards adv. Epstein Ca* No.: 502009CA040800XXXXMDAG ExPert Interrogatories To Jeffrey Epstein 16. Has the expert served as an expert witness in any other litigated case in the past three years? If so, state as to each case: a. The style of the case, the Court in which it was filed and the names and addresses of the attorneys involved. b. Whether the expert testified for the Plaintiff or Defendant. c. The area or field in which the expert held himself/herself out to be an expert. STATE OF COUNTY OF EFTA00601985 08/18/2010 14:48 FAX 5818845818 SEARCY DENNEY gp010/010 Edirds adv. Epstein Case No.: 502009CA040800)00C<MBAG Expert Interrogatories To Jeffrey Epstein The foregoing instrument was acknowledged before me this day of 20 , by , who is personally !mown to melor who has produced as identification and who did did/ not!take an oath. (SEAL) (Notary signature) (Notary name - print) NOTARY PUBLIC, State of Florida (Serial number, if any) EFTA00601986