EFTA01103268.pdf

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla.R.Civ.Pro. 1.201 Case No. 502009CA040800XXXXMBAG PlaintiffiCounter-Defendant, v. SCOTT ROTHSTEIN, Individually, BRADLEY J. EDWARDS, Individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT, JEFFREY EPSTEIN'S MOTION TO ENLARGE TIME TO RESPOND TO EDWARDS' ADDITIONAL INTERROGATORY Plaintiff/Counter-Defendant, Jeffrey Epstein, ("Epstein"), by and through his undersigned counsel, and pursuant to the Florida Rules of Civil Procedure, files this Motion to Enlarge Time to Respond to Defendant, Counter/Plaintiff, Bradley J. Edwards' Additional Interrogatory. The grounds for this motion are as follows: 1. On April 1, 2011, Defendant, Counter/Plaintiff, Bradley J. Edwards ("Edwards") served by facsimile his Notice of Propounding Interrogatory aAda Additional Interrogatory to Epstein. A copy of this discovery request is attached hereto as Exhibit "A". 2. The deadline for Epstein to respond to this discovery request is May 2, 2011. 3. Initially, Mr. Edwards submitted interrogatories in excess of the permissive number. The parties agreed to allow an excess number of interrogatories and the court entered an agreed order expanding the number of interrogatories on October 5, 2010. 4. The number of interrogatories for which Edwards seeks a response is approximately 68 interrogatories. FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561)802-9044 EFTA01103268  Epstein v. Rothstein, et al. 2 Case No. 50 2009 CA 040800XXXXMBAG Epstein's M- Enlarge Time to Respond to Edwards' Ada Interrogatory 4-1-11 5. Edwards has pending with this discovery his Motion to Permit Additional Interrogatory which motion has not be set before this court for hearing. 6. Epstein requests an extension of fourteen (14) days within which to serve his response to Edwards' Additional Interrogatory faxed April 1, 2011. 8. Undersigned counsel certifies that this request is made in good faith and not for the purpose of delay. The undersigned counsel further certifies that he has and will continue to make an effort to resolve this matter without the need of a hearing. WHEREFORE, the Plaintiff/Counter-Defendant, Jeffrey Epstein, respectfully requests that this Court grant an extension of fourteen (14) days; i.e. up to an including May 16, 2011 in which to serve a response to Edwards' Additional Interrogatory. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been duly furnished via WEmail, ❑ Facsimile, IlY6.S. Mail, ❑ Hand Delivery, ❑ Federal Express this g4 day of May, 2011 to: Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561)802-9044 EFTA01103269  Epstein v. Rothstein, et al. 3 Case No. 50 2009 CA 040800XXXXMBAG Epstein's M- Enlarge Time to Respond to Edwards' Add'l Interrogatory 4-1-11 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 By: Jos L. Ackennant."Aas Fla. Bar No. 235954 FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: Facsimile: Attorneys for Jeffrey Epstein, Plaintiff/ Counter-Defendant FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 EFTA01103270  5/2- IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintifgs), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). NOTICE OF PROPOUNDING INTERROGATORY TO PLAINTIFF, JEFFREY EPSTEIN Defendant, Bradley J. Edwards, hereby provides notice that pursuant to Rule 1.340(e), Florida Rules of Civil Procedure, that one (1) Interrogatory has been directed to Plaintiff, Jeffrey Epstein, this kt day of , 2011. It is requested that the aforesaid answers be served within thirty (30) days at the offices of Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409. EFTA01103271 Case No.: 502009CA040800)OOOCMBAG f I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by 1 AI U.S. Mail to all Counsel on the attached list on this i' day of 2011. JACK OLA Flor r No.: 169440 Se r Denney Scarola Barnhart & Shipley, P.A. 2 9 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorney for Plaintiff(s) 2 EFTA01103272 Case No.: 502009CA040800XXXXMBAG COUNSEL LIST Jack A. Goldberger, Esquire Att ury, o ger eiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: Fax: Attorneys for Jeffrey Epstein Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 Phone: Fax: Attorneys for JeffreyEpstein e L. Ackerman Jr., Esquire ow erWhite time P.A. 901 Phillips Point West 777 S Flagler Drive West Palm Beach, FL 33401-6170 Phone: Fax: Attorneys ..Epstein Siar c i Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: Fax: Attorneys or cots othstein 3 EFTA01103273  INTERROGATORY TO PLAINTIFF, JEFFREY EPSTEIN (If answering for another person or entity, answer with respect to that person or entity, unless otherwise stated.) 1. As to every act characterized by the Plaintiff as an alleged "abuse of process" by Bradley Edwards, state the following: a. An exact and detailed description of the "process" including the title of all pleadings or other documents which Plaintiff contends were abusive; b. The date on which each alleged abuse occurred; c. The nature of the damage suffered by the Plaintiff as a consequence of this abuse; d. The amount of the damage alleged to have been caused by the abuse. EFTA01103274 Case No.: 502009CA0408003OOOCMBAG STATE OF COUNTY OF ) The foregoing instrument was acknowledged before me this day of , 20__, by , who is personally known to me or who has produced as identification and who did/did not take an oath. (SEAL) (Notary signature) (Notary name - print) NOTARY PUBLIC, State of Florida (Serial number, if any) 2 EFTA01103275