EFTA00584744.pdf
JEFFREY EPSTEIN, IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY,
FLORIDA
CASE NO.: 502009CA040800XXXXMBAG
JUDGE: CROW
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
and BRADLEY J. EDWARDS,
individually.
Defendants.
AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM
(VIDEOTAPED)
PLEASE TAKE NOTICE that Pursuant to Rule 1.410 of the Florida Rules of Civil
Procedure, the undersigned attorney will take the deposition of Defendant/Counter-Plaintiff
Bradley J. Edwards on Wednesday, May 15, 2013 at 10:00AM at Empire Legal Support,
Inc., 401 East Las Olas Boulevard, Suite 1400, Fort Lauderdale, FL 33301, upon oral
examination before Empire Legal Support, Notaries Public, or any other notary public or officer
authorized by law to take depositions in the state of Florida. The oral examination will continue
all day and day to day thereafter until completed. This deposition is being taken for the purpose
of discovery, for use at trial, or for such other purposes as are permitted under the rules of Court.
If you fail to appear, you may be in contempt of court. You are subpoenaed to appear by
EFTA00584744
the following attorney, and unless excused from this subpoena by this attorney or the court, you
shall respond to this subpoena as directed. This includes bringing with you the documents listed
in "Schedule A" attached hereto.
We hereby certify that this date was coordinated with opposing counsel, and that a true
and correct copy of this amended notice was served upon all parties listed in the service list
below, via Electronic Service, this April 22, 2013.
Tonja Haddad Coleman, Esq.
Fla. Bar No.: 0176737
LAW OFFICES OF TONIA HADDAD, PA
315 SE 7'h Street
Suite 301
Florida 33301
facsimile)
EFTA00584745
SCHEDULE A
(To Bring With You For Deposition)
1. Copies of income tax returns for the past five (5) calendar years of the
Defendant/Counter-Plaintiff Bradley J. Edwards (hereinafter "Edwards") (2007-2012).
2. Income tax records for the current tax year, and copies of any estimated income
tax returns filed for the current year for Edwards.
3. Copies of income tax returns for the past three (3) calendar years of Farmer, Jaffe,
Weissing, Edwards, Fistos & Lehrman, P.L.
4. Copies of all documentation related to all settlements, attorneys' fees awards, jury
verdict awards, and arbitration/mediation income received by Farmer, Jaffe, Weissing, Edwards,
Fistos & Lehrman, P.L., and/or Bradley J. Edwards, PA.
5. Income tax records for the current tax year, and copies of any estimated income
tax returns filed for the current year for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman,
P.L.
6. A copy of Edwards's (or Bradley J. Edwards, PA's) partnership agreement with
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.
7. Copies of any and all documents, memoranda . . . upon which you rely in support
of your allegation of lost income/value of time diverted from your professional responsibilities as
alleged in your Counterclaim.
8. Copies of any and all documents, memoranda . . . upon which you rely in support
of your allegation of injury to your reputation as alleged in your Counterclaim.
9. Copies of any and all receipts, reports, or invoices evidencing treatment for your
mental anguish, embarrassment, and anxiety as alleged in your Counterclaim.
10. Copies of any and all receipts, reports, or invoices evidencing lost income
suffered as a result of your mental anguish, embarrassment, and anxiety as alleged in your
Counterclaim.
EFTA00584746
FIFTEENTH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY,
FLORIDA
CASE NO.: 502009CA040800XXXXMBAG
JUDGE: CROW
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
and BRADLEY J. EDWARDS,
individually.
Defendants.
AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM
(VIDEOTAPED)
PLEASE TAKE NOTICE that Pursuant to Rule 1.410 of the Florida Rules of Civil
Procedure, the undersigned attorney will take the deposition of Defendant/Counter-Plaintiff
Bradley J. Edwards on Wednesday, May 15, 2013 at 10:00AM at Empire Legal Support,
Inc., 401 East Las Olas Boulevard, Suite 1400, Fort Lauderdale, FL 33301, upon oral
examination before Empire Legal Support, Notaries Public, or any other notary public or officer
authorized by law to take depositions in the state of Florida. The oral examination will continue
all day and day to day thereafter until completed. This deposition is being taken for the purpose
of discovery, for use at trial, or for such other purposes as are permitted under the rules of Court.
If you fail to appear, you may be in contempt of court. You are subpoenaed to appear by
EFTA00584744
the following attorney, and unless excused from this subpoena by this attorney or the court, you
shall respond to this subpoena as directed. This includes bringing with you the documents listed
in "Schedule A" attached hereto.
We hereby certify that this date was coordinated with opposing counsel, and that a true
and correct copy of this amended notice was served upon all parties listed in the service list
below, via Electronic Service, this April 22, 2013.
Tonja Haddad Coleman, Esq.
Fla. Bar No.: 0176737
LAW OFFICES OF TONIA HADDAD, PA
315 SE 7'h Street
Suite 301
Florida 33301
facsimile)
EFTA00584745
SCHEDULE A
(To Bring With You For Deposition)
1. Copies of income tax returns for the past five (5) calendar years of the
Defendant/Counter-Plaintiff Bradley J. Edwards (hereinafter "Edwards") (2007-2012).
2. Income tax records for the current tax year, and copies of any estimated income
tax returns filed for the current year for Edwards.
3. Copies of income tax returns for the past three (3) calendar years of Farmer, Jaffe,
Weissing, Edwards, Fistos & Lehrman, P.L.
4. Copies of all documentation related to all settlements, attorneys' fees awards, jury
verdict awards, and arbitration/mediation income received by Farmer, Jaffe, Weissing, Edwards,
Fistos & Lehrman, P.L., and/or Bradley J. Edwards, PA.
5. Income tax records for the current tax year, and copies of any estimated income
tax returns filed for the current year for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman,
P.L.
6. A copy of Edwards's (or Bradley J. Edwards, PA's) partnership agreement with
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.
7. Copies of any and all documents, memoranda . . . upon which you rely in support
of your allegation of lost income/value of time diverted from your professional responsibilities as
alleged in your Counterclaim.
8. Copies of any and all documents, memoranda . . . upon which you rely in support
of your allegation of injury to your reputation as alleged in your Counterclaim.
9. Copies of any and all receipts, reports, or invoices evidencing treatment for your
mental anguish, embarrassment, and anxiety as alleged in your Counterclaim.
10. Copies of any and all receipts, reports, or invoices evidencing lost income
suffered as a result of your mental anguish, embarrassment, and anxiety as alleged in your
Counterclaim.
EFTA00584746