EFTA00613615.pdf

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, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). REQUEST ro PRODUCE TO JEFFREY EPSTEIN Bradley J. Edwards by and through his undersigned counsel, request, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that Jeffrey Epstein, produce and permit Bradley J. Edwards to inspect and copy each of the following documents*: 1. Paragraph 12 of Edwards' Third Amended Counterclaim alleges that "Epstein ignored the statutory requirement for written notice prior to the initiation of a civil theft claim" against Edwards. That allegation is denied by Epstein. Produce any and all documents* which you contend constitute any notice to Edwards of the intent to file a claim for violation of Chapter 772, Florida Statutes, and all documents* referring to the delivery to Edwards or any agent of Edwards of such notice. *"Documents" shall include, but not be limited to all non-identical copies of writings, drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data compilations from which information can be obtained, translated, if necessary, by the party to whom the request is directed through detection devices into reasonably usable form. EFTA00613615 Edwards adv. Epstein Case No • 502009CA040800XXXXMBAG Request to Produce to Jeffrey Epstein "Documents" also include all electronic data as well as application metadata and system metadata. All inventories and rosters of your information technology (IT) systems—e.g., hardware, software and data, including but not limited to network drawings, lists of computing devices (servers, PCs, laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps and security tools and protocols. It is requested that the aforesaid production be made within thirty days of service of this request at the offices of Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida. Inspection will be made by visual observation, examination and/or copying. I HEREBY CERTIFY that a true and correct copy of the foregoing has be n furnished by Electronic and U.S. Mail to all Counsel on the attached list, this 2012. Jack a Flo ar No.: 169440 Denney Scarola Barnhart & Shipley Palm Beach Lakes Boulevard est Palm Beach, Florida 33409 Phone: Fax: Attorneys or Bradey7 dwwards 2 EFTA00613616  COUNSEL LIST Bradley J. Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, FL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Pho Fax: Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phon Fax: Marc S. Nurik, Esquire One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Pho Fax Tonja Haddad Coleman, Esquire 524 S Andrews Avenue, Suite 200N Fort 01 Phon Fax: Lilly Ann Sanchez, Esquire The L-S Law Firm 1441 Brickell Avenue, 15th Floor Mia Phd FaZ: EFTA00613617