EFTA00724396.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL' CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Ha. R. Civ. Pro.1201 Plaintiff, v. Case No. 50 2009CA040800,OOO(MB AG SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. gPSTEIN'S REQUEST TO PRODUCE TO EDWARDS Defendant, JEFFREY EPSTEIN ('Epstein'), pursuant to Fla. R. Civ. P. 1.350, requests that Defendant, BRADLEY J. EDWARDS (*Edwards"), produce or make available for inspection documents responsive to the requests below within thirty (30) days from the date of service: DEFINITIONS AND INSTRUCTIONS A. "Document' means any written or graphic matter or other means of preserving thought or expression, and all tangible things from which Information can be processed or transcribed, including the originals and all non-Identical copies, whether different from the original by reason of any notation made on such copy or otherwise, including, but not limited to, correspondence, memoranda, notes, messages, letters, purchase orders, telegrams, teletype, telefax bulletins, s-mails, electronic data, meetings, reports, or other communications, interoffice and intro-office telephone calls, diaries, chronological data, minutes, books, reports, charts, ledgers, invoices, worksheets, receipts, returns, trade information regarding fabric, carpets, samples EFTA00724396  etc..., computer printouts, prospectuses, financial statements, schedules, affidavits, contracts, cancelled checks, transcripts, statistics, surveys, magazine or newspaper articles, releases (and any and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphs or aural records or representations of any kind, including, without limitation, photographs, charts, graphs, microfiche, microfilm, video tape, recordings, motion pictures and electronic, mechanical or electric recordings or representations of any kind (including, without limitation, tapes, cassettes, discs and recordings), and including the file and filo cover. The term "Document" also means any and all computer records, data, files, directories, electronic mail, and information of whatever kind whether printed out or stored on or retrievable from floppy diskette, compact diskette, magnetic tape, optical or magnetic-optical disk, computer memory, hard drive, zip drive, Jaz drive, orb drive, microdisk, external memory stick, software, or any other fixed or removable storage media, including without limitation, all back-up copies, dormant or remnant files, and any and all miscellaneous files and/or file fragments, regardless of the media on which they reside and regardless of whether the data consists in an active file, deleted file, or file fragment. B. "Communications" means any oral or written statement, dialogue, colloquialism, discussion, conversation or agreement. C. "Plaintiff' means L.M. (LM. v. Jeffrey Epstein, Palm Beach County Case #502008CA028051XXXXMB), E.W. (E.W. v. Jeffrey Epstein, Palm Beach County Case #502008CA028058XXXXMB), Jane Doe (Jane Doe v. Jeffrey Epstein, United States District Court Case #08-civ-80893-Marra/Johnson), and any other person who is or was represented by Rothstein Rosenfeldt & Adler that has not 2 EFTA00724397  for yet filed an action against Jeffrey Epstein, and any employee, agent or attorney any plaintiff andfor any other person acting for or on behalf of any plaintiff, or under her authority and control. D. "RRA' means Rothstein Rosenfeldt & Adler, P.A. E. "Money" means any tangible thing of value. F. "Costs" include, but are not limited to, court costs, filing fees, Sheriffs service and any other necessary service of legal papers or notices or subpoenas, court reporters' charges, long distance telephone charges, postage, courier services or Federal Express or UPS, investigative costs, investigative bills, photocopies, faxes, Westlaw computerized research, travel expenses, and witness fees and expert witness fees and costs. G. "Trustee" means Herbert Stettin as bankruptcy trustee for RRA. REQUEST FOR PRODUCTION' 1. For the time period from March 1, 2009 to present any and all documents between, or on behalf of RRA, its employees or agents or clients, and any third party regarding a purported settlement of any litigation between Jeffrey Epstein and a RRA client or Plaintiff, or the financing of any litigation between Jeffrey Epstein and a RRA client or Plaintiff, (whether existing clients or fabricated clients), including but not limited to: a. Documents indicating that litigation with Jeffrey Epstein has been settled; b. Soliciting or receiving money in return for settlement funds allegedly paid or to be paid by Jeffrey Epstein; c. Soliciting money to help finance ongoing litigation against Jeffrey Epstein; d. Soliciting money to be given to, or used on behalf of, the Plaintiffs in litigation against Jeffrey Epstein; e. Communication between third party investors or potential investors and the Plaintiffs or their attorneys involved in litigation against Due to the potential volume of documents involved, the parties and the Court should consider appointment of a special master andlor an In camera Inspection to address any objections, claims of pdvllege and generally manage the production of documents. 3 EFTA00724398  Jeffrey Epstein; f. Payments made by RRA to or on behalf of any Plaintiff. 2. Any and all fee agreements that exist or have existed between the following: a. Any Plaintiff and Bradley J. Edwards or any entity with which he has been associated; b. Any Plaintiff and the law firm RRA. 3. All emails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (Including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All emalls, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, and/or any attorney or representative of RRA regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 5. All agreements or documents of any nature which were provided to or received from an investor or potential Investor relating to any case (real or fabricated) Involving Jeffrey Epstein and any of the following: a. Scott W. Rothstein b. Bradley J. Edwards c. RRA e. any entity formed by RRA or Bradley J. Edwards or Scott W. Rothstein to create investment opportunities for third party investors to Invest in any plaintiffs case against Jeffrey Epstein 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiffs case. . 7. All documents made available to any investor or potential investor by Bradley J. Edwards, RRA, Scott W. Rothstein or any of Scott W. Rothstein's entities to solicit "Investors" for any case involving Jeffrey Epstein. 8. All document reflecting the names and addresses of all individuals or entities who invested or purported to invest In any aspect of any case against Jeffrey Epstein. 9. AU documents evidencing the Costs and payment of any bill or Costs in each Plaintiffs case against Jeffrey Epstein, and the source(s) for said payments of any Costs. 4 EFTA00724399  firm wherein the Trustee of 10. All documents received by you or your current arising out of work done and Costs RRA has asserted a lien for attorney's fees or Costs time Plaintiffs' were represented by incurred related to the Plaintiffs' cases during the RRA. from the trash at 358 El Brillo 11. All documents and tangible things retrieved of Jeffrey Epstein. Way, Palm Beach, Florida which is alleged to be the home which purported to be that 12. All conversations recorded from any telephones tapes, CDs, DVDs, zip drives, of Jeffrey Epstein that are contained In any media (audio transcriptions). hard drives or any other electronic format and any written purported to be 13. All conversations recorded from any telephones which , Alan Dershowitz or Jack from Jeffrey Epatein's attorneys including Roy Black , CDs, DVDs, zip drives, hard Goldberger, that are contained in any media (audio tapes riptions). drives or any other electronic format and any written transc including but not 14. All intercepted phone conversations authorized by RRA or working for anyon e retain ed by limited to any one of its attorneys or investigators or media (audio tapes, CDs, any RRA related to Jeffrey Epstein that are saved or stored in forma t and any written onic DVDs, zip drives, hard drives or any other electr transcriptions). -mails) to or from Jeffrey 15. All intercepted or acquired electronic mail (e d to any one of its attorneys or Epstein authorized by RRA including but not limite investigators or anyone retained by or working for RRA. ils) to and from the 18. All Intercepted or acquired electronic mall (e-ma Black, Alan Dershowitz or attorneys for Jeffrey Epstein including but not limited to: Roy d to any one of its attorneys Jack Goldberger, authorized by RRA including but not limite or investigators or anyone retained by or working for RRA. l assault took place 17. All documents supporting the contention that a sexua in or a Jeffre y Epste in entity at any on an airplane purportedly owned by Jeffrey Epste time between 1998 and 2005. were incurred by you 18. AU documents related to the amount of all Costs that sentin g Jane Doe, L.M. and in the representation of you and/or your law firm in repre E.W. prior to joining RRA. were incurred by RRA 19. All documents setting forth to the amount of Costs time you were employed by in its representation of Jane Doe, L.M. and E.W. during the RRA (or that is being claimed by the Trustee). to Judge Hafele 20. In the attached transcript dated July 31, 2009, you stated with regard to the E.W. and L.M. cases the following: 5 EFTA00724400  Mr. Epstein — at "What the evidence is really going to show is that rces have permitted, least dating back as far as our Investigation resou Ilfe, made an attempt to back to 1997 or '98 — has every single day of his sexually abuse children. 20, we're not We're not talking about five, we're not talking about I believe, is the talking about 100, we're not talking about 400, which about thousands of number known to law enforcement, we are talking te and comp licate d system that he children, and it is through a very intrica e workin g under neath him that devised where he has as many as 20 peopl girls.° ts, to locate these he is paying well to schedule these appointmen tion including any (A) Provide all documents to support this asser documents which are the source of the information. ents in the Jane 21: All documents related to or mentioning potential depon Doe, L.M. or E.W. cases. counterclaim in 22. All documents that support your claim of damages In your this case. Denney firm for their 23. The written fee agreement with the Searcy representation of you In this case. lf) and one or 24. All emails exchanged between you (or anyone of your beha billionaire or a similar more of the following Individuals wherein Epstein, a Palm Beach reference was mentioned: a. Scott Rothstein b. Russell Adler c. William Berger d. Michael Paten e. Kenneth Jenne f. David Boden g. Deborah Vilieges h. Andrew Barnett i. Patrick Roberts J. Richard (Rick) Fandrey k. Christina Kitterman. 25. A copy of your RRA business card. given to you 26. Any employment agreements, letter agreements or memos compensation and benefits by RRA or a representative or agent of RRA describing your at RRA. 6 EFTA00724401  Stettin, as bankruptcy 27. All documents and communications from Herbert Trustee for RRA, asserting liens against recoveries in: MB a. L.M. v. Epstein, Case No. 502008CA028051)000( E.W. v, Epstein Case No. 502008CA0 28058 )00(X MB b. JOHNSON -8011 9-MA RRA/ c. Jane Doe v. Epstein Case No. 08-CV Certificate of Service was sent by fax and U.S. I HEREBY CERTIFY that a true copy of the foregoing , 2010: Mail to the following addressees on this 12th day of April Gary M. Farmer, Jr., Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Welssing, Edwards, Fistos Atterbury Goldberger & Weiss, P.A. & Lehrman, PL 250 Australian Avenue South 425 N. Andrews Avenue, Suite 2 Suite 1400 Fort Lauderdale, FL 33301 West Palm Beach, FL 33401-5012 954-524-2820 Fax: 561.835-8691 954-524-2822 - fax Co-Counsel for Defendant Jeffrey Epstein Attorneys for Defendant, LM. Jack Scarola, Esq. MARC S. NURIK, ESQ. Searcy Denney Scarola Barnhart & Law Offices of Marc S. Murk Shipley, P.A One East Broward Boulevard 2139 Palm Beach Lakes Blvd. Suite 700 West Palm Beach, FL 33409 Fort Lauderdale, FL 33301 686-6300 954-745-5849 383-9424 F 954-745-3556 Fax Attorneys for Defendant Bradley Edwards Attorneys for Defendant Scott Rothstein BURMAN, CRITTON, LUTHER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 West Pal 33401 (561) (561) By: o D. ritton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) 7 EFTA00724402  0001/005 Will/2010 1$:59 FAX $61.6845810 SF.AECY DENNEY IN THE CIRCUIT COURT OF TIIE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)C<XXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, Individually, BRADLEY J. EDWARDS, individually, and L.M., Individually, Defendant. TO PLAINTIFF'S REQUEST DEFENDANT BRADLEY J. EDWARDS RESPONSE FOR PRODUCTION DATED APRIL 12. 2010 Response to Request for Defendant, BRADLEY J. EDWARDS, hereby files his follows: Production propounded by Plaintiff on April 12, 2010 as 1 None. to the a. Objection, relevance, not reasonably calculated to lead discovery of admissible evidence. b. None. rs as that Is 3. Objection as to communications to or from investigato ey-clie nt privile ge. protected by the work-product and /or attorn the work-product 4. Objection; any such communications are protected by and /or attorney-client privilege. 5. None. to lead to the 6. Objection, relevance, not reasonably calculated without waiving discovery of admissible evidence; vague; overbroad, objection, there are no fee agreements with any investor. EFTA00724403 05/11/2010 18:59 FAX 5016845810 SEARCY DENNEY 0002/005 Case No.: 502009CA041)800XXXXMBAO Edwards' Response to Request for Production dated 4/12110 7. None. 8. None. 9. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence. 10. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence. 11. None. 12. None. 13. None. 14. None. 15. None. 16. None. 17. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence; vague; overbroad, ambiguous. 18. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence. 19. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence and protected by the work-product privilege. 20. Objec0en, vague overbroad and any and all such documents are protected by the work-product privilege. 21. Objection, vague overbroad and any and all such documents are protected by the work-produ ct and attorney-client privilege. 22. Not yet determined. 2 • EFTA00724404 06/11/2010 18:00 FAX 5818846816 SEARCY DENNEY VI003/005 Case No.: 502009CA040800XXXXMEtAG Edward,' Response to Request for Production dated 4/12/10 23. Objection. 24. Objection; attorney-client privilege and/or work-product privilege. 25. None In Defendants possession. 28. None. 27. None in Defendant's possession. 3 EFTA00724405  tossioes 08/11/2010 18:00 FAX 8818845810 SEARCYDENIM G Case No.: so2oo$CAimoaeoxXXXMHA Prod uction dated 4112/10 Edwards' Resp onse to Req uest for CERTIFICATE OF SERVICE been and correct copy of the foregoing has I HEREBY CERTIFY that a true 611c44,Th the attached list on IA% In010. furnished viaU.S. Mail to all counsel on Jack Scarola Shipley. PA Seamy Denney Scamla Barnhart & Attorneys for Defendant, Bradley Edwards 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 666-6300 Fax: (561 1 4-/Ca / %1 BY: Jack tar No.: atter° 4 EFTA00724406 05711/2010 16:00 FAX 5616665616 SEARCY DENNEY e005/006 Case No.: 502000CA040800XXXXMBAG Edwards' Response to Request for Production dated 02/10 COUNSEL LIST Robert D. Critton, Jr., Esquire Michael J. Pike, Esquire Burman, Critton, LutUer & Coleman LLP 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 Phone: (561)-842-2820 Fax: (561)-844-8929 Attorneys for Jeffrey Epstein Jack Goldberger Atterbury, Goldberger & Weiss, PA. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659.8300 Fax (561)-835-8691 Attorneys for Jeffrey Epstein Gary M. Farmer, Jr. Fanner, Jaffe, WelssIng, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (964) 524-2822 Attorneys for L.M. Marc Nurik Law Offices of Marc S. Nurik One East Broward Boulevard, Suite 700 Fort Lauderdale, FL 33301 Phone: 954-745-5849 Fax: 954-745-3556 Counsel for Scott Rothstein 6 EFTA00724407