EFTA00806733.pdf

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). NOTICE OF PRODUCTION FROM NON-PARTY TO: Tonja Haddad Coleman, Es uire Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 William Chester Brewer, Es uire 250 S Australian Avenue, Suite 1400 West Palm Beach, FL 33401 YOU ARE NOTIFIED that after ten (10) days from the date of service of this Notice, if service is by delivery, or fifteen (15) days from the date of service, if service is by mail, and if no objection is received from any party, the undersigned will issue or apply to the Clerk of this Court for issuance of the attached Subpoenas directed to the following individual to produce the items listed at the time and place specified in the Subpoena. 1. Joseph L. Ackerman, Esquire Fowler White Burnett, P.A. 515 N. Flagler Drive, Suite 2100 West Palm Beach, FL 33401 EFTA00806733 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Notice of Production from Non-Party Page 2 2. Robert D. Critton, Esquire 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 3. Jack A. Goldberger, Esquire Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 4. Roy Black, Esquire Black Srebnick Komspan and Stumpf, P.A. 201 South Biscayne Boulevard, #1300 Miami, FL 33131 1 HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this day of .9 -S t , 2017. JACK S Flori Atto Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorneys or ra ey . wards EFTA00806734 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Notice of Production from Non-Party Page 3 COUNSEL LIST William Chester Brewer, Es uire Tonja Haddad Coleman, Esquire 250 S Australian Avenue, Suite 1400 West Palm Beach. FL 33401 Tonja Haddad, P.A. Pho 315 SE 7th Street, Suite 301 Fax: Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein Phon Fax: Jack A. Goldberger, Esquire Attorneys for Jeffrey Epstein Mar lurilc, ii uire Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue S, Suite 1400 One E Broward Blvd., Suite 700 West P 401 Fort Lauderdale, FL 33301 Phone: Phone: Fax: Fax Attorneys for Jeffrey Epstein Attorneys br coit Koulslein Fanner Jaffe Weissing Edwards Fistos & Lehrman, P.L. 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: Fax: Fred Haddad, Es uire Fred Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Fax: Attorneys for Jeffrey Epstein EFTA00806735  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). SUBPOENA DUCES TECUM TO NON-PARTY THE STATE OF FLORIDA TO: Joseph L. Ackerman, Esquire Fowler White Burnett, P.A. 515 N. Flagler Drive, Suite 2100 West Palm Beach, FL 33401 YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 10, 2017 at 1:00 p.m. and to have with you at that time and place the following: Duces Tecum: All documents* regarding your representation of Jeffrey Epstein with respect to any allegation of criminal wrongdoing against Jeffrey Epstein and any consideration of and involvement in the filing prosecution of any claim by Jeffrey Epstein against Scott Rothstein and/or Bradley Edwards. EFTA00806736 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 2 *"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 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) 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. 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 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. If you fail to: 1) Appear as specified; or EFTA00806737 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The undersigned, as custodian of records for Joseph L. Ackerman, Esquire, certifies that the attached documents consisting of pages represents a true copy of all 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 , 2017, 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: EFTA00806738  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). SUBPOENA DUCES TECUM TO NON-PARTY THE STATE OF FLORIDA TO: Robert D. Critton, Esquire 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 6, 2017 at 1:30 p.m. and to have with you at that time and place the following: Duces Tecum: All documents* regarding your representation of Jeffrey Epstein with respect to any allegation of criminal wrongdoing against Jeffrey Epstein and any consideration of and involvement in the filing and prosecution of any claim by Jeffrey Epstein against Scott Rothstein and/or Bradley Edwards. •"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 EFTA00806739 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 2 compilations 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. "Documents" 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. 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 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. If you fail to: I) Appear as specified; or 2) Furnish the records instead of appearing as provided above; or 3) Object to this subpoena, EFTA00806740 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 3 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 day of 2017. Primary E-mail: Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach Florida 33409 Phone: Fax: Attorneys for Bradley Edwards EFTA00806741 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The undersigned, as custodian of records for Robert D. Critton, Esquire, certifies that the attached documents consisting of pages represents a true copy of all 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 , 2017, 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: EFTA00806742  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). SUBPOENA DUCES TECUM TO NON-PARTY THE STATE OF FLORIDA TO: Jack A. Goldberger, Esquire Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 6, 2017 at 10:30 a.m. and to have with you at that time and place the following: Duces Tecum: All documents* regarding your representation of Jeffrey Epstein with respect to any allegation of criminal wrongdoing against Jeffrey Epstein and any consideration of and involvement in the filing and prosecution of any claim by Jeffrey Epstein against Scott Rothstein and/or Bradley Edwards. EFTA00806743 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 2 *"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 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) 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. 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 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. If you fail to: 1) Appear as specified; or EFTA00806744 Edwards adv. Epstein Case No. 502009CA0401100XXXXMBAG Subpoena to Non•Party Page 3 2) Furnish the records instead of appearing as provided above; or 3) Object to this subpoena, 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 day of , 2017. Primary E-mail: Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Flnrirta 33409 Phone Fax: Attorneys for Bradley Edwards EFTA00806745 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The undersigned, as custodian of records for Jack A. Goldberger, Esquire, certifies that the attached documents consisting of pages represents a true copy of all 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 , 2017, 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: EFTA00806746  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 individually, Defendant(s). I SUBPOENA DUCES TECUM TO NON-PARTY THE STATE OF FLORIDA TO: Roy Black, Esquire Black Srebnick Komspan and Stumpf, P.A. 201 South Biscayne Boulevard, #1300 Miami, FL 33131 YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 6, 2017 at 3:30 p.m. and to have with you at that time and place the following: Duces Tecum: All documents* regarding your representation of Jeffrey Epstein with respect to any allegation of criminal wrongdoing against Jeffrey Epstein and any consideration of and involvement in the filing and prosecution of any claim by Jeffrey Epstein against Scott Rothstein and/or Bradley Edwards. EFTA00806747 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 2 *"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 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) 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. 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 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. If you fail to: 1) Appear as specified; or EFTA00806748 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 3 2) Furnish the records instead of appearing as provided above; or 3) Object to this subpoena, 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 day of , 2017. 7 JACK AR LA Fier' Ba o.: Attu e -Mail(s): ; and mm Primary E-mail: Searcy Denney Scarola Barnhart & Shipley. P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorneys or ra ey wards EFTA00806749 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The undersigned, as custodian of records for Roy Black, Esquire, certifies that the attached documents consisting of pages represents a true copy of all 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 , 2017, 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: EFTA00806750