EFTA00795460.pdf

#291874/mep 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). / REQUEST TO PRODUCE TO i STEIN Defendant/Counter-Plaintiff, Bradley J. Ed rtJ,f bind through his undersigned counsel, requests, pursuant to Rule 1.350 of the Flo( of Civil Procedure, that Plaintiff/Counter Defendant, Jeffrey Epstein, produce a rmit c( radley J. Edwards to inspect and copy each of the following documents*: 1. All document con #Eating, reflecting, or relating to communications between Plaintiff or any nt of Plaintiff, on the one hand, and William Scherer, or any person associate th William Scherer in the practice of law, any prosecuting, law enforcement, edfiment entity which communication relates directly or indirectly to any e gage: of illegal activity or tortuous conduct in which Epstein is alleged to have + *"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 compilations from which information can be obtained, translated, if necessary, by the party to EFTA00795460 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Request to Produce to Jeffrey Epstein whom the request is directed through detection devices into reasonably usable form. "Documents" also include all electronic data as well as application metadata and system metadata. All inventories and rosters of your information technology (IT) syiteMs—e.g., hardware, software and data, including but not limited to network drawings f computing devices (servers, PCs, laptops, PDAs, cell phones. with data stor r transmission features), programs, data maps and security tools and protocols. It is requested that the aforesaid production be made irty days of service of this .request at the offices of Searcy Denney Scarola Ba pley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida. on will be made by visual observation, examination and/or copying. I HEREBY CERTIFY that a ct copy of the foregoing has been furnished by Fax and U.S. Mail to all Counsrel ched list, this ) )lay of pril, 2911. O Attorneys for Bradley J. Edwards 2 EFTA00795461 Edwards adv. Epstein Case No.: 502009CA040800XXXXPABAG Request to Produce to Jeffrey Epstein COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. Attorney For: Jeffrey Epstein Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL Attorney For: Jeffrey Epstein Marc S. Nurik Law Offices of Marc S. Nurik Attorney For: Scott Rothstein 3 EFTA00795462