EFTA00801993.pdf

EXHIBIT A EFTA00801993 #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 .IEFPREY EPSTEIN Defendant/Counter-Plaintiff, Bradley J. EdwitAls by.and through his undersigned counsel, t requests, pursuant to Rule 1.350 of the Floc• ttle's Of Civil Procedure, that Plaintiff/Counter A Defendant, Jeffrey Epstein, produce aI 't, radley J. Edwards to inspect and copy each of the following documents*: 1. All documen SC conytifuting, reflecting, or relating to communications between Plaintiff or any awn of Plaintiff, on the one hand, and William Scherer, or any person associate,ckiith Villliam Scherer in the practice of law, any prosecuting, law enforcement, and/or goveitiment entity which communication relates directly or indirectly to any allegation of illegal activity or tortuous conduct in which Epstein is alleged to have engaged. *"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 EFTA00801994 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) systetns--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. It is requested that the aforesaid production be made within thirty days of service of this .request at the offices of Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida. Inspection will be made by visual observation, examination and/or copying. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Fax and U.S. Mail to all CounseIon the attached list, t ay of pril, 2t 11. r No.: 169440 enney Scarola Barnhart & Shipley Palm Beach Lakes Boulevard est Palm Beach Florida 33409 Phone: Fax: Attorneys for Bradley J. Edwards 2 EFTA00801995 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Request to Produce to Jeffrey Epstein COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. Attorney For: Jeffrey Epstein 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Pho Fax: Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL Attorney For: Jeffrey Epstein 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Pho Faxl Marc S. Nurik Law Offices of Marc S. Nurik Attorney For: Scott Rothstein One E Broward Blvd., Suite 700 , Fort Lauderdale, FL 33301 Pho Fax: Joseph L. Ackerman, Jr., Esquire Fowler White Burnett, P.A. Attorney. For: Jeffrey Epstein 901 Phillips Point West 777 S Flagler Drive West Pidm Beach, FL 33401-6170 Pho Fax: 3 EFTA00801996 EXHIBIT B EFTA00801997  IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800,OOOCMBAG JEFFREY EPSTEIN, Plaintiff, vs. I SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and C .._, n • To L.M., individually, 2 n c ... <CDC --C:-"C r- - fl Defendant, C") f>..) `" r" REQUEST FOR PRODUCTION TO COUNTER-DEFENDANT (PUNITIVE DAMAGES? BRADLEY J. EDWARDS, by and through his undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, hereby requests Production from JEFFREY EPSTEIN of the documents and things described below for the purpose of inspection, copying, photographing, testing or sampling and any other purposes permitted under the Florida Rules of Civil Procedure at the office of the undersigned within thirty (30) days of service of this request. DEFINITIONS AND INSTRUCTIONS: A. The term "documents" as used in this Request is defined as including, but not limited to, the original and any non-identical copy (which is different from the original because of notations on such copy or otherwise) of all correspondence, telegrams, teletype messages, contracts (including drafts, proposals and any and all exhibits thereto), draft minutes and addenda, memoranda (including inter and intra office memoranda), memoranda for file, pencil jottings, diary entries, desk calendar entries, reported recollections and other written form of _EXHIBIT EFTA00801998 Edwards adv. Epstein Case No.: 502009CA040800XJOO(MBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 2 of 12 notation of events or intentions, transcripts and recordings of conversations and telephone calls, books, records, photographs, reports, tabulations, charts, books of account, ledgers, invoices, financial statements, purchase orders, receipts, canceled checks and other documentary material not subject to attorney/client privilege, together with any documents thereto, or enclosures therewith. The term "document" shall include data stored, maintained or organized electronically or magnetically through computer equipment, translated, if necessary, by you into comprehensible form. The term "document includes the complete file or files within which any items constituting a "document" are found, including all such files within your possession, custody or control wherever located, including any branch, local or main offices, and including not only the contents of such files but also the folder, jacket, envelope or other container in which the file is kept or stored. Each draft, final document, original, reproduction, and each signed and unsigned document and every additional copy of such document where such copy contains any commentary, note, notation or other change whatsoever that does not appear on the original or on the copy of the one document produced shall be deemed and considered to constitute a separate document. B. As used herein, the following words shall have the meanings indicated: (i) "Plaintiffs" in addition to the Plaintiffs named in the full style of this action, shall include any attorney, officer, director, employee or agent of EFTA00801999 Edwards adv. Epstein Case No.: 502009CA040800)ODONBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 3 of 12 Plaintiffs or any other persons acting under Plaintiffs' control or supervision, or in concert or association with Plaintiffs. "Defendant", in addition to the Defendant named in the full style of this action, shall include any attorney, officer, director, employee or agent of the Defendant or any other persons acting under Defendant's control or supervision, or in concert or association with the Defendant. "You" shall include the person (as defined below) or party to whom this Request is addressed and additionally all of his/her/its agents, officers, directors, employees, and other persons acting or purporting to act on his/her/its behalf, and includes also, to the extent there is no actual privilege, his/her/its attorneys. (iv) "Person" means any natural individual in any capacity whatsoever or any entity or organization, including divisions, departments, and other units herein, and shall include, but not be limited to, public or private t. corporations, partnerships, joint ventures, voluntary or unincorporated a associations, organizations, proprietorships, trusts, estates, governmental agencies, commissions, bureaus, or departments, and the agents, servants and employees of same. (v) "Concerning" includes referring to, responding to, relating to, connected with, regarding, discussing, analyzing, showing, describing, reflecting, employing and constituting. EFTA00802000 Edwards adv. Epstein Case No.: 502009CA0401300)OOaMBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 4 of 12 (vi) "Evidencing" means having a tendency to show, prove, or disprove. (vii) "Communication" means any oral or written statement, dialogue, colloquy, discussion or conversation, and also means any transfer of thoughts or ideas between persons by means of documents and includes any transfer of data from one location to another by electronic or similar means. (viii) "Including" shall mean including hut not limited to. (ix) The words "and" and "or" as used herein shall be construed either disjunctively or conjunctively as required by the context to bring within the scope of this production request any answer that might be deemed outside its scope by another construction. (x) "Related to" or "relating to" shall mean directly or indirectly, refer to, reflect, describe, pertain to, arise out of or in connection with, or in any way legally, logically, or factually be connected with the matter discussed. C. This Request calls for production of all responsive documents in your possession, custody or control without regard to physical location of said document. Control means in your possession, custody or control or under your direction, and includes in the possession, custody or control of those under the direction of you and your employees, subordinates, counsel, accountant, consultant, expert, parent or affiliated corporation, and any person purporting to act on your behalf. EFTA00802001 Edwards adv. Epstein Case No.: 502009CA040800)OOOCMBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 5 of 12 D. All documents shall be originals unless otherwise indicated. If your original is a photocopy or other copy, then the photocopy shall be produced as the original. E. Unless another time period is specified, this Request is addressed to documents created in the past five years from the date of this Request, and ending on the date of compliance with this Request. F. If you possess no documents responsive to a paragraph in this Request, state this fact, specifying the paragraph concerned. G. If you object in part to any Request, produce the portion of the documents requested to which you do not object, and state your objections to the remainder. H. As required by Florida Rule of Civil Procedure 1.280(b)(5), if you (including your attorneys and agents) arc withholding information otherwise discoverable under these rules by claiming that it is privileged or subject to protection as trial preparation material, you (including your attorneys and agents): ' (i) Shall make the claim expressly and shall describe the nature of the documents, communications, or things not produced or disclosed in a manner that, without revealing the information itself privileged or protected, will enable the party seeking discovery through this Request to assess the applicability of the privilege or protection. (ii) Provide a brief description of the document, including (a) the date of the document; (b) number of pages, attachments and appendices; (c) the names of its author, authors, preparers and an identification by employment and title of each EFTA00802002 Edwards adv. Epstein Case No.: 502009CA040800XMCvlBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 6 of 12 such person; (d) the name of each person who has sent, shown, or blind carbon copies of the documents, or has had access to or custody of the documents, together with an identification of each such person, and (e) in the case of any document relating or referring to a meeting or conversation, an identification of such meeting or conversation. -14 I. When appropriate, the singular form of a word should be interpreted in the plural as may be necessary to bring within the scope hereof any documents which might otherwise be construed to be outside the scope hereof. CONTINUING REQUEST This is a continuing request for the production of documents to the extent allowed by Florida Rule of Civil Procedure 1.280(c). At such time as you become aware of the existence of any additional documents responsive to this Request so that your response was not complete when made, you arc hereby requested to produce such documents promptly. DESTROYED DOCUMENTS If any documents responsive to this Request were at one time in existence, but have been lost or destroyed, a list should be provided of the documents so lost or destroyed stating the following information for each such document: (a) the type of document; (b) the date on which it ceased to exist, (c) the circumstances of its loss or destruction; (d) the identity of all persons having knowledge; and (e) the identity of all persons having knowledge of its contents. EFTA00802003 Edwards adv. Epstein Case No.: 502009CA040800)OOOGvIBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 7 of 12 MANNER OF PRODUCTION Pursuant to Rule 1.350, you should produce the original documents in the form, order and manner in which they are maintained in your files or the files of other persons under your control. In this connection, and for purposes of illustration, documents are to be produced in the file folder and file cartons in which they have been maintained or stored, clipped, stapled or otherwise arranged in the same form and manner as they were found. In the alternative, you should segregate all documents according to the specifications of this Request, and should organize and label each group of documents with the appropriate specifications prior to production. If any document is responsive to more than one specification of this Request, it should be labeled to reflect each specification to which it is responsive. `~ REQUESTS FOR PRODUCTION 1. Please produce all,Financial Statements prepared for or submitted to any Lender or Investor for the past five (5) years by you personally or on your behalf or on behalf of any entity in which you hold a controlling interest. 2. Please produce the W-2's and any other documents reflecting any income (including salary, bonuses, dividends, profit distributions, and any other form of income), including all gross and net revenue received by you directly or indirectly for the past five (5) years. 3. All tax returns filed with any taxing entity during the past five (5) years by you or on your behalf, or on behalf of any entity in which you hold or held a controlling interest at the time of filing. EFTA00802004 Edwards adv. Epstein Case No.: 502009CA040800,OOOCMBAGt Request to produce to Jeffrey Epstein (Punitive Damages) Page 8 of 12 4. All bank statements or other financial statements which were prepared by or received by you, or on your behalf or by or on behalf of any entity in which you had an ownership interest of 10% or more at any time during the past five (5) years. 5. All financial statements which were prepared by you or on your behalf, or by or on behalf of any entity in which you held an ownership interest of 10% or more at any time during the past five (5) years. 6. The deeds and titles to all real property owned by you or held on your behalf either directly or indirectly at any time during the past five (5) years. 7. All passbooks with respect to all savings accounts, checking accounts and savings and loan association share accounts owned by your or on which you hold a right or have a held a right to withdraw funds at any time during the past five years. 8. All passbooks with respect to all savings accounts, checking accounts and savings loan association share accounts, owned by you in whole or in part jointly as co-partner, or joint venture, in any business enterprise, or owned by an entity in which you have or have had a controlling interest at any time during the past 5 years. 9. The most recent bank ledger sheets in your possession, or accessible by you on the Internet, with respect to all bank accounts in which you have a right to withdraw funds. 10. The most recent bank ledger sheets in your possession, or accessible by you on the interest, with respect to all bank accounts owned by you solely, or jointly as co-partner, or joint venture, in any business enterprise, or owned by any entity in which you have a controlling interest. EFTA00802005 Edwards adv. Epstein Case No.: 502009CA040800X2OCXMBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 9 of 12 11. All checkbooks for all accounts on which you were authorized to withdraw funds for the past five (5) years. 12. All corporate securities (stocks or bonds) owned by you, directly or indirectly. 13. The latest available balance sheets and other financial statements with respect to any and all business enterprises of whatever nature in which you possess any ownership interest of 10% or more, whether as partner, joint venture, stockholder, or otherwise. 14. Your accounts receivable ledger or other company records which sets forth the names and addresses of all persons or business enterprises that are indebted to you and the amounts and terms of such indebtedness. ihe 15. Copies of the partnership or corporate income Tax Returns for any partnership or corporation in which you do possess or have possessed any ownership interest of 10% or more whether as partner, joint venture, stockholder or otherwise, for the last five (5) years. 16. The title certificates, registration certificates, bills of sale, and other evidences of ownership possessed by you or held for your beneficial interest with respect to any of the following described property owned by you or held directly or indirectly for your beneficial interest: a. Motor vehicles of any type; b. Commercial, business or construction equipment of any type; and c. Boats, launches, cruisers, planes, or other vessels of any type. 17. All records pertaining to the transfer of any money or property interests or financial interests made by you in the past 5 years. EFTA00802006 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 10 of 12 18. Any and all memoranda and/or bills evidencing the amount and terms of all of your current debts and obligations. 19. All records indicating any and all income and benefits received by you from any and all sources for the past 5 years. 20. Copies of any and all brokerage account statements or securities owned by you individually, jointly with any person or entity or as trustee, guardian or custodian, for the past 5 years, including in such records date of purchase and amounts paid for such securities, and certificates of any such securities. 21. All records pertaining to the acquisition, transfer and sale of all securities by you or on your behalf for the past 5 years, such records to include any and all information relative to gains or losses realized from transactions involving such securities. 22. All policies of insurance in which you or any entity controlled by you is the owner or beneficiary. 23. Copies of any and all trust agreements in which you are the settlor or beneficiary together with such documents necessary and sufficient to identify the nature and current value of the trust res. O EFTA00802007 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 11 of 12 I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this Zi day of ‘ 114‘1", 20 II/ 1 JAC. OLA Fl ar No.: 169440 P E-mail: ndary E-mail(s) Searcy Denney Scarola Barnhart & Shipley, PA. 2139 Palm Beach Lakes Boulevard West Palm Beach Florida 33409 Phon Fax: Attorney for gic .1 Edwards EFTA00802008 Edwards adv. Epstein Case No.: 502009CA0401100)OOCGIBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 12 of 12 COUNSEL LIST Lilly Ann Sanchez, Esquire [email protected] Atterbury, Goldberger & Weiss, P.A. The L-S Law Firm 250 Australian Avenue South, Suite 1400 1441 Brickell Avenue, 15th Floo West Palm 3401 Miami, Phon Pho Fax: Fax: Attorneys for Jeffrey Epstein Attorneys for Jeffrey Ep Farmer, Jaffe, Weissing, Edwards, Fistos Tonja Haddad, Lehrman, FL 315 SE 7th Street, Suite 301 425 North Andrews Avenue, Suite 2 P Lauderdale FL 33301 e cort Fort Lauderdale, 33301 ho Phone: /Fax: Fax: Attorneys for Jeffrey Epstein Attorneys for Jeffrey Epstein Fred Haddad, One Financial Plaza, Suite 2612 Fort Lauderdale. FL 33394 Phone. Fax: Attorneys for Jeffrey Epstein Marc S. Nurik, Esquire Lave Offices of Marc S. Nurik One B Broward Blvd., Suite 700 Fort Lauderdale. FL 3 301 Phone: Fax: Attorneys for Scott Rothstein EFTA00802009 EXHIBIT C EFTA00802010  IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003COC3CMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). NOTICE OF SERVICE OF INTERROGATORIES TO COUNTERDEFENDANT Counterplaintiff, Bradley J. Edwards, hereby gives notice that pursuant to Rule 1.340(e), Florida Rules of Civil Procedure, that Net Worth Interrogatories numbered 1 through 13 have been directed to Counterdefendant, JEFFREY EPSTEIN, this ti day of December, 2012. I HEREBY CERTIFY that, a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this 0 Wday of D ber, 2012. ar No.: E-mail: econdary E-mail(s): Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm da 33409 Phone: Fax: ( Attorney for Bradley J. Edwards EFTA00802011 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800X3004:MBAG COUNSEL LIST Jack A. Goldber er Es uire Marc S. Nurik. Esquire Atterbury, Goldberger & Weiss, P.A. Law Offices of Marc S. Nurik 250 Australian Avenue South, Suite 1400 One E Broward Blvd., Suite 700 West Palm 33401 Fort La 301 SA' Pho • Ph • Fax: Fax: Attorneys for Jeffrey Epstein Attorneys for Scott Rothstein) Lilly Ann Sanchez, Esquire The L-S Law Firm, Farmer, Jaffe, Weissing, Edwards, Fistos & 1441 Brickell Avenue, 15th Floor Lehrman, FL Miami L 3131 425 North Andrews Avenue, Suite 2 Phone: Fort Lauderdale, FL 33301 Fax: Pho c: Fax: uire (s. Attorneys for Jeffrey Epstein oda Haddad Coleman Esquire • Tonja Haddad, P.A. Fred Haddad, P.A. 315 SE 7th Street, Suite 301 One Financial Plaza, Suite 261 Fort Lauderdale, FL 33301 Fort La der e 394 Phone: Pho : Fax: Fax: IS7 4r Attorneys for Jeffrey Epstein Attorneys for Jeffrey Epstein • 2 EFTA00802012 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800)OCXXMIBAO NET WORTH NTERROGATORIES TO JEFFREY EPSTEIN 1. What is your full name? 2. How are you currently employed? . 3. State the amount of your current annual income from all sources for each of the past 3 years and describe all additional benefits received by you or payable to you for each of the past 3y ears including bonuses, allowances, pension and profit sharing participations, stock options, deferred compensation, insurance benefits and other prerequisites of your employment including the dollar amount or dollar value of each. 4. If you own or have any beneficial interest in any stocks, bonds, mutual funds, or other securities of any class in any government, governmental organization, company, firm or corporation, whether foreign or domestic, please state: (a) The name and address of the entity in which you own or have any beneficial property or security interest of any sort; 2 EFTA00802013 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG (b) The date and cost of acquisition; (c) The current fair market value of each such interest; (d) The manner in which such Vie calculated. 5. As to each income tali return filed by you or on your behalf with any taxing authority for the years 2009 through 2012, identify as specifically as identified in your tax return the source of all reported income and the separate amounts derived from each source 6. For each parcel of real property in which you hold any interest, state: 3 EFTA00802014 EDWARDS ADV. EPSTEIN Case No.: 502009CA04080WOCXXMBAG (a) The address, (b) The legal description of the property; (c) The assessed value of the property for tax purposes; (d) The date and price of acquisition; Whether, when, by whom, why and at what amount the property has been raised since the time of purchase; (f) Whether, when, and at what price the property has been offered for sale since the time of purchase; 4 EFTA00802015 EDWARDS ADV. EPSTEIN Case No.: 502009CA0408003OOOCMBAG (g) The name and address of each real estate agent with whom the property has been listed for sale since the time of purchase; CP (h) The cost of any improvements made to the property since purchase; (i) 4, The nature of your interest in the property. .ZCt (j) The current fair market value of the property and a description of the manner in which that value was calculated 7. List each item and state the estimated value of all personal tangible, and intangible property in which you have an interest which personal property was acquired at a cost in excess of $10,000 or which personal property has an estimated present value in excess of $10,000, and as to each state: (a) The date of acquisition; 5 EFTA00802016 EDWARDS ADV. EPSTETN Case No.: 502009CA0408003OOCXMBAG (b) The cost of acquisition; 44" (c) The current estimated fair market value; (d) The manner in which the feta value was estimated. i&pet44)4" 8. If any of the real ot onal property owned by you, either individually, jointly or otherwise, is encumbered by either a real estate mortgage, chattel mortgage, or any other type of lien, then for each item of property, state a description of the nature and amount of the encumbrance, the date the'encumbrance arose, whether the encumbrance is evidenced by any written document and, if so, a description of that document. 9. If you have an ownership interest in any businesses, for each business state: 6 EFTA00802017 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800)OOOO4BAG (a) The name and address of the business; (b) The present book value and the present market value of your interest in the business, and its percentage of the total value of the business; Li 49 (c) A description of the manner in which the stated fair market value was calculated. 10. Identify all banks, credit union and savings and loan accounts, in which you have an interest or right of withdrawal and for each account state: (a) Where the account is located; (b) The highest and lowest balance in the account during the 365 day period immediately preceding your receipt of these interrogatories. 7 EFTA00802018 EDWARDS ADV. EPSTEIN Case No.: 502009CA0408003OOM113AG 11. Identify all other assets of a value in excess of $10,000 which assets were not previously identified and as to each state: (a) The date of acquisition; Gv • (b) The cost of acquisition (.111 4/ (c) The current estimated fair market value; CAS 7t. s- (d) The means utilized to estimate the current fair market value. 8 EFTA00802019 EDWARDS ADV. EPSTEIN Case No.: 502004CA040800)COC<MBAG 12. Identify all other liabilities of an amount in excess of $10,000 not previously identified and as to each state: (a) The date the liability arose; O4z- (b) 'SY The amount of the liability at inceptiN Sc ‘ '- (c) The terms of repayment or satisfaction; Cl I‘ it'.1.ilir (d) The current outstanding balance. 9 EFTA00802020 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG 13. As to any calculation or estimate of your net worth at any time in the five years immediately preceding your receipt of these interrogatories, state: (a) the date of the calculation or estimate; (b) the name and address of the person or entity responsible for performing the work Lie) (c) the reason for performing the calculation date; A Nrd ti: (d) the amount of net worth calculated or ated 14. What is your present net 15. As to all transfers of anythig of a value in excess of $10,000 made by you or on your behalf within the past 5 years, state: (a) a description of the transferred property; (b) the reason for the transfer; (c) the value of the item(s) transferred at the time of transfer; (d) the date and cost of your acquisition of the item(s); 10 EFTA00802021 EDWARDS ADV. EPSTEIN Case No.: 502009CA0408003OOOCMBAG (e) whether you received anything of value in exchange for the transferred item(s) and, if so, a description of what you received and the dollar value of what you received; (f) the name and address of the recipient of each transferred item IA - IL 7 STATE OF sic COUNTY OF The foregoing instrument was acknowledged before me this day of , 20_, by(bit r who is personally known to me or who has produced as identification and who did did/ not take an oath. (SEAL) 4 O (Notary signature) (Notary name - print) NOTARY PUBLIC, State of Florida (Serial number, if any) 11 EFTA00802022 EXHIBIT D EFTA00802023  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 FOR ADMISSIONS TO JEFFREY EPSTEIN COMES NOW the Counter-Plaintiff, Bradley J. Edwards, by and through his undersigned counsel and propounds the following Request for Admissions pursuant to Rule 1.370 Florida Rules of Civil Procedure, requesting that Counter-Defendant, Jeffrey Epstein, admit the truth of the facts set forth as follows: 1. Admit that you have publicly been described as a billionaire. 2. Admit that press reports have described you as a billionaire. 3. Admit that you have never publicly disputed the description of you as a billionaire. 4. Admit that you have never publicly disputed any press reports describing you as a billionaire. 5. Admit that you are a billionaire. 6. Admit that you have been a billionaire sometime within the past 5 years. 7. Admit that you have been a billionaire sometime within the past 10 years. EFTA00802024 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Request for Admissions to Jeffrey Epstein 8. Admit that you have a reputation as being a billionaire. 9. Admit that your personal net worth has exceeded a billion dollars at times during the past 5 years. 10. Admit that your personal net worth has exceeded half a billion dollars at times during the past 5 years. 11. Admit that your personal net worth has exceeded a quarter of a billion dollars at times during the past 5 years. 12. Admit that you have never paid even one penny in punitive damages to any person who has alleged that you engaged in improper sexual conduct with them while that person was a minor. 13. Admit that you have never spent even one day in a state or federal prison facility (as opposed to a county jail) as punishment for any sex-related crime. Pursuant to the Rules of Civil Procedure, each fact on which admission is requested shall be deemed admitted if not denied or if no reply is received on or before March 28, 2013. 2 EFTA00802025 Edwards adv. Epstein Case No.: 502009CA0408003OOCXMBAG Request for Admissions to Jeffrey Epstein I 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 February, 2013. Jack Sc Flori No.: 169440 Pr' E-mail: S dary E-mail(s): y Denney Scarola Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard West Palm Beach. Florida 33409 Phone: Fax: Attorneys for Bradley J. Edwards 3 EFTA00802026 Edwards adv. Epstein Case No.: 502009CA040800XJCXXMBAG Request for Admissions to Jeffrey Epstein COUNSEL LIST Jack A. Goldberger Es uire Marc itili Es uire i Law Offices of Marc S. Nurik Atterbury, Goldberger & Weiss, P.A. One E Broward Blvd., Suite 700 250 Australian Avenue South, Suite 1400 Fort Lauderdale FL 33301 West Palm Beach, FL 33401 Phone: Phone: Fax: Fax: Attorneys for Scott Rothstein Attorneys for Jeffrey Epstein Lill Ann Sanchez, E • uire Braille J. Edwards Es uire staff. The L-S Law Firm Farmer, Jaffe, Weissing, Edwards, Fistos & 1441 Brickell Avenue, 15th Floor Lehrman, FL Miami, FL 33131 425 North Andrews Avenue, Suite 2 Phone: Fort Lauderdale, FL 33301 Fax: Phone: Attorneys for Jeffrey Epstein Fax: Tonja Haddad Coleman, Esquire Fred Haddad Es uire sagiac, ton" on'a Wd.cony 0 MSS Tonja Haddad, P.A. Fred Haddad, P.A. 315 SE 7th Street, Suite 301 One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33301 Fort Lauderdale, FL 33394 Phone: Phone: Fax: Fax: Attorneys for Jeffrey Epstein Attorneys for Jeffrey Epstein 4 EFTA00802027 EXHIBIT E EFTA00802028  IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACE. COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800)OOOCMBAG Judge David F. Crow 0 I VI JEFFREY EPSTEIN, f. Ca) Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF EPSTEIN'S RESPONSE TO DEFENDANT EDWARDS' REOUEST TO PRODUCE Plaintiff/Counter-Defendant, Jeffrey Epstein, by and through his undersigned counsel and pursuant to the Florida Rules of Civil Proced lei this his Response to Request to Produce served on April 15, 2011 and states as fol la. Plaintiff does not have any documents be