EFTA00798039.pdf

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). I NOTICE OF SERVING ANSWERS TO INTERROGATORIES PROPOUNDED BY COUNTER-DEFENDANT JEFFREY EPSTEIN Bradley J. Edwards, by and through his undersigned counsel, hereby files this Notice of Serving Answers to Interrogatories with the Court propounded by the Counter-Defendant, Jeffrey Epstein, on July 12, 2017, which have been furnished to the attorneys for the Counter-Defendant. 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 'ay of 2017. OLA No.: 169440 E-Mail(s): [email protected]• and ®searcylaw.com Primary E-Mail: _scarolateam®searcylaw.com Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: 561-383-9451 Attorneys for Bradley J. Edwards EFTA00798039 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories COUNSEL LIST William Chester Brewer, Esquire wcblaw®aol.com; wcblawasst®gmail.com 250 S Australian Avenue, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-655-4777 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Jack A. Goldberger, Esquire jgoldberger®agwpa.com; smahoney®agwpa.com Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Bradley J. Edwards, Esquire staftefile®pathtojustice.com Fanner Jaffe Weissing Edwards Fistos & Lehrman, P.L. 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fred Haddad, Esquire Dee®FredHaddadLaw.com; Fred®FredHaddadLaw.com Fred Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: (954)467-6767 Fax: (954)-467-3599 Attorneys for Jeffrey Epstein Tonja Haddad Coleman, Esquire tonja®tonjahaddad.com; efiling®tonjahaddad.com Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: (954)467-1223 Fax: (954)-337-3716 Attorneys for Jeffrey Epstein EFTA00798040 Marc S. Nurik, Esquire [email protected] One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein 3 EFTA00798041  INTERROGATORIES As to every individual identified on your List of Trial Witnesses, and each category/group of witnesses listed thereon, please provide with particularity the following: 1. The proper name, address, telephone number, electronic mail address, or other means of contact for each witness: ANSWER: DESCRIPTION OF WITNESSES WITNESSES EXPECTED TO BE PRESENTED Jeffrey Epstein 2-3 (Evected to refuse to testify on each element of the claim for Malicious Prosecution). Consistent with rior assertions of rivile e. 2. c/o John Stephenson 1201 W. Peachtree Street Atlanta, Georgia 30339 2-3 Expected to testify about each element of malicious prosecution except bonafide termination and damages. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of unitive dame es Subject to assertions of privilege 3. do Erica Dubno 767 Third Avenue, Suite 3600 New York, New York 10017 2-3 Expected to testify about each element of malicious prosecution except bonafide termination and damages. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive dams es Sub'ect to assertions of privilege 4. do Stan Pottinger EFTA00798042  DESCRIPTION OF WITNESSES 49 Twin Lakes Road, Suite 100 South Salem NY 10590 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive dama es through her own knowledge and experiences with Epstein. 5. do Peter Guirguis, Esq. MINTZ & GOLD LLP 600 Third Avenue, 25th Floor, New York 10016 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive dama es through her own knowledge and experiences with Epstein. 6. do Peter Guirguis, Esq. MINTZ & GOLD LLP 600 Third Avenue, 25" Floor, New York, 10016 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive dam :es through her own knowledge and experiences with Epstein. 7. 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive dame es throw her own knowledge and experiences with Epstein. 8. do Robert Josefsberg, Esq. PODHURST ORSECK, PA, 25 W FLAGLER STREET, STE 800, MIAMI, FL 33131 EFTA00798043  DESCRIPTION OF WITNESSES 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages through her own knowledge and experiences with Epstein. Robert Josefsberg, Esquire 9' PODHURST ORSECIC, PA, 25 W FLAGLER STREET, STE 800, MIAMI, FL 33131 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. Will confirm the propriety of Edwards' actions. Detective Joseph Recarey 10. Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. Chief Michael Reiter 11 Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. John Connolly 12 do Simon & Schuster 1230 6th Avenue New York, New York 10020 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of EFTA00798044  DESCRIPTION OF WITNESSES the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. Charles Lichtman, Esquire 13 350 East Las Olas Boulevard I Suite 1000 Fort Lauderdale, FL 33301 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify as to the falsity of the claims made by Epstein against Edwards and the propriety of Edwards' actions. William Scherer, Esquire 14. 633 S Federal Hwy #800 Fort Lauderdale, FL 33301 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify as to the falsity of the claims made by Epstein against Edwards. Antonio Figueroa (Tony) 15. Palm Coast, Florida 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages through his own knowledge and experiences with Epstein. Records Custodian of Palm Beach Police Department 16. 345 South County Road Palm Beach, FL 33480 17. Records Custodian of United States Attorney's Office for the Southern District of Florida Records Custodian of the Federal Bureau of Investigations 18. Spencer Kuvin, Esquire 19. 1800 S. Australian Avenue, #400 West Palm Beach, Florida 33409 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. Will also confirm the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. Theodore Leopold, Esquire 20' 2925 PGA Boulevard Palm Beach Gardens, Florida 33410 EFTA00798045  DESCRIPTION OF WITNESSES 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. Will also confirm the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. 21. Rinaldo Rizzo do Robert Lewis 228 East 45th Street I 17th Floor New York, NY 10017 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages through his own knowledge and experiences with Epstein. Adam Horowitz, Esquire 22 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. Will also confirm the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. Isidro M. Garcia, Esquire 23 Garcia Law Firm, P.A. 224 Datum Street, Suite 900 West Palm Beach, FL, 33401 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. Will also confirm the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. All of the Lawyers who Represented Victims of Jeffrey Epstein. 24. 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of EFTA00798046  DESCRIPTION OF WITNESSES punitive damages. Will also confirm the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. WITNESSES WHICH MAY BE CALLED IF NEED ARISES 2-3. Each of the witnesses listed below as numbered 25-157 (with the exception of records custodians) has information pertaining to the malicious prosecution elements of absence of probable cause and malice. If called, each could provide information regarding the truth of the claims prosecuted by Edwards against Epstein, and the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted b Edwards at the time, including on the issue of punitive damages. 25. Landon Thomas 26 do New York Times 620 Eighth Avenue New York, NY 10018 Oren Kramer 27 do Boston Provident, L.P. 717 5th Avenue #I2A New York, NY 10022 Lawrence LaVecchio 28. United States Attorney's Office Southern District of Florida Broward Financial Center Fort Lauderdale, Florida. Will also confirm the leadership role played by Edwards in the prosecution of civil claims t ainst Epstein and the propriety of Edwards' actions. 29. do Brad Edwards, Farmer Jaffe Weissing 425 North Andrews Avenue Fort Lauderdale FL 33301 30. 31. 32. do Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 33 * do Jack Scarola SEARCY DENNEY, ET AL. EFTA00798047  DESCRIPTION OF WITNESSES 2139 PALM BEACH LAKES BLVD. West Palm Beach, FL 33409 34. c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 Brandy Brenson c/o Spencer Kuvin 35, 1800 South Australian Ave #400 West Palm Beach, Florida, 33409 36. c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL, 33131 37. c/o Spencer Kuvin 1800 South Australian Ave 4400 West Palm Beach, Florida, 33409 38. c/o Bradley Edwards, Esq. FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 Paul Cassell, Esq. 39. 383 S. University Street Salt Lake City Utah, UT 84112 40. c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 Fr. LAUDERDALE, FL 33301 41. 42' do Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 43. c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 EFTA00798048  DESCRIPTION OF WITNESSES MIAMI, FL 33131 44. c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 Prince Andrew Albert Christian Edwards 45. Duke of York, Buckingham Palace Road London SW IA IAA Frederic Fekkai 46. Address Currently Unknown 47. cio Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 Lesley Groff 48' c/o Mike Miller 1114 Avenue of the Americas New York, NY 10036 Dave Rogers 49. c/o Bruce Reinhart 505 S. Flagler Drive, Ste 300 West Palm Beach, FL 33401 50. c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 51. c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI FL 33131 52. c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 53. c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 EFTA00798049  DESCRIPTION OF WITNESSES 54. c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 Tod Meister 55. Palm Beach, FL 38480 56. cIo Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 57. c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA, 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 58. c/o Spencer Kuvin 1800 South Australian Ave #400 West Palm Beach, Florida, 33409 59. c/o Marshall Dore Louis 40 NW third Street, Suite 200 Miami, FL 33128 Jason Richards 60. Federal Bureau of Investigation 16320 NW 2nd AVE., MIAMI, FL 33169 61. c/o Bradley Edwards, Esq. FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2, FT. LAUDERDALE, FL 33301 62. c/o Bradley Edwards FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2, FT. LAUDERDALE, FL 33301 63. c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 EFTA00798050  DESCRIPTION OF WITNESSES 64. do Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 65. do Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 Nezbitt Kurkendall 66. Federal Bureau of Investigation 16320 NW 2nd AVE. MIAMI, FL 33169 67. do Isidro M. Garcia Garcia Law Firm, P.A. 224 Datum Street, Suite 900 West Palm Beach, FL, 33401 Igor Zinoview 68 Addres,, Ci i ently Unknown 69. Address Currently'Unknown 70. • Seth Lehrman 71. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 Matt Weissing 72 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 Maria Villafana 73. 500 S. Australian Avenue, #400 West Palm Beach, FL 33401. Will also confirm the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. Any additional individuals identified as victims by the United states Attorney's Office and whose 74. identities were conveyed to Jeffrey Epstein as part of a list supplied as it related to the NPA Leslie Wexner 75. Three Limited Parkway Columbus, Ohio 43206. Subject to assertions of privilege Donald Trtunp 76. c/o Alan Garten, Esq. 725 Fifth Avenue EFTA00798051  DESCRIPTION OF WITNESSES New York, NY 10022. Subject to the assertions of privilege La Visoski 77. RIVIERA It! ACH, FL 33401 78. 79 ' C/O ATTORNEY WILLIAM UNROCH 140 WEST END, APT 30-BW NEW YORK, NY 10023 80. do Spencer Kuvin 1800 S. Australian Avenue, #400 West Palm Beach, Florida 33409 81. 82. do Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 David Co field (David Seth Kokin) 83. LAS VEGAS, NV 89135 84. Michael Fisten 85 Weston, FL Russell Adler 86 Delray Beach, FL Marie Alessi 87. BOYTON BEACH, FL 33472 Janusz Banasiak 88. 358 EL BRILLO WAY PALM BEACH FL, 33480 Beata Banasiak 89. 358 EL BRILLO WAY PALM BEACH, FL 33480 EFTA00798052  DESCRIPTION OF WITNESSES Juan Alessi 90. BOYTON BEACH, FL 33472 91. Jerry Goldsmith 92. WEST PA I M BEACH, FL 33418-7942 93. Valdson Cotrin 94. Address Currently Unknown 95. 96. Unknown, South Africa Glenn Dubin 97. 1040 5TH AVE UNIT 15A NEW YORK, NY 10028-0137 Abigail Wexner 98 Three Limited Parkway Columbus, Ohio 43206 Officer Munyan 99. Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 Officer Minot 100. Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 Sgt. Sorge 101. Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 102' S/A Witness #152 Arnold Paul Pros.: 103. WEST PALM BEACH, FL 33405-1654 EFTA00798053  DESCRIPTION OF WITNESSES Jose .h Pagnano 104. WEST PALM BEACH, FL 33401 105. Ste han Kossl CAMBRIDGE MA 02138-1802 Cecile Deon • 106. ST THOMAS VI 00802 Tommy Mottola 107. PALM BEACH FL 33480-3012 Mike Sanka 108. 449 S BEVERLY DR STE 101 BEVERLY HILLS, CA 90212 109. S/A Witness #105 William "Bill" Rile 110. CORAL SPRINGS FL 33076 I toward Rubenstein 111. 1345 AVENUE OF THE AMERICAS NEW YORK, NEW YORK 10105 Robert Meister 112. PALM BEACH FL 33480 Todd Meister 113. PALM BEACH, FL 33480 President William J. Clinton 114 William Hammond 115 Royal Palm Beach, FL Robert Roxburgh 116. West Palm Beach, Florida Michele Pagan 117 Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 EFTA00798054  DESCRIPTION OF WITNESSES Michele Dawson 118 Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 Amy Fortimer 119. WELLINGTON, FL 33414 120. 121. 122. 123. 124. c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 125. Zack Bryan 126. Wellin' on, Florida 127. Larry Morrison 128. WELLINGTON, FL 33449 129. Story Cowles WEST PALM BEACH, FL 33401 Alan Dershowitz 130. CAMBRIDGE, MA 02138 or EFTA00798055  DESCRIPTION OF WITNESSES NEW YORK, NY 10017. Subject to assertions of privilege Michael Dawson 131. Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 Salaam Kahlid Monroe 132. CORAL GABLES, FL 33134 Jelitza Negrette 133. PORTLAND, ME 04101 Sera Cordem 134. MIAMI, FL 33131 Cassandra Rivera 135. WEST PALM BEACH, FL 33415 Randee Speciale 136. PALM BEACH VICTIM SERVICES 205 N DIXIE HIGHWAY # 5.1100 WEST PALM BEACH, FL 33401 137. Address Currently Unknown Steven Hoffenberg 138. Address Currently Unknown Michael Stroll 139. Address Currently Unknown Douglas Shoettle 140. 243 Riverside, Dr. New York, NY 10025 Ghislaine Maxwell 141' Address Currently Unknown Records Custodian 142 Amazon Records Custodian 143' Yellow Cab Records Custodian 144. . Citrix Systems, Inc. Records Custodian 145. Federal Bureau of Investigation Records Custodian 146. Milton Girls Juvenile Facility EFTA00798056  DESCRIPTION OF WITNESSES 5770 EAST MILTON ROAD MILTON, FL Records Custodian 147. School District of Palm Beach County 3344 FOREST HILL BLVD, SUITE C-124 West Palm Beach, FL 33406 Records Custodian 148 St. Mary's Medical Center 901 45'h STREET West Palm Beach, FL 33401 Records Custodian 149. WELLINGTON REGIONAL HOSPITAL 10104 FORREST HILL BLVD WELLINGTON, FL 33414 All witnesses that Defendants have listed on their Witness List not objected to by Plaintiff, Jane Doe. 150. All rebuttal witnesses. 151. All People on Jeffrey Epstein's Inmate Visitor Log while he was in jail. 152. WITNESS TESTIMONY EXPECTED TO BE PRESENTED BY MEANS OF DEPOSITION Mark Epstein 153' 30 VANDAM STREET NEW YORK, NY 10013 154. c o Akin S. Ross, Gsq. 155. Alfredo Rodriguez 156. 11349 SW 86TH LN, Miami, FL C/O Federal Public Defender or Bureau of Prisons Scott Rothstein 157. do Mark Nurik One East Broward Boulevard, Suite 700 Fort Lauderdale, Florida 33301 EFTA00798057 2. Each contested factual issue expected to be addressed by the witness, including identifying with particularity as to which element(s) of your claim for MaliciousProsecution this witness's testimony is applicable: ANSWER: See response to number 1. 3. A detailed description of the testimony expected to be presented at trial by the witness as to each contested factual issue and clement of your claim against Epstein: ANSWER: See response to number 1. 4. A description of the Trial Exhibit List number of each exhibit expected to be introduced into evidence by the witness: ANSWER: Unknown at this time which exhibits will be introduced through which witness. 5. A description of the Trial Exhibit List number of each exhibit introduced through other means about which the witness is expected to testify, together with a description of thewitness' expected testimony regarding each exhibit: ANSWER: Unknown at this time the exhibits about which each witness will testify. EFTA00798058  STATE OF Fib& clot. COUNTY OF ,,YqtytAMA do The foregoing instrument was acknowledged before me this /fric.‘- day of I 2017 by eR ,< 4- Cl acueVe di) , who is personal) 0 -- to me or who has produced ...--- as identification and who did/did r not take an oath. azak keilic4iaoL (Notary name - print) NOTARY PUBLIC, State of Florida EFTA00798059