EFTA01080982.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). 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 furnished by mail this day of 1 611--- ,2011,t ed list of counsel Attorney for Plaintiffs) EFTA01080982 Case No.: 502009CA040800XXXXMBAC Answers to Interrogatories ANSWERS TO INTERROGATORIES 1. 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 EFTA01080983 Case No.: 502009CA040800XXXXMBAG Answers to Interrogatories Signature of Answering Party STATE OF COUNTY OF The foregoing instrument was acknowledged before me this pew— day of who is personally known to me or 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 EFTA01080984 Case No.: 502009CA040800XXXXMBAG Answers to Interrogatories COUNSEL LIST Jack A. Goldberger Jose h L. Ackerman Jr. Es uire Atterbury, Goldberger & Weiss. P.A. Fowler White Burnett, P.A. Attorneys for Jeffrey Epstein Attorneys for Jeffrey Epstein Fanner, Jaffe, Weissine, Edwards. Fistos & Lehrman. PL Marc S. Nurik 2 Law Offices of Marc S. Nurik Attorneys for Jeffrey Epstein Attorneys for Scott Rothstein Martin Weinberg, Esquire Martin Weinberg, P.C. Attorneys for Jeffrey Epstein 4 EFTA01080985