EFTA01099325.pdf

Discovery Request to Edwards and Response EFTA01099325  IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla.R.Civ.Pro. 1.201 tjase No: 502009CA040800XXXXMBAG Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, Individually, BRADLEY J. EDWARDS, Individually, and L.M., Individually Defendants/Counter-Plaintiffs. PLAINTIFF, JEFFREY EPSTEIN'S NOTICE OF PROPOUNDING FIRST SET OF EXPERT WITNESS INTERROGATORIS AND REQUEST TO PRODUCE EXPERT REPORTS TO DEFENDANT/COUNTER-PLAINTIFF. BRADLEY J. EDWARDS Plaintiff/Counter-Defendant, Jeffrey Epstein, by and through his undersigned counsel, and pursuant to the Florida Rules of Civil Procedure, files this his Notice of Propounding First Set of Expert Witness Interrogatories and Request to Produce Expert Reports directed to Defendant/Counter-Plaintiff, Bradley J. Edwards' numbered 1 through 13 and Request to Produce Expert Reports numbered 14-16 to respond to within the time prescribed by the Fla.R.Civ.Pro.. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true d correct copy of the foregoing has been duly e ated via ❑ Email, a /Facsimile, t ICJ S. Mail, ❑ Hand Delivery, ❑ Federal Express this V ay of November, 2010 to: Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 EFTA01099326  3pstein v. Rothstein, et al. 2 Case No. 50 2009 CA 040800,OOOCMBAG Epstein's NOS of Expert Int to Edwards and RTP Experts Reports Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 By: Jo L. Ackerm Jr. > 1.--' Fla. Bar No. 235954 FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach. Florida 33401 Telephone. Facsimile: Attorneys for Jeffrey Epstein, Plaintiff/ Counter-defendant EFTA01099327  Epstein v. Rothstein, et al. 3 Case No. 50 2009 CA 040800XXXXMBAG Epstein's NOS of Expert Int to Edwards and RTP Experts Reports EPSTEIN'S EDWARDS EXPERT INTERROGATORIES TO EDWARDS & RTP EXPERT REPORTS 1. 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. 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 lien 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. 4. State the name, volume and page number of the publication in which each article or paper listed above can be found. EFTA01099328  Epstein v. Rothstein, et al. 4 Case No. 50 2009 CA 040800XXXXMBAG Epstein's NOS of Expert Int to Edwards and RTP Experts Reports 5. State the substance of the facts to which each expert listed is expected to testify. 6. Give a complete list of all documents, depositions, exhibits, plans, drawings, ordinances or statutes which each expert has used in basing his/her opinion. 7. State the opinion to which the experts aforementioned are expected to testify. 8. Give a summary of the grounds of each opinion stated. EFTA01099329  Epstein v. Rothstein, et al. 5 Case No. 50 2009 CA 040800XXXXMBAG Epstein's NOS of Expert Int to Edwards and RTP Experts Reports 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. c. The dates the expert was with each employer. d. The type of duty the expert performed with each employer. II. If the expert was not practiced or worked in his/her field during the last five years, what was his/her employment during this time? EFTA01099330  Epstein v. Rothstein, et al. 6 Case No. 50 2009 CA 040800XXXXMBAG Epstein's NOS of Expert Int to Edwards and RTP Experts Reports 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. 13. Did the expert submit any other reports based upon tests, examinations or analysis 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. EFTA01099331  Epstein v. Rothstein, et al. 7 Case No. 50 2009 CA 040800XXXXMBAG Epstein's NOS of Expert Int to Edwards and RTP Experts Reports EPSTEIN'S REQUEST TO PRODUCE EXPERT REPORTS TO EDWARDS 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. 16. Has the expert served as an expert witness in any other litigated case in the past three years? 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. EFTA01099332  Epstein v. Rothstein, et al. 8 Case No. 50 2009 CA 040800XXXXMBAG Epstein's NOS of Expert Int to Edwards and RTP Experts Reports State of ) County of ) The foregoing instrument was acknowledged before me this day of 2010 by , who is personally to me or who has produced as identification and who did did/not take an oath. (SEAL) (Notary Signature) (Print Notary Name) Notary Public, State of (Serial Number, if any) EFTA01099333 Edwards' Response EFTA01099334 #291874/mep IN THE CIRCL COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). NOTICE OF SERVING ANSWERS TO FIRST SET OF EXPERT WITNESS INTERROGATORIES AND REQUEST TO PRODUCE EXPERT REPORTS COMES NOW the Defendant/Counterplaintiff, Bradley J. Edwards, by and through his undersigned counsel, and hereby files this Notice with the Court that Answers to the First Set of Expert Interrogatories propounded by the Plaintiff, Jeffrey Epstein, on November 4, 2010, have been furnished to the attorney for the Plaintiff. I HEREBY CERTIFY that a true copy of the foregoing has been furnished bY'slmail this 2nd day of December, 2010 to all counsel the atta ed list. JACK OLA Flori' r No.: 169440 Se enney Scarola Barnhart & Shipley, M. 2 alm Beach Lakes Boulevard est Palm Beach Florida 33409 Phone: Fax: Attorney for Bradley J. Edwards EFTA01099335 Edwards adv. Epstein Case No.: 502009CA040800}O00CMBAG Edwards• Answers to Expert Interrogatories COUNSEL LIST Jack A. Goldberger, Esquire Atterbuty, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: Fax: Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 Phone: Fax: Joseph L. Ackerman, Jr., Esquire Fowler White Burnett, P.A. 901 Phillips Point West 777 S Flagler Drive West Palm Beach, FL 33401-6170 Phone: Fax: Marc S. Nurik Esquire Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: Fax: EFTA01099336 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Edwards' Answers to Expert Interrogatories ANSWERS TO INTERROGATORIES 1. 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. Answer: Bradley Edwards has not retained any experts at this time. However, it is expected that some or all of the attorneys who have prosecuted civil claims against Jeffrey Epstein arising out of his abuse of children will be called to testify on behalf of Edwards and may express opinions regarding the services rendered by Edwards on behalf of his clients. 2. 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. Answer: N/A 3. Give the name or title of each paper which each expert has authored in the field of his/her expertise. Answer: N/A 4. State the name, volume and page number of the publication in which each article or paper listed above can be found. Answer: N/A 5. State the substance of the facts to which each expert listed is expected to testify. Answer: N/A 2 EFTA01099337 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAC Edwards' Answers to Expert Interrogatories 6. Give a complete list of all documents, depositions, exhibits, plans, drawings, ordinances or statutes which each expert has used in basing his/her opinion. Answer: N/A 7. State the opinion to which the experts aforementioned are expected to testify. Answer: N/A 8. Give a summary of the grounds of each opinion stated. Answer: N/A 9. Has the expert listed above practiced or worked in his/her field during the past five years? Answer: N/A 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 c. The dates the expert was with each employer d. The type of duty the expert performed with each employer II. If the expert was not practiced or worked in his/her field during the last five years, what was his/her employment during this time? Answer: N/A 3 EFTA01099338 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Edwards' Answers to Expert Interrogatories 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? Answer: N/A 13. Did the expert submit any other reports based upon tests, examinations or analysis of documents that he/she conducted in which he/she did not render an opinion? Answer: N/A 14. Attach a copy of any reports made by each expert on the basis of her/her tests, examinations or analyses to your answers to these Interrogatories. Answer: N/A 15. Is the expert to be compensated for his/her work and efforts in connection with this action? Answer: N/A 16. Has the expert served as an expert witness in any other litigated case in the past three years? Answer: N/A 4 EFTA01099339  Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Edwards' Answers to Expert Interrogatories Signa f Answering Party STATE OF ot.ii.).4 ) COUNTY OF etefre-A ) The foregoing instrument was acknowledged before me this O`14)4° day of )ei ifittter l — , 20 /6 bY aek k ranedii - who is personally known to me et who has- pfeetuced (type- of—ielentifieatiert) as- -identificationand who did/did-net take an oath. Not ry Publi Sta e of Florida Large My Commission expires. Commission No: 5 EFTA01099340 Discovery Request to Edwards and Response EFTA01099341  IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRC IN AND FOR PALM BEACH COUNTY, FLORIDA pal CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. NOTICE OF PROPOUNDING INTERROGATORY TO DEFENDANT, BRADLEY J. EDWARDS Plaintiff, Jeffrey Epstein, hereby provides notice that pursuant to Rule 1.340(e), Florida Rules of Civil Procedure, that one (1) Interrogatory has been directed to Defendant, Bradley J. Edwards, this L day of May, 2011. It is requested that the aforesaid answers be served within thirty (30) days at the offices of Fowler White Burnett, Phillips Point, West Tower, 777 South Flagler Drive, Suite 901, West Palm Beach, Florida 33401. FOWLER WHITE BURNETT • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • CM, EFTA01099342  Epstein v Rothstein, Edwards, etc CASE NO. 502009CA040800XXXXMBAG Plaintiffs Notice of Propounding Interrogatory to Bradley J. Edwards I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail this ay of May, 2011 to: Jack Scarola, Esq. Jack A. Goldberger, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A Atterbury Goldberger & Weiss, P.A. 2139 Palm Beach Lakes Blvd. 250 Australian Avenue South West Palm Beach, FL 33409 Suite 1400 West Palm Beach, FL 33401-5012 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 Respectfully submitted, ‘04. J seph L. Ackerman, Jr. Fla. Bar No. 235954 Email: FOWLER WHITE BURNETT, M. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: Facsimile: WAI07431NOTOSIS•Not of Intorropicey to Ott Edwords41.A.docx -2- PowLat WHITE autr4rn...901 PHILLIPS POINT WEST, 777 Sauna Futon owe, Wen PALM BEACH, FLORIDA 33401 EFTA01099343  INTERROGATORY TO DEFENDANT,BRADLEY J.EDWARDS I. As to every act characterized by the Defendant, Bradley J. Edwards an alleged "abuse of process" by Jeffrey Epstein, state the following: a. An exact and detailed description of the "process" including the title of all pleadings or other documents which the Plaintiff contends were abusive; b. The date on which each alleged abuse occurred; c. The exact nature of the damage suffered by the Defendant, Bradley J. Edwards as a consequence of this abuse; d. The amount of the damage alleged to have been caused by the abuse. EFTA01099344  By: BRADLEY J. EDWARDS STATE OF FLORIDA ) ss. COUNTY OF Being first duly sworn, , who is personally known to me or who has produced (type of identification), deposes and says that the attached Answer to Interrogatory are true and correct in all respects. SWORN TO AND SUBSCRIBED before me this day of , 2011. Notary Public Name of Notary (Print or Type) My commission expires: EFTA01099345 Edwards' Response EFTA01099346  IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)COOCMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). DEFENDANT, BRADLEY J. EDWARDS' NOTICE OF SERVING ANSWERS TO INTERROGATORIES COMES NOW the Defendant, Bradley J. Edwards, by and through undersigned counsel, and hereby provides Notice with the Court that Answers to Interrogatories propounded by the Plaintiff, Jeffrey Epstein, on May 16, 2011, have been furnished to the attorney for the Plaintiff I HEREBY CERTIFY that a true copy of the foregoing has been finished by mail this I 61--day of , 2011, t. ee attac ed list of counsel JACK S OLA Florid No.: 169440 Sea • enney Scarola Barnhart & Shipley, 213: 'alm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorney for Plaints D EC LE V JUN 1 3 ?OH I 119 EFTA01099347 Case No.: 502009CA040800XXXXMBAG Answers to Interrogatories ANSWERS TO INTERROGATORIES I. As to every act characterized by the Defendant, Bradley J. Edwards an alleged "abuse of process" by Jeffrey Epstein, state the following: a. An exact and detailed description of the "process" including the title of all pleadings or other documents which the Plaintiff contends were abusive; ANSWER: Every pleading, motion, notice, and discovery request served by the Plaintiff on Bradley Edwards in this case. b. The date on which each alleged abuse occurred; ANSWER: The date of service of each of the above as reflected on the Certificate of Service of each. c. The exact nature of the damage suffered by the Defendant, Bradley J. Edwards as a consequence of this abuse; ANSWER: Emotional distress, embarrassment, mental anguish, humiliation, loss of reputation and standing in the community, loss of the value of the time expended in defense of and in responding to the abuse process, attorneys fees and costs. d. The amount of the damage alleged to have been caused by the abuse. ANSWER: A total in excess of $1 Million. The exact amount is unliquidated and subject to determination by a jury. 2 EFTA01099348 Case No.: 502009CA040800YJCOCMBAG Answers to Interrogatories Signature of Answering Party STATE OF COUNTY OF The foregoing instrument was acknowledged before me this otit day of , 2011 by —34 edtgaA.4.S who is personally known to me or -9 who has produced (type of identification) as identification and who did/did not take an oath. Nota Public State f Florida at Larg My C mission expires: Commission No: 3 EFTA01099349 Case No.: 502009CA040800XXXXMBAG Answers to Interrogatories COUNSEL LIST Jack A. Goldberger, Esquire Joseph L. Ackerman, Jr., Esquire [email protected] Atterbury, Goldberger & Weiss. a Fowler White Burnett, P.A. 250 Australian Avenue South, Suite 1400 901 Phillips Point West West Palm Beach, FL 33401 777 S Flagler Drive Phone: West Palm Beach. FL 33401-6170 Phone: Attorneys for Jeffrey Epstein Fax: Attorneys Epstein Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman. PL Marc S. Nurik 425 N. Andrews Avenue, Suite 2 Fort Lauderd le FL 33 t 1 Law tees o arc S. Nurik Phone: One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein Phone: Fax: (9.54.1. 11 Attorneys for Scott Rothstein Martin Weinberg, Esquire Martin VL76ber 20 Park Plaza, Suite 1000 Suffolk. MA 02116 Phone: Fax: Attorneys for Jeffrey Epstein 4 EFTA01099350 Discovery Request to Edwards and Response EFTA01099351  IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, Case No. 50 2009CA040800)OOO(MB AG v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. EPSTEIN'S FIRST REOUEST FOR ADMISSIONS TO EDWARDS Plaintiff, JEFFREY EPSTEIN, pursuant to Ha. R. Civ. P. 1.370, requests that Defendant, BRADLEY J. EDWARDS ("Edwards" and/or "You" and/or "Your") admit or deny the following: 1. Admit that in Your March 23, 2010 deposition You testified under oath (at page 12), there are only three cases in existence against Jeffrey Epstein in which You represent a plaintiff (Jane Doe, L.M. and..). 2. Admit that the testimony described in Request No. 1 is false. 3. Admit that in Your March 23, 2010 deposition you testified under oath You only filed three cases against Jeffrey Epstein. 4. Admit that the testimony described in Request No. 3 is false. 5. Admit that the Motion to Proceed Anonymously (DE #3) asserted that L.M. "was an identified victim by the FBI and U.S. Attorney's office in a criminal investigation against the Defendant, Jeffrey Epstein." EFTA01099352  6. Admit that the assertion in Request No. 5 is false. 7. Admit that in paragraph 8 of Your answer to the Complaint in this action, You asserted that "RRA never filed a lawsuit on behalf of L.M." 8. Admit that the assertion described in Request No. 7 is false. 9. Admit that in paragraph 8 of Your answer to the Complaint in this action, You asserted that lawsuits filed on behalf of L.M. and other victims "were filed by EDWARDS prior to any association with or knowledge of RRA." 10. Admit that the assertion described in Request No. 9 is false. 11. Admit that in paragraph 9 of the Complaint (DE #1) in Case No. 09-CV-81092 it is alleged that Epstein "coerc[ed] or forc[ed] the then-minor L.M. to perform oral sex on 12. Admit that the allegations described in Request No. 11 are false. 13. Admit that in paragraph 17 of Your answer to the Complaint in this action, You admitted that "[r]elevant to this action, EPSTEIN is currently named as a defendant in three civil actions alleging, inter alia, sexual assault and battery that were handled by RRA and its attorneys including EDWARDS prior to its implosion — one of which is filed in federal court (Jane Doe v. Epstein, Case No. 08-CIV-80893, U.S.D.C. S.D. Fla.)(Jane Doe is a named Defendant herein), and two of which have been filed in state court in the 15th Judicial Circuit Court, Palm Beach County, State of Florida, (L. M. v. Epstein, Case No. 502008CA028051.3OCOCMB AB;.. v. Epstein, Case No. 502008CA028058XXXXMB AB), (hereinafter collectively referred to as the "Civil Actions," and L.M is a named Defendant herein). The Civil Actions were all filed in August and September of 2008." 14. Admit that Scott Rothstein was involved in the decision to file the Complaint EFTA01099353 (DE #1) in Case No. 09-CV-81092. 15. Admit that Russell Adler was involved in the decision to file the Complaint (DE #1) in Case No. 09-CV-81092. 16 Admit that in her September 24, 2009 deposition L.M. testified under oath (at page 71), that she never had oral sex with Epstein. 17. Admit that You caused to be filed a Complaint (DE #1) on behalf of L.M. in the case styled J ..M. v. leffrey Epstein., Case No. 09-CV-81092 in the United States District Court, Southern District of Florida, Miami Division on July 24, 2009. A copy of the Complaint is attached as Exhibit A. 18. Admit that a Complaint (DE #1) was filed on behalf of L.M. in the case styled L.M. v. Jeffrey Epstein, Case No. 09-CV-81092 in the United States District Court, Southern District of Florida, Miami Division, under Your name, Florida Bar number and e-mail address while you were employed by Rothstein, Rosenfeldt & Adler ("RRA"). 19. Admit that the Complaint (DE #1) in Case No. 09-CV-81092 is two hundred thirty-four (234) pages, contains six hundred forty-four (644) paragraphs and one hundred fifty- six (156) counts. 20. Admit that in Your March 23, 2010 deposition You testified under oath (at page 226) that You had no other professional e-mail addresses while at RRA except 21. Admit that a Motion to Keep True Name Sealed in Envelope (DE #2) was filed in Case No. 09-CV-81092 under Your name, Florida Bar number and e-mail address. 22. Admit that a Motion to Proceed Anonymously (DE #3) was filed on behalf of L.M. in Case No. 09-CV-81092 under Your name, Florida Bar number and e-mail address. EFTA01099354  Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. Mail to the following addressees on this IF day of June, 2010: Gary M. Farmer, Jr., Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Atterbury Goldberger & Weiss, P.A. Lehrman, PL 250 Australian Avenue South, Suite 1400 425 N. Andrews Avenue, Suite 2 West Palm Beach, FL 33401-5012 Fort Lauderdale, FL 33301 Fax: - fax Co-Carlendant Jeffrey Epstein Attorneys for Defendant, L.M. Jack Scarola, Esq. MARC S NURIK, ESQ. Searcy Denney Scarola Barnhart & Shipley, P.ALaw Offices of Marc S. Nurik 2139 Palm Beach Lakes Blvd. One East Broward Boulevard West Palm Beach, FL 33409 Suite 700 686-6300 Fort Lauderdale, FL 33301 383-9424 F Fax Attorneys for Defendant Bradley Edwards Attorneys colt Rothstein FOWLER WHITE BURNETT, M. Attorneys for Plaintiff Jeffrey EpsThiri Espirito Santo Plaza 1395 Stickel] Avenue, 14th Floo Miami, Florida 33131 fax By: Sanchez, Esq. da Bar No. 195677 EFTA01099355 Edwards' Response EFTA01099356 #24,1874/mep IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. i iDTT ROTHSTEIN, individually, SC B LEY J. EDWARDS, individually, and L. ., individually, . Defendant, EDWARDS' RESPONSE TO FIRST REQUEST FOR ADMISSIONS ' Dofondant/Counterplaintif£, BRADLEY J. EDWARDS, hereby files his Response to PlaIndfc JEFFREY EPSTEIN'S First Request for Admissions to Edwards dated Juno 18, 2010 es fjollows: 1. Denied. The transcript is accurate but Request for Admission No. 1 does not accurately describe the testimony. 2. Denied. A Complaint was filed in Federal Court against Jeffrey Epstein on behalf of L.M., but never served. 3. Denied. 4. Denied on the grounds that no suoh testimony was given. 5. Admitted. 6. Denied. 7. Admitted. EFTA01099357 4.0.1%.”t 11 0.1.V eta 101411.11NNO • Case No.: 502009CA040800)OOO:MBAO EDWARDS' REPONSE TO FIRST REQUEST FOR ADMISSIONS Page 2 of 4 ! 8. Denied. While a second Complaint was filed in Federal Court on behalf of L.M., it was never served and, therefore, RRA never prosecuted a lawsuit on behalf of L.M. except for the Isuit Bled prior to Edwards' association with RRA. 9. Admitted. 10. Denied. See response to Request for Admission No. 8. 11. Admitted. 12. Admitted. This allegation which is accurate as to was mistakenly carried . over to L.M. in the drafting of the Complaint on behalf of L.M. 13. Admitted. 14. Denied. 15. Denied. 16. Admitted. 17. Admitted. 18. Admitted. 19. Admitted. 20. Admitted. 21. Admitted. 22. Admitted. 23. Admitted. 24. Admitted. 25. Admitted. EFTA01099358 Case No.: 502009CA04080000aMBAO EDWARDS' REPONSE TO FIRST REQUEST FOR ADMISSIONS Page 3 of 4 26. Admitted. 27. Admitted. 28. Admitted. 29. Admitted. 30. Denied. 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 attache I l day of July, 2010. Jack Flora No.: 169440 Sea enney Scarola Barnhart & Shipley, . 21 alm Beach Lakes Boulevard est Palm 'cla 33409 I Phone: Fax Attorneys for Bradley J. Edwards EFTA01099359 VI/ v.. 44V.44,44 a V • 1114• •111" ••••.•••••Ip*: se a..•• • di•a.a Case No.: 502009CA040800)00CX.MBAO EDWARDS' REPONSE TO FIRST REQUEST FOR. ADMISSIONS Page 4 of 4 COUNSEL LIST Jack A. Goldberger, Esquire Attlethury, Goldberger & Weissit 250 Australian Avenue South, Suite 1400 Webt P 3401 PM Fax: Attorneys for Jeffrey Epstein Fanner, Jaffe, Weissing, Edwards, Fistos Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fat L 33301 Pho Fax: Fowler White Burnett, 777 S Flagler Drive, Suite 901 West Palm 3401 PM Fax: Attorneys for Jeffrey Epstein Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale. FL 33301 Phan; Fax: Attorneys for Scott Rothstein EFTA01099360 Discovery Request to Edwards and Response EFTA01099361  IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXM BAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, Copy v. RECEIVED SCOTT ROTHSTEIN, individually and APR 12 201,FILING BRADLEY J. EDWARDS, individually, CLEminion sock CLERK & CIRCUIT CIVIL COMPTROLLER Defendants. DIVISION I PLAINTIFF'S REQUEST FOR PRODUCTION OF APRIL 7, 2011 Plaintiff Jeffrey Epstein, pursuant to Rule 1.350, Fla, R.Civ. P., requests that defendant Bradley J. Edwards, produce for inspection and copying the documents identified below within the time limits provided by the Rule at the office of the undersigned. I. DEFINITIONS AND INSTRUCTIONS 1. "Document" means any document known to you and every such document which can be located or discovered by reasonably diligent efforts; any original or copy of such in your custody, possession or control, including, but not limited to, any printed, written, recorded, taped, electronic (e-mails), graphic, or other tangible matter from whatever source, however produced or reproduced, whether in draft or otherwise, whether sent or received or neither, including the original, all amendments and addenda and any non-identical copy (whether different from the original because of notes made on or attached to such copy or otherwise) of any and all writings, correspondence, letters, telegrams, facsimile communications, cables, notes, notations, papers, newsletters, memoranda, inter-office communications, releases, agreements, contracts, books, pamphlets, studies, minutes of meetings, recordings or other memorials of any type of personal or telephone conversations, meetings or conferences (including, but not limited to, telephone bills and long distance charge slips), reports, analyses, evaluations, estimates, projections, forecasts, receipts, statements, accounts, books of account, diaries, calendars, desk pads, appointment books, stenographer's notebooks, transcripts, ledgers, registers, worksheets, journals, statistical records, cost sheets, summaries, lists, tabulations, digests, cancelled or uncanceled checks or drafts, vouchers, charge slips, invoices, purchase orders, accountant's reports, financial statements, newspapers, periodical or magazine materials, and any material underlying, supporting or used in the preparation of any documents or record whatsoever. EFTA01099362  CASE NO. 502009CA0408003OOOa4BAG 2. "Referring to", "reflecting", "supporting", "evidencing" or "relates to" means in any way directly or indirectly, concerning, disclosing, describing, confirming, or representing. 3. "And" and "or" shall be construed in the disjunctive or conjunctive as necessary in order to bring within the scope of each request all documents which might otherwise be construed to be outside its scope. 4. "Epstein" means the Plaintiff. 5. "Defendant", "you" and/or "Edwards" means Bradley J. Edwards and agent or attorney for him and any other person acting or purporting to act for, or on behalf of Edwards or under Edwards's authority or control. 6. "Complaint" refers to the initial pleading or Complaint filed by Plaintiff in this action and any amended pleadings. 7. All other terms are defined as they are in the Complaint. 8. Any document as to which a claim of privilege is or will be asserted should be identified by author, signatory, description (e.g., letter, memorandum, facsimile, recording, etc.), title (if any), date, addresses (if any), general subject matter, present depository and present custodian and a complete statement of the ground for the claim of privilege should be set forth. 9. If you maintain that any document that is requested has been destroyed, set forth the contents of the document, the date of such destruction and the name of the person who authorized or directed such destruction. 10. If any of the documents requested cannot be produced in full, produce to the extent possible, specifying the reasons for the inability to produce the remainder. 11. In responding to the following document requests, please specify which documents are responsive to each request and, where appropriate, to each sub-part thereof 12. This request is a continuing one. If after producing documents, you become aware of any further responsive documents, you are requested to produce such additional documents. 13. If you maintain that documents responsive to any Request contained herein have previously been produced in response to an earlier Request, so state and provide the bate-number if so numbered. 14. Unless otherwise stated, the time period for this request is from May 1, 2010 through the date of service. -2- EFTA01099363  CASE NO. 502009CA040800XXXXMBAG REQUESTS 1. All documents reflecting any allegedly public statements made by Plaintiff regarding "his criminal activity" as referenced by counsel to Defendant Edwards in an email of March 14, 2011 to Plaintiff's counsel Ackerman. 2. All documents reflecting or tending to support Defendant Edwards's position that Plaintiff waived his Fifth Amendment rights under the U.S. Constitution. 3. All documents reflecting or tending to support Defendant Edwards's position that Plaintiff has lost his Fifth Amendment rights by operation of law or otherwise except by waiver. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this 7th day of April, 2011 to Gary M. Farmer, Jr., Esq., Fanner, Jaffee, Weissing, Edwards, Fistos, et al, 425 N. Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012; Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301; and Jack Scarola, Esquire, Searcy Denney Scarola et al., 2139 Palm Beach La