EFTA01107608.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT EPSTEIN'S RESPONSES TO INTERROGATORIES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure hereby files his responses to Defendant/Counter-Plaintiff Bradley Edward's Interrogatories to Jeffrey Epstein: A. With regard to all communications that occurred at any time prior to the filing of your civil lawsuit against Bradley Edwards in which communication you expressed the position that Bradley Edwards was a knowing participant in the efforts of Scott Rothstein to defraud investors (the Scott Rothstein Ponzi scheme) or that Bradley Edwards engaged in any misconduct relating to the Scott Rothstein Ponzi scheme, state the following: 1. a detailed description of the contents of the communication; 2. all participants in and parties to the communication; 3. the date, time, place and circumstances of the communication EFTA01107608  including how the communication was made; 4. whether, when, how and why the contents of the communication were ever subsequently related to any other person; 5. whether and how the contents of the communication were ever memorialized in any manner and, if so, the identity of everyone having custody of such memorialization. ANSWER: Objection. The answer to this interrogatory requires the disclosure of information absolutely protected from such disclosure by the attorney/client privilege. Any communication to which the attorney-client privilege attaches is "absolutely immune from disclosure." United Services Auto. Ass 'n. v. Roth, 859 So. 2d 1270, 1271 (Fla. 4th DCA 2003). The attorney-client privilege is a privilege that cannot be overcome. See Nevin v. Palm Beach County School Bd., 958 So. 2d 1003 (Fla. 1st DCA 2007). Accordingly, I assert the attorney/client privilege as provided for in § 90.502 of the Florida Statutes. B. With regard to any request, direction, or authorization to sue Bradley Edwards communicated by you at any time prior to the filing of your civil lawsuit against Bradley Edwards, state the following: 1. a detailed description of the contents of the communication; 2. all participants in and parties to the communication; 3. the date, time, place and circumstances of the communication including how the communication was made; 4. whether, when, how and why the contents of the communication were ever subsequently related to any other person; 5. whether and how the contents of the communication were ever memorialized in any manner and, if so, the identity of everyone having custody of such memorialization. ANSWER: Objection. This interrogatory asks for the disclosure of EFTA01107609  information absolutely protected by the attorney/client privilege. Any communication to which the attorney-client privilege attaches is "absolutely immune from disclosure." United Services Auto. Ass 'n. v. Roth, 859 So. 2d 1270, 1271 (Fla. 4th DCA 2003). See Nevin v. Palm Beach County School Bd., 958 So. 2d 1003 (Fla. 1st DCA 2007). Accordingly, I assert the attorney/client privilege as provided for in § 90.502 of the Florida Statutes. WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this September 20, 2013. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONIA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale Florida 33301 EFTA01107610  SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . ; Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . ; Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradle , dwards, E . Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Es 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Ton'a Haddad Coleman, Esquire Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein EFTA01107611