EFTA01105824.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)OOCXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). SUBPOENA WITHOUT DEPOSITION THE STATE OF FLORIDA TO: Jack A. Goldberger, Esquire YOU ARE COMMANDED to appear at Searcy Denney Scarola Bamhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 10, 2013 at 9:00 a.m. and to have with you at that time and place the following: Duces Tecum: All documents* reflecting any and all communications between you (or anyone acting on your behalf) and Jeffrey Epstein (or anyone acting on his behalf) which communication related directly or indirectly to the basis for and/or the viability of any claim by Epstein against Bradley Edwards. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the EFTA01105824 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Pagc2 scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. *The term "documents" includes but is not limited to all non-identical copies of letters, notes, memoranda, e-mails, faxes, records, transcripts, and entries, regardless of whether they were made manually, mechanically, electronically, magnetically, digitally, or by any other means, and regardless of whether they are on papers, tape, film, electronic devices, electronic media, as well as application metadata and system metadata, or any other media or thing. If you fail to: 1) Appear as specified; or 2) Furnish the records instead of appearing as provided above; or 3) Object to this subpoena, EFTA01105825 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page3 You may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED this I Pe— day of September, 2013. Jack a Flof arNo.: 169440 Pr' E-mail: ndary E-mail(s): earcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West P a 33409 Phone: Fax: Attorneys for Bradley J. Edwards EFTA01105826 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The undersigned, as custodian of records for , certifies that the attached documents consisting of pages represents a true copy of g items within my possession, custody or control which are described in the Subpoena Duces Tecum Without Deposition served on me in the above styled action and each page is numbered by me for identification. Production is complete and has been numbered by the custodian of records. It is further certified that originals of the items produced are maintained under the direction, custody and control of the undersigned. The foregoing Certification was acknowledged before me, an officer duly authorized in the State and County aforesaid to take acknowledgments, this day of 20_, who: is personally known to me; or has produced as identification; and who: did or did not, take an oath, and who executed the foregoing certification, and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited. Notary Public, State of Florida at Large My Commission Expires: EFTA01105827 Edwards adv. Epstein Case No. 502009CA0408003OOOCMBAG Subpoena to Non-Party Page5 COUNSEL LIST Jack A. Goldberger, Esquire Attorneys for Scott Rothstein [email protected]; [email protected] Tonja Haddad Coleman, Esquire Atterbtuy, Goldberger & Weiss, P.A. [email protected]; 250 Australian Avenue South, Suite 1400 [email protected] West Palm Beach, FL 33401 Tonja Haddad, P.A. Phone: (561)-659-8300 315 SE 7th Street, Suite 301 Fax: (561)-835-8691 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein Phone: (954)467-1223 Fax: (954)-337-3716 Bradley J. Edwards, Esquire Attorneys for Jeffrey Epstein [email protected] Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, FL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (954) 524-2822 Fred Haddad, Esquire [email protected]; [email protected] Fred Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: (954)467-6767 Fax: (954)467-3599 Attorneys for Jeffrey Epstein Marc S. Nurik, Esquire [email protected] Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 EFTA01105828