EFTA00592187.pdf

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, PlaintifKounter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants/Counter-Plaintiffs. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY J. EDWARDS' REQUEST FOR PRODUCTION SERVED JUNE 9.2011 Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350, of the Florida Rules of Civil Procedure, files this his Response to the Request for Production from the Defendant/Counter-Plaintiff, Bradley J. Edwards' ("Edwards"), Request for Production Served June 9, 2011, and would state as follows: 1. Since Epstein has not be able, due in large part to the objections of Edwards to obtain all relevant documents that would reflect, suggest, or relate to Edwards' knowledge of Rothstein's conduct, it is not possible to to produce all documents responsive to this request. However, exhibits to the deposition of A.J. Discala, Dean Kretschmar, and Michael Legamaro due fit and are responsive to this request. In addition, the documents that are exhibits to Epstein's Motion to Use Confidential Documents are also responsive. 2. See Response to Number 1 above. 3. Undetermined at this time. FOWLER WHITE BURNEUTIMI. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DR/VE, WEST PALM BEACH. FLORIDA 33401 • (561) 802.9044 EFTA00592187  Epstein v Rothstein, et al. CASE NO. 502009CA040800XXXXMBAG Epstein's Response to Edwards' RFP Served June 9, 2011 4. Objection. Work product. See Grinnel Corp. v. Palms 2100 Ocean Boulevard Limited, 924 So 2d 887 (Fla. 4th DCA 2006). 5. Objection. Work product. See Grinnel Corp. v. Palms 2100 Ocean Boulevard Limited, 924 So 2d 887 (Fla. 4th DCA 2006). I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this 144 of July, 2011 to: Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, E., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012; Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301; Jack Scarola, Esq., Searcy Denney Scarola et al., 2139 Palm Beach Lakes Boulevard, P.O. Drawer 3626, West Palm Beach, FL 33409; and Martin G. Weinberg, Esq., 20 Park Plaza, Suite 1000, Suffolk, MA 02116. Respectfully submitted, 2 se:h Ackerman, Jr. Fla. Bar No. 235954 914-6 FOWLER WHITE BURNETT, 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: Facsimile: WA80743NRESPON37-Epssein's Response to alwardt FtFP 64.1I -.ILA.docx -2- FOWLER WHITE BURNF.17. • 901 PHILUPS POINT WEST, 777 SOWN FLA0L.ER DRIVE, WEST PALM BEACH. FLORIDA 33401 • (560 802.9044 EFTA00592188