EFTA00622901.pdf

JEFFREY EPSTEIN, IN THE CIRCUIT COURT OF THE 1.11-1EENTH JUDICIAL CIRCUIT IN Plaintiff, AND FOR PALM BEACH COUNTY, FLORIDA VS. SCOTT ROTHSTEIN, individually, CASE NO.: 502009CA040800XXXXMBAG and BRADLEY J. EDWARDS, individually. JUDGE: CROW Defendants. NOTICE OF TAKING VIDEOTAPED DEPOSITION (Continuation of May 15, 2013 Deposition) PLEASE TAKE NOTICE that Pursuant to Rule 1.410 of the Florida Rules of Civil Procedure, the undersigned attorney will take the deposition of Defendant/Counter- Plaintiff Bradley J. Edwards on Thursday, October 10, 2013 at 10:00AM at Empire Legal Support, Inc., 401 East Las Olas Boulevard, Suite 1400, Fort Lauderdale, FL 33301, upon oral and videotaped examination before Empire Legal Support, Notaries Public, or any other notary public or officer authorized by law to take depositions in the state of Florida. The oral examination will continue all day and day to day thereafter until completed. This deposition is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the rules of Court. If you fail to appear, 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. We hereby certify that this date was coordinated with opposing counsel, and that a true and correct copy of this notice was served upon all parties listed in the service list below, via Electronic Service, this August 6, 2013. EFTA00622901 /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 EFTA00622902  SCHEDULE A (To Bring With You For Deposition) 1. Copies of income tax returns for the past five (5) calendar years of the DefendanUCounter-Plaintiff Bradley J. Edwards (hereinafter "Edwards") (2007-2012). 2. Income tax records for the current tax year, and copies of any estimated income tax returns filed for the current year for Edwards. 3. Copies of income tax returns for the past three (3) calendar years of Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 4. Copies of all documentation related to all settlements, attorneys' fees awards, jury verdict awards, and arbitration/mediation income received by Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., and/or Bradley J. Edwards, PA. 5. Income tax records for the current tax year, and copies of any estimated income tax returns filed for the current year for Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 6. A copy of Edwards's (or Bradley J. Edwards, PA's) partnership agreement with Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 7. Copies of any and all memoranda, diaries, journals, appointment books, calendars, electronic mails, notes, correspondence, or other documents upon which you rely in support of your allegation of lost income/value of time diverted from your professional responsibilities as alleged in your Counterclaim. 8. Copies of any and all memoranda, diaries, journals, appointment books, calendars, electronic mails, notes, correspondence, or other documents upon which you rely in support of your allegation of injury to your reputation as alleged in your Counterclaim. 9. Copies of any and all receipts, reports, invoices, or other documents evidencing treatment for your mental anguish, embarrassment, and anxiety as alleged in your Counterclaim. 10. Copies of any and all receipts, reports, or invoices evidencing lost income suffered as a result of your mental anguish, embarrassment, and anxiety as alleged in your Counterclaim. 11. Copies of any and all memoranda, diaries, journals, appointment books, calendars, electronic mails, notes, correspondence or other documents upon which you rely in support of your claim for Punitive Damages. EFTA00622903  12. Copies of any and all documents you intend to introduce at trial in support of the allegations made by you in your Fourth Amended Counterclaim you filed in this matter. EFTA00622904