EFTA00793345.pdf

Filing # 66507496 E-Filed 01/12/2018 04:26:17 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION TO REOPEN DISCOVERY TO TAKE DEPOSITIONS Counter-Plaintiff, Bradley J. Edwards, by and through undersigned counsel, hereby files this Response in Oppositions to Jeffrey Epstein's Motion to Reopen Discovery to Take Depositions, and as grounds therefor states as follows: The Motion Fails to Meet the Court's Requirements to Reopen Discovery 1. On November 27, 2017, the Court entered its Order on Motion to Reconfirm Existing Pre-Trial Deadlines, in which the Court ruled that additional discovery will only be permitted if "the discovery requests are impacted by the Court's rulings on motions currently pending to be heard on November 29'h, December 6th and 7'h." At the hearing preceding the Order, the Court outlined the standard by which any such additional discovery requests would be considered: So what I am going to do is this. Because there are issues that need to be addressed -- and I'm hoping I will have orders out as soon as possible after those hearings are done -- is that I am going to require motions to be filed I A copy of the Court's Order is attached hereto as Exhibit 'A'. EFTA00793345 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Motion to Reopen Discovery Page 2 of 8 on a discovery issue-by-discovery issue, deposition by deposition, so as to find out several things. One, is the need to take that deposition and whether that need has been either clarified or required by virtue of a court order that will be entered subsequently to the commencement of Wednesday's hearings and thereafter on those days that I provided. If it cannot be demonstrated to the Court that these witnesses need to be taken solely as a result the Court's ruling, then those requests will be denied because, again, we were set to try the case next week. *** So 20 some-odd deposition, unless they can be proven and shown to the Court as being required as a result of the rulings of the Court, will not be entertained. They should have been done before. And if not done before, I will need a reason for that as well. 11/27/2017 Hearing Tr. at 12:11-25 and 13:1-6, 17-23.2 2. Thus, Epstein has the burden to establish that (a) the new depositions are required solely as a result of a recent Court ruling, and, if so, (2) that the depositions could not have been taken before. Epstein's motion clearly fails to meet either requirement, and therefore the motion should be denied.3 A. Epstein Has Been Aware of the Relevance of the Testimony of These Witnesses for Years and Could Have Deposed Them Long Before the Discovery Cutoff. 3. As an initial matter, L.M. was a named defendant in this lawsuit filed by Epstein. Allegations regarding L.M.'s role in the Ponzi scheme and her fabricated claim are replete 2 Excerpts of the November 27, 2017 hearing transcript are attached as Exhibit Perhaps understanding the Motion's futility, Epstein spends the first four pages arguing about Edwards' damages and, incredibly, accusing Edwards of using L.M., E.W. and Jane Doe for his own personal gain. As Epstein is all too aware, the only person who has forced these victims to do anything against their will is Epstein, and the suggestion that these victims have by now "put behind them" the atrocious sexual misconduct committed against them by Epstein is yet another example of Epstein's indifference to the permanent damage he inflicted on his child victims. 2 EFTA00793346 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Motion to Reopen Discovery Page 3 of 8 throughout Epstein's Initial Complaint. Any suggestion that L.M.'s deposition is needed "solely" as a result of the Court's December 5, 2017 ruling is therefore absurd. 4. Jane Doe is also named repeatedly throughout Epstein's malicious and baseless Initial Complaint, and she was also alleged to be pursuing claims against Epstein that had "minimal" value. Edwards' first witness list, filed June 30, 2010, listed all named victims ofJeffrey Epstein as fact witnesses for trial, which of course included Jane Doe. As such, any argument that Jane Doe's deposition is needed "solely" as a result of a recent Court ruling is also absurd. 5. Rather, Epstein was obviously well-aware of the relevance of the testimony ofL.M. and Jane Doe long before the Court's recent rulings. There is no need, however, to accept Edwards' argument to that effect. Rather, the Court need only consider the fact that in August 2017 Epstein requested and received dates to take L.M. and Jane Doe's depositions in early October 2017 (before the discovery deadline). Epstein, however, voluntarily chose not to set either witness for deposition. 6. Thus, Epstein clearly fails to meet the first requirement enunciated by the Court, that the depositions be needed "solely" as a result of a recent ruling, and the Motion should be denied on those grounds alone. B. Epstein's Prior Counsel Failed to Set L.M. and Jane Doe's Depositions, Despite Requesting and Receiving Dates for Their Depositions in August 2017. 7. The Motion should further be denied because, although Epstein could have taken these depositions months ago, he voluntarily chose not to so. 3 EFTA00793347 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Motion to Reopen Discovery Page 4 of 8 8. Specifically, on August 2, 2017, Epstein's prior counsel requested deposition dates for L.M. and Jane Doe (the email also sought the depositions of E.W. and That same day, undersigned counsel's office responded via email and stated that dates were available in early October, and to call to clear specific dates for these depositions. 9. On August 3, 2017, Edwards, as counsel for L.M., E.W. and Jane Doe, stated that he would accept service of subpoenas for his clients' depositions. 10. On August 14, 2017, after some back and forth email exchanges, Epstein's prior counsel instructed undersigned counsel's office to hold 10/5, 10/11 and 10/12 for depositions. 11. On August 16, 2017, Edwards confirmed that he would make L.M., E.W., and Jane Doe available on any date. 12. Epstein then set ' deposition for 10/5 and E.W's deposition for 10/12. No depositions were set for 10/11. 13. On September 26, 2017, Epstein unilaterally cancelled the 10/5 deposition of after Ms. Roberts had travelled to New York from Australia solely for purposes of sitting for the deposition. 14. Epstein failed to set L.M. and Jane Doe for deposition on 10/5, despite Edwards' notice that he could make them available on that date. 15. As such, no depositions were taken on 10/5 16. Epstein also failed to take any depositions on 10/11. 17. Instead, Epstein used only 10/12 to take the deposition of E.W. 4 EFTA00793348 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Motion to Reopen Discovery Page 5 of 8 18. Thus, when the Court asks Epstein's counsel for the reason why L.M. and Jane Doe's depositions have not been taken, the answer is quite simple: because Epstein chose not to take them. C. Epstein's Current Counsel Chose Not to Set Any Depositions Prior to the Close of Discovery. 19. After Epstein's prior counsel failed to use either the 10/5 or 10/11 dates to take the depositions of L.M. and Jane Doe, his current counsel made efforts to set witness depositions prior to the November 24, 2017 discovery deadline. 20. Specifically, on November 13, 2017, Epstein's counsel requested deposition dates for a number of attorneys who had represented other Epstein victims. 21. Notably, however, Epstein's current counsel failed to request new deposition dates for either L.M. or Jane Doe. 22. On November 13, 2017, undersigned counsel's office advised Epstein's counsel that it was available for depositions each day, apart from Thanksgiving, until the discovery cutoff on November 24th. Thus, Epstein could have set depositions on 11/14, 11/15, 11/16, 11/17, 11/18, 11/19, 11/20, 11/21, 11/22, or 11/24. 23. Epstein failed to set any depositions, whether of the attorney witnesses or of L.M. and Jane Doe, on the dates given. 24. In total, Epstein therefore declined to use twelve (12) days provided by undersigned counsel to schedule the depositions of L.M. and Jane Doe prior to the discovery cut- off. As such, the only reason these witnesses have not been deposed, witnesses whose importance 5 EFTA00793349 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Motion to Reopen Discovery Page 6 of 8 Epstein has been aware of for years, is because Epstein affirmatively chose not to depose them. Epstein's current remorse over that litigation tactic certainly fails to meet the Court's requirements to reopen discovery, particularly on the eve of trial in this eight (8) year old case. Conclusion For the foregoing reasons, Epstein's Motion to Reopen Discovery should be denied. I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this Id - --day of '--. A-°" 1111 2018. JACK/SC RO Flola ar No.: 169440 DA I i P. VITALE JR. Flo • a Bar No.: 115179 Attorney E-Mail(s): [email protected] and [email protected] Primary E-Mail: [email protected] Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for Bradley J. Edwards 6 EFTA00793350 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Motion to Reopen Discovery Page 7 of 8 COUNSEL LIST Bradley J. Edwards, Esquire [email protected] 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 Jack A. Goldberger, Esquire [email protected]; [email protected] Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Nichole J. Segal, Esquire njs®FLAppellateLaw.com; [email protected] Burlington & Rockenbach, P.A. 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: (561)-721-0400 Attorneys for Bradley J. Edwards Scott J. Link, Esquire [email protected]; [email protected]; [email protected]; Angela®linlcrocldaw.com; [email protected]; [email protected] Link & Rockenbach, P.A. 1555 Palm Beach Lakes Boulevard Suite 301 West Palm Beach, FL 33401 Phone: (561)-727-3600 Fax: (561)-727-3601 Attorneys for Jeffrey Epstein Marc S. Nurik, Esquire [email protected] EFTA00793351 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Motion to Reopen Discovery Page 8 of 8 One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein 8 EFTA00793352  IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY. FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, vs. SCOTT ROTHSTEIN. individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). ORDER ON MOTION TO RECONFIRM EXISTING PRETRIAL DEADLINES g,v 25 73ne riem$4 -17.74497-.4t/ THIS CAUSE having come to be considered upon Bradley J. Edwards' MOTIONTO RECONFIRM EXISTING PRETRIAL DEADLINES, and the Court having reviewed the file and being fully advised in the premises. it is hereby. ORDERED and ADJUDGED: Va."- PAC 7/4•44n c yzee.44,4 )- pi 44i> /ell 1 -e- 44VC, CY(Aa 441446-MA antaPean. -de 001-17 DONE AND ORDERED at West Palm Beach, Palm Beach County. Florida. this c? 7 day of 6.43•• , 2017. DO ALD HAFT, IRCUIT JUDGE *aced", -OfeteZt AineeLe ke-Atutf4=7 norst--494.4 7 s it cora.t4 Copies h ve been furnkshed o all cot nsel o,t; the attached consel list. I t.,4 nztvenerg,44.61-24, cg ;c;zaa.9) at. ardai %7 A EFTA00793353  Edwards adv. Epstein Case No.: 502009CA040800XXXXMRAC Order on Motion to Reconfirm Existing Pretrial Deadlines COUNSEL LIST Jack Scarola, Esquire _scarolateam©searcylaw.com Searcy Denney Scarola Barnhart & Shipley PA 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Phone: (561) 686-6300 Fax: 561-383-9451 Attorneys for Bradley J. Edwards Bradley J. Edwards, Esquire staff [email protected] 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 Nichole J. Segal, Esquire njs©FLAppellateLaw.com; kbt©FLAppellateLaw.com Burlington & Rockenbach, P.A. 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: (561)-721-0400 Attorneys for Bradley J. Edwards Jack A. Goldberger, Esquire jgoldberger©agwpa.com; [email protected] Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Scott J. Link, Esquire [email protected]; [email protected]; [email protected]; [email protected]; Tanya©Iinknxklaw.com; [email protected] 2 EFTA00793354 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Order on Motion to Reconfirm Existing Pretrial Deadlines Link & Rockenbach, l'.A. 1555 Palm Beach Lakes Boulevard Suite 301 West Palm Beach, FL 33401 Phone: (561)-727-3600 Fax: (561)-727-3601 Attorneys for Jeffrey Epstein Marc S. Nurik, Esquire [email protected] One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein 3 EFTA00793355  1 3 IN THE CIROLIIT COURT OF Tile MS. ROCKENBACH: Good morning, Your PIPTED1111 JI7DICIAL CIRCOIT, IN 2 Honor. AND MR PAW RAM CCUM, FLORIDA Casa No. 50200PCJU)401100:03C0111 3 MR. SCAROLA: Good morning. THE COURT: Good morning. dant( EPSTEIN, 5 Thank you for sending me the legal Plaintiff, issues that need to be addraased and the SCOT( ROTIMEIN, individually, anticipated amount of time that you are BRADLEY MAIDS, individually, 4 going to need. I appreciate that. Defer&Saats/Countax-Plaintiffa. 9 This motion I have before me is to Id reconfirm and Edwards' opposition to the II existing pretrial deadlines, which were set TRANSCRIPT Or PROCEW1K03 22 in contemplation of the ease going to trial I) in December. DATE PARDO: Nooday, November 27th, 2017 Ii SCAROLA: Almost, sir. $:01 a.m. - 9:27 a.m. PLACE 205 S. nixie Sighway. Room IOC THE COURT: Pardon? West Palm Reach, Florida 14 MR. SCAROLA: Almost. Your Honor has BEFORE: whale Motel*, Presiding Judge 17 it backwards. It is Mr. Edwards who is le seeking to reconfirm the deadline. This cause ease on to be heard et tie Um and place 29 Mr. Epstein is objecting to that aforesaid, when and whore the following propeediegs vete repotted by: 20 reconfirmation. 21 THE COURT: My error. Sorry about Sonja D. Rill 22 that. Palm Reach Reporting Service, Inc. 1465 Pals leach Lakes Boulevard, Suite 1001 23 MR. SCAROLA: That's all right. A Nast Pala Beach, it )2401 24 mistake that we all make repeatedly. 1541) 471-2995 25 THE COURT: Mr. Edwards is seeking to 2 4 2 APPEARANCES: 1 confirm or reconfirm the existing deadlines, 2 For Plaintiff: 2 Mr. Epstein is objecting. Okay. 3 LIKK & ROCKENBACH, P.A. All right. So I guess the place to 1555 Palm Bondi Lakes Boulevard, Suite 301 4 start is from Mr. Edwards' standpoint as the Reim Palm Beach, FL 33401 By KAM BERARD ROOM/MACH, REWIRE 5 punitive plaintiff here. Is there any 3 S discovery that's necessary from your For Bradley Edwards: standpoint at this juncture? SERACT, DIMMY, SCAROtA, MNOWIT & a MR. SCMOLA• Ho sir SHIPLRY, P.A. a TIC COURT: Ns. RecRenbach7 2139 Palm Beach Lakes Boulevard West Palm Beech, FL 33409 10 NS. ROCKINBACN: Yes, Your Honor. If By MC( sCAMM. ES0UIRE 11 you recall, your order that granted the By DAVID P. VITALS, JR. motion to continue sets forth in it -- which 10 13 la November 14th -- that both parties don't 11 Ia know how the Court will ultimately rule on 12 13 If Critical issues, which will require counsel 14 to try to strategize and plan their 17 respective teen under extreme uncertainty 16 le and duress. And that was a quote fres your :1 19 order, which you correctly identified. If If 20 And as a result, Your honor opened up 20 21 additlonai days on your caiendar so that we 21 22 could hear those incredibly significant 22 27 diapositive legal motions that are pending. 2) 24 34 We are going to be before the Court on 21 25 Wednesday, and then next week. on Palm Beach Reporting Service, Inc. 561-471-2995 Fx. EFTA00793356  9 Keeping these deadline, in place, was in Europe and that vas the date :hat war freezing this case in the position that it 2 provided. lie contradicts Mr. Edwards• was in on the eve of trial and ready to be answers to interrogatories about damages. tried is the only way to prevent those kind: 4 So this case -- there are no additional 5 of last-minute delays. notions to be filed. Your Honor has then. r There has been an avalanche 6 of motions all, in addition to the response:. what w„ that have already been filed, but we have • do need is to proceed in an orderly fashion plenty of tine now to dispose of those • and allow these deadlines to be reset in notions. Md if there is a reasonable basis • conformance with a standard pretrial order Io upon disposition of those motions to for Your for a March 13th trial setting. II Honor to consider on a case-by-case basis -- TICE COURT: Thank you. 22 and that's the only way it should be done, 12 Ply intention was not to Open the 33 an extension of a deadline or an exception 11 floodgates to allow wholesale discovery, as Is to a deadline -- then Mr. Epstein. through •+ pointed out, and not -- it really wasn't ➢o 15 his very able counsel, has every aeons by ze nuch the Court's schedule, but respective it which to present those issues On a 14 counsel's vacation schedules, which took up IS case -by -case basis to the Court. But the 17 essentially a month of time where I wasn't le deadlines previously set should be enforced. able to set anything substantively during 19 Thank you, Your Honor. is that period and had to thereafter wait. 20 MS. ROCKENBACH: Your Honor, I want to 20 BeCause there la tine that Opens up and zi try this case on March 13th. zi 1 know -- or at least counsel that 22 THE COURT: We are going to try the 22 represented Hr. Epstein in the past -- they 23 Case on March 13th. 21 typically were amenable to setting things 24 MS. ROCXENBACH There's no question • s and getting hearings set if the COUrt had 21 that both parties are respecting this 2) tine open. Mr. Scarola and his office have 10 12 Court's order on November loth setting that always been very accommodating in that specifically. But as Your Honor has 2 regard. identified, these critical issues have yet SO it was not with the anticipation to be ruled on by this Court. that we are going to open the floodgates for Md Mr. Scarola makes my point in discovery to essentially recOMMenCe. raising the three claimants that Mr. Edwards 4 Again, it's a 2009 case. I know the previously represented and settled their counterclaim was filed a little bit later cases. That'➢ a very Significant 11See that than that, but It is an old case -- has an this court will rule on on Wednesday to appellate history -- that needs t0 get tried to determine whether their testimony is even in March. 11 relevant. So what I an going to do is this. IS I see that we're getting a preview 12 Because there are issues that need to be 13 about the fabrication issues. But I look 13 addressed -- and I'm hoping I will have II forward to Wednesday and discussing 14 it with Orders out as soon as passible after tho➢e IS the court. 13 hearing: are done -- is that I am going to la The attorneys that Mr. Scarola require notions to be filed on a discovery IT identifies as designated 17 for years. they issue-by-discovery Issue, deposition by le were not. they were fact witnesses and only 11) deposition, so as to find out several If recently identified as expert witnesses, so 13 things. One, is the need to take that 20 appropriate discovery was propounded and 20 deposition and whether that need has been 21 their depositions were requested. 21 either clarified or required by virtue of a 22 The new expert that Hr. Edwards has 22 court order that will be entered 23 listed -- brand-new expert 23 -- Is being subsequently to the conmencement of deposed this Friday, which incidentally is 24 Wednesday's hearings and thereafter on those 25 past the discovery cut-off date. 25 i think he day➢ that I provided. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00793357  13 15 If it cannot be demonstrated to the stipulation. Those issues are going to be • Court that these witnesses need to be taken 2 significantly impacted by the Court's legal 3 solely as a result the Court's ruling, then 1 rulings. 4 those requests will be denied, because, 4 THE COURT; I'm sorry. I didn't follow 5 again, we were set to try the case next S that. • week. eis. ROTKENSACH: lin sorry. 7 An0 but for the legal Issues that 7 Joint pretrial stipulation is Pa -- • retained and the feet that the Court did not 0 was due. In our response to Hr. tdweeds' • want to put anyone's back against the wall. unilateral pretrial stipulation. we noted to Including itself, in the short period of Io that based on the fact that Your Honor le it time that we had between trial and the 11 going to be making significant legal rulings 12 hearings that had been set, and those were 12 On November 29th, December 5th and le just for a ono-day period and not enough 13 December 7th, it was impossible for us t0 24 time -- It vas not contemplated that frame the issues to be tried In this case. IS discovery was going to be open again, at IS there are pending legal motions that Your 16 least on the wholesale basis. if Honor is going to be ruling on probably on SO 20 some-odd depOtiltion, unless they Wednesday. SO my request is that we be le can be proven and shown to the Court as is allowed additional tun following those it being required as a result of the rulings of 19 hearings to reconvene and arrive at a joint ie the Court, will not be entertained. They 20 pretrial Stipulation. 21 should have been done before. MO if not 21 THE COURT: All I can say is the 22 done before, I will need a reason for that 22 elements of malicious prosecution are well 23 as well. 23 set out In Florida law. 24 HS. ROCXENBACH: Thank you, Your Honor. rf MS. ROCHE/COACH: Agreed. xi Md so for clarification, that notion 23 THE COAT; And so anticipating 14 16 1 that Your Honor is referencing would be 1 witnesses CO testify as to those issues 2 filed after Your Honor's rulings on 2 shouldn't be en extraordinary tasks at this 3 November 29th or December 5th or point in time. December Ith? 4 What I was going to say is I recognize THE COURT: Meaning any notions that that those lints night be tailored in will be filed after the Court rulings accordance with the Court's rulings, but it relative to whether or not those deponents 1 shouldn't hold back -- just like pending or the discovery was occasioned by the notions in limine that are In every Case, Court's ruling? subsequent to -- either filed or filed 10 ROCHEIMIACH: Correct. 10 before or after the pretrial is filed and li THE COURT: Correct. We don't know II heard. Md It may reduce. increase or IS what that is going to be as of yet. whatever the number of witnesses, but it 13 MS. ROCKEHOACH: Thank you. Ii wouldn't Change the issues that have to be 11 And as far as the pretrial -- the joint 14 tried as it relates to a malicious 15 pretrial stipulation, Your Honor, my point prosecution action. Is in that was not knowing how the Court will Is MS. ROCICENOACH: I would tend to agree 21, rule on critical issues requires -- it 17 with Your Honor. However, the recent I, causes extreme uncertainty with regard to le filings by Mr. Edwards ihOw that perhaps It the issues to be tried. If there are a mixing or misunderstanding of 20 Mr. Scarola -- Mr. Edwards filed a 20 those legal elements as compared to a 21 unilateral pretrial stipulation. I am going 21 defamationCM. 22 to ask the Court to allow us to reconvene 21 SO I think this will be cleared up on 23 following the hearings that are pending 23 Wednesday when Your SOW sees our motion', 24 before and scheduled before Your Honor so 24 hears our acgusents, and substantively rules 23 that we can arrive at a joint pretrial 23 on the pending real issues to be tried. And Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00793358