EFTA01113432.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXIMBAG JEFFREY EPSTEIN, Plaintiff(s), VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and 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 A clay 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 I ber, 2012. Jack9 Flo ar No.: 169440 E-mail: ndary E-mail(s): Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Fax Fax: Attorney or ey . Edwards EFTA01113432 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXM:BAG COUNSEL LISP Jack A. Goldberger, Esquire 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 Beach, FL 33401 Fort Lauderdale, FL 33301 Phone: Phone: Fax: Fax: Attorneys for Jeffrey Epstein Attorneys for Scott Rothstein Bradley J. Edwards, Esquire Lill Ann Sanche Es uire The L-S Law Firm armer„ easing, wards, Fistos & 1441 Brickell Avenue, 15th Floor Lehrman, FL Miami, FL 33131 425 North Andrews Avenue, Suite 2 Phone: Fort Lauderdale, FL 33301 Fax: Phone: IMEMINON Attorneys for Jeffrey Epstein Fax: Tonja Haddad Coleman, Esquire Fred Haddad, Esquire 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 2 EFTA01113433 EDWARDS ADV. EPSTEIN Caen No.: 502009CA040800XXXXMI3AG NET WORTH NTERROGATORIES TO JEFFREY EPSTEIN 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 EFTA01113434 EDWARDS ADV. EPSTEIN Case No • 502009CA0408003OOOCMBAG (b) The date and cost of acquisition; (c) The current fair market value of each such interest; (d) The manner in which such value was calculated. 5. As to each income tax 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 EFTA01113435 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXX/ABAG (a) The address, (b) The legal description of the property; (c) The ass sled value of the property for tax purposes; (d) The date and price of acquisition; (e) Whether, when, by whom, why and at what amount the property has been appraised 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 EFTA01113436 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800)OOOCMBAG (g) The name and address of each real estate agent with whom the property has been listed for sale since the time of purchase; (h) The cost of any improvements made to the property since purchase; (i) The nature of your interest in the property. (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 EFTA01113437 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG (b) The cost of acquisition; (c) The current estimated fair market value; (d) The manner in which the fair market value was estimated. 8. If any of the real or personal 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 EFTA01113438 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG (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; (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 EFTA01113439 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800)COOCMBAG 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; (b) The cost of acquisition; (c) The current estimated fair market value; (d) The means utilized to estimate the current fair market value. 8 EFTA01113440 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800)OOOCMBAG 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; (b) The amount of the liability at inception; (c) The terms of repayment or satisfaction; (d) The current outstanding balance. 9 EFTA01113441 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 (c) the reason for performing the calculation or estimate; (d) the amount of net worth calculated or estimated 14. What is your present net worth? 15. As to all transfers of anything 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 EFTA01113442 EDWARDS ADV. EPSTEIN Case No.: 502009CA0408007OOOQvIBAO (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; (I) the name and address of the recipient of each transferred item 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) 11 EFTA01113443