EFTA00722339.pdf
09/16/2010 14:44 FAX SEARCY DENNEY liDoovoo4
#291874/mep IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502009CA040800XXXXM BAG
JEFFREY EPSTEIN,
Plaintiff(s),
SCpTT ROTHSTEIN, individually,
B LEY J. EDWARDS, individually, and
L.M., individually,
I Defendant(s).
I /
DEFENDANT/COIJNTERPLAINTIFF'S REOUEST TO PRODUCE
TO PLADITIFF/COUNTERDEFENDANT, JEFFREY EPSTEIN
Defendant/Counterplaintiff, Bradley J. Edwards ,by and through his undersigned counsel,
recuests, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that
PlIntifUColuiterdefendant, Jeffrey Epstein, produce and permit Bradley J. Edwards to inspect
and copy each of the following documents*:
1. All statements of the Defendant, Bradley J. Edwards, pertaining to any of the
issues in this lawsuit
2. All statements of any witness you intend to use at trial for impeachment.
3. All documents* including but not limited to diaries, journals, computer database
=lends or any other written or electronically stored information that reflect or relate to any
communication to or from minor females and/or any physical contact which did or was planned
to bccur between you and any person who was a minor female" at the time of the physical
cotdact or planned physical contact including but not limited to any massage, fondling, or sexual
EFTA00722339
09/10/2010 14:44 FAX SEARCY DENNEY U1002/004
s adv. Epstein
No.: 302009CA040800XXXXMBAG
Request to Produce to Jeffrey Epstein
interaction of any kind (this should include all message pads or appointment scheduler for minor
feriales").
4. All written documents supporting the allegations in your complaint.
5. All message pads, calendars of your schedule or appointments or other documents
containing your "massage" appointments; and
6. A complete copy of each and every exhibit which you intend to introduce or have
considered introducing into evidence at trial.
"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
corlimilations 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.
"Dtcuments" 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, M., 2139 Palm Beach
- "minor females" is defined as females who were known by you at the time or who are now !mown to you to have
beed under 18 yearn of age at the time of your interaction with diem, and females who you now bavc mason to
believe may have been under 18 years of age at the time of your interaction with them.
2
EFTA00722340
09/16/2010 14:45 FAX SEARCY DENNEY lib003/004
Edwards adv. Epstein
Case No.: 502009CA040800=0CMBAG
Request to Produce to Jeffrey Epstein
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 been furnished by
Fax and U.S. Mail to all Counsel on the attached list, th 110.1)—day of 2010.
la`•
Bar No.: 169440
cy Denney Scarola Barnhart & Shipley
139 Palm Beach Lakes Boulevard
West Palm Beach. Florida 33409
Phone:
Fax:
Attorneys for
3
EFTA00722341
09/16/2010 14:45 FAX SEARCY DENNEY in004/004
Edwards
' adv. Epstein
Ca+ No.: 502009CA040800,OOOCM:BAG
Request to Produce to Jeffrey Epstein
COUNSEL LIST
Jack A. Goldberger, Esquire
Attetbury, Goldberger & Weiss, M.
25C Australian Avenue South, Suite 1400
Wet Palm Beach, FL 33401
P
Fac
il iar
Carp? M. Farmer, Esq.
Farmer, Jaffe, Weissing, Edwards, Fistos &
Le an, PL
42 N. Andrews Avenue, Suite 2
Fo Lauderdale FL 33301
Phone:
Pale
Marc S. Nurik, Esq.
Law Offices of Marc S. Nurik
One E Broward Blvd., Suite 700
Fort Lauderdale FL 33301
Phcine:
Fax:
Christopher E. Knight, Esq.
Joseph L. Ackerman, Esq.
Fovher White Burnett, PA.
777. S Flagler Drive, Suite 901
West Palm Beach FL 33401
Phone:
Fax'
4
EFTA00722342
#291874/mep IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502009CA040800XXXXM BAG
JEFFREY EPSTEIN,
Plaintiff(s),
SCpTT ROTHSTEIN, individually,
B LEY J. EDWARDS, individually, and
L.M., individually,
I Defendant(s).
I /
DEFENDANT/COIJNTERPLAINTIFF'S REOUEST TO PRODUCE
TO PLADITIFF/COUNTERDEFENDANT, JEFFREY EPSTEIN
Defendant/Counterplaintiff, Bradley J. Edwards ,by and through his undersigned counsel,
recuests, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that
PlIntifUColuiterdefendant, Jeffrey Epstein, produce and permit Bradley J. Edwards to inspect
and copy each of the following documents*:
1. All statements of the Defendant, Bradley J. Edwards, pertaining to any of the
issues in this lawsuit
2. All statements of any witness you intend to use at trial for impeachment.
3. All documents* including but not limited to diaries, journals, computer database
=lends or any other written or electronically stored information that reflect or relate to any
communication to or from minor females and/or any physical contact which did or was planned
to bccur between you and any person who was a minor female" at the time of the physical
cotdact or planned physical contact including but not limited to any massage, fondling, or sexual
EFTA00722339
09/10/2010 14:44 FAX SEARCY DENNEY U1002/004
s adv. Epstein
No.: 302009CA040800XXXXMBAG
Request to Produce to Jeffrey Epstein
interaction of any kind (this should include all message pads or appointment scheduler for minor
feriales").
4. All written documents supporting the allegations in your complaint.
5. All message pads, calendars of your schedule or appointments or other documents
containing your "massage" appointments; and
6. A complete copy of each and every exhibit which you intend to introduce or have
considered introducing into evidence at trial.
"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
corlimilations 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.
"Dtcuments" 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, M., 2139 Palm Beach
- "minor females" is defined as females who were known by you at the time or who are now !mown to you to have
beed under 18 yearn of age at the time of your interaction with diem, and females who you now bavc mason to
believe may have been under 18 years of age at the time of your interaction with them.
2
EFTA00722340
09/16/2010 14:45 FAX SEARCY DENNEY lib003/004
Edwards adv. Epstein
Case No.: 502009CA040800=0CMBAG
Request to Produce to Jeffrey Epstein
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 been furnished by
Fax and U.S. Mail to all Counsel on the attached list, th 110.1)—day of 2010.
la`•
Bar No.: 169440
cy Denney Scarola Barnhart & Shipley
139 Palm Beach Lakes Boulevard
West Palm Beach. Florida 33409
Phone:
Fax:
Attorneys for
3
EFTA00722341
09/16/2010 14:45 FAX SEARCY DENNEY in004/004
Edwards
' adv. Epstein
Ca+ No.: 502009CA040800,OOOCM:BAG
Request to Produce to Jeffrey Epstein
COUNSEL LIST
Jack A. Goldberger, Esquire
Attetbury, Goldberger & Weiss, M.
25C Australian Avenue South, Suite 1400
Wet Palm Beach, FL 33401
P
Fac
il iar
Carp? M. Farmer, Esq.
Farmer, Jaffe, Weissing, Edwards, Fistos &
Le an, PL
42 N. Andrews Avenue, Suite 2
Fo Lauderdale FL 33301
Phone:
Pale
Marc S. Nurik, Esq.
Law Offices of Marc S. Nurik
One E Broward Blvd., Suite 700
Fort Lauderdale FL 33301
Phcine:
Fax:
Christopher E. Knight, Esq.
Joseph L. Ackerman, Esq.
Fovher White Burnett, PA.
777. S Flagler Drive, Suite 901
West Palm Beach FL 33401
Phone:
Fax'
4
EFTA00722342