EFTA00798060.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). NOTICE OF SERVING ANSWERS TO INTERROGATORIES Bradley J. Edwards, by and through his undersigned counsel, hereby files this Notice of Serving Answers to Interrogatories with the Court propounded by Jeffrey Epstein on September 5, 2017, and said Answers to Interrogatories have been furnished to the attorneys for Jeffrey Epstein. 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 -5 14" day of ( bee" , 2017. AROLA Florida Bar No.: 16944 Attorney E-Mail(s): [email protected]• and [email protected] Primary E-Mail: [email protected] 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 EFTA00798060 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories COUNSEL LIST William Chester Brewer, Esquire [email protected]; [email protected] 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; [email protected] 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 [email protected] Farmer Jaffe Weissing Edwards Fistos & Lehrman, P.L. 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 Fred Haddad, Esquire Dee®FredHaddadLaw.com; [email protected] 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; [email protected] Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: (954)467-1223 EFTA00798061 Edwards adv. Epstein Case No.: 502009CA040800)OOOCMBAG Notice of Serving Answers to Interrogatories Fax: (954)-337-3716 Attorneys for Jeffrey Epstein 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 EFTA00798062 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories DAMAGES INTERROGATORIES TO BRADLEY J. EDWARDS 1. State the full name, address, telephone number and description of business for each of your employers (including as an independent contractor, if applicable), at any time during the period in question, and for each employer provide the dates ofemployment, nature of work, title, position, salary, and description of your duties for such employer, as well as any changes in title, position or duties during your employment during the period in question, any termination thereof and the reasons for such change. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave ofCourt. 2. State the full name, address, telephone number, type ofentity (including, without limitation, corporation, partnership, limited partnership, limited liability corporation, sole proprietorship or other entity) and description of the business conducted of each business enterprise with which you have been affiliated as a principal (including as an owner, officer, director, partner, manager, member, shareholder, or in any similar capacity) at any time during the period in question, as well as the dates of such affiliation, the nature ofsuch affiliation, any changes during the period in question in the nature of such affiliation, and the reasons for such changes, as well as any income, profits, distributions, salary, commission, or bonus paid in connection with such affiliation. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 ofCounter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave ofCourt. EFTA00798063 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories 3. State the full name, address and telephone number of all corporations, limited liability companies, partnerships, limited partnerships, limited liability corporations, sole proprietorships other entities or business enterprises for which you have served at any time during the period in question as a member of the Board of Directors, a member of the Board of Trustees, a committee member, an advisory board member, a member of senior management, or in some similar capacity, state the dates of service, describe the capacity in which you served, state the full name, address, email address and telephone number ofeach person to whom you reported in such capacity, and if any payment, compensation, fee, honorarium, other remuneration or other consideration was received for such service, state the nature (whether cash or other consideration), frequency, dates, and amounts thereof, and state the dates such service terminated, if applicable, and any reasons therefor. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 ofCounter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court. 4. Identify each person or entity for whom you performed services for a fee amounting to $5,000 or more, or on a contingency basis or under some other financial arrangement during the period in question, and provide the dates of service, the nature of the services performed, the terms of the business arrangement with respect to the performance of such services, the dates of any payments for such services and the amounts paid or the amounts owed for such services, and identify the person or persons to whom or which such amounts were paid or such amounts are owed. If you performed such services through a law firm, state the name of the law firm through which you performed such services in addition to the other information requested herein. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 ofCounter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave ofCourt. In addition, this Interrogatory seeks to invade the attorney-client and work product privileges. EFTA00798064 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories 5. At any time during the period in question did you have any interest of five (5%) percent or more in a corporation, partnership, limited partnership, limited liability company, trust or other entity, including, without limitation, professional service entities? If so, state the name and address of each such entity, the dates on which you held your interest, the dates on which you disposed of such interest, if applicable, all amounts and other consideration you paid to acquire such interest, and all amounts and consideration received, directly or indirectly, in connection with holding such interest and in connection with the disposition of such interest, and include the names, addresses and telephone numbers ofall other controlling shareholders, partners, members, officers, directors, managers, settlors, trust protectors, trustees, and beneficiaries of such entity. See definition no. 5 above in preparing the response to this interrogatory with respect to any such interest acquired at any time on or after December 7, 2009 or any such interest in which there was a change in the ownership thereofat any time on or after December 7, 2009. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 ofCounter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court. 6. With respect to the provision by you of legal services at any time during the period in question, for each distinct arrangement through which you provided legal services, describe in detail how you provided legal services, whether as an individual, as a sole proprietor, through a professional corporation, a professional partnership, a professional limited liability company, a professional association, or similar entity, or through a combination of any of the foregoing, and for each entity through which you provided such legal services describe in detail all agreed (whether or not followed) and defacto business arrangements with respect to your provision oflegal services through such entity, including, without limitation, cost sharing, fee splitting, fee percentage, profit sharing and/or profit participation. If any such business arrangement was memorialized pursuant to an agreement, describe the agreement, all amendments, modifications, and supplements thereto, the dates of the same, and all parties thereto, and identify and state the names, addresses, email addresses, and telephone numbers of all persons in possession or control of embodiments of such agreement, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format). ►f the actual business arrangement with respect to your provision of legal services through such entity differed from any memorialized business arrangement, describe the difference and the reasons therefor. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. EFTA00798065 Edwards adv. Epstein Case No.: S02009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court. In addition, this Interrogatory seeks to invade the attorney-client and work product privileges 7. Identify by name, address, and telephone number, each and every domestic and foreign bank, brokerage and/or other financial institution in which there was an account maintained in your name or over which you have had signatory authority or other such control during the period in question, and provide the account number, the type ofaccount, starting date on which you had opened such account or had signatory authority or other such control over it. For each such account provide the account balance, if any, at March I, 2009, October 1, 2009, December 1, 2009, and August 1, 2012 and the account balance, ifany, at the present date. If the starting date of the account was a date between any two of the foregoing dates, provide the opening account balance at the starting date. See definition no. 5 above in preparing the response to this interrogatory for all such accounts opened at any time on or after December 7, 2009. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 ofCounter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave ofCourt. 8. Furnish the following financial information with respect to you as of March I, 2009, October 1, 2009, December I, 2009, and August I, 2012 and as of the present date: Assets Cost M Fair Market Value ($1 1. Cash 2. Cash surrender value of insurance 3. Accounts receivable 4. Notes receivable 5. Real estate, including fractional interests 6. Motor Vehicles 7. Boats and other watercraft, including fractional interests 8. Aircraft, including fractional interests 9. Club Memberships 10. Interests in Trusts 11. Partnership Interests 12. Limited Liability Company Interests 13. Stocks, bonds, options financial contracts or other securities EFTA00798066 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories 14. Interests in Commodities 15. Pensions or annuities 16. Precious and semi-precious stones 17. Jewelry 18. Artwork 19. Antiques 20. Watches 21. Gold 22. Silver 23. Musical Instruments 24. Other collections (coins, stamps, pens, memorabilia, etc.) 25. Contracts or Agreements b. Liabilities Face Amount ($1 Fair Market Value ($) 1. Loans on insurance 2. Accounts payable 3. Credit balances payable 4. Leases payable 5. Notes payable 6. Mortgages 7. Accrued real estate taxes 8. Liens payable 9. Judgments 10. Reserves See definition no. 5 above in preparing the response to this interrogatory with respect to assets and liabilities reported at December 1, 2009, August 1, 2012 and the present date. Provide separate assets and liabilities tables for each distinct font of ownership described in clauses (a), (b) and (c) of definition no. 5, and for each separate assets and liability table, identify the owner thereof. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave ofCourt. 9. Provide the following information relating to your insurance policies in force as at each of March 1, 2009, October 1, 2009, December 1, 2009, and August I, 2012, and as now in force: Policy No. Cash Surrender Value and Description Insurer Policy Amount Accumulated Dividends EFTA00798067 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories (1) (2) (3) (4) Policy Loan No. Automatic Premium Payments and Description Date Made Date Made See definition no. 5 above in preparing the response to this interrogatory at December 1, 2009 and August 1, 2012 and as now in force, and for each such reporting date provide separate tables for each distinct form of ownership described in clauses (a), (b) and (c) of definition no. 5, and for each separate table, identify the owner thereof RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave ofCourt. 10. As at each of March I, 2009, October 1, 2009, December I, 2009, and August I, 2012 and as at the present date, identify each account receivable and note receivable held by you, and in connection therewith set forth the name, address and telephone number of the debtor, identify the payee of each such account receivable and note receivable, and provide the amount then outstanding of each such account receivable and note receivable. See definition no. 5 above in preparing the response to this interrogatory at December I, 2009 and August 1, 2012 and as at the present date. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 ofCounter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court. EFTA00798068 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories I I. At any time during the period in question did you own, claim an interest in, or possess, or control, whether directly or indirectly, in your own name, through ownership by entities in which you hold an interest or control, or through trusts in which you are grantors, trustees or beneficiaries, any real property? If your answer to this interrogatory is in the affirmative, state or identify: (a) the dates of acquisition and disposition; (b) the property's address; (c) the type of property (i.e., house, condominium, commercial building, investment property, etc.); (d) the cost of the property at the time purchased; (e) fair market value of the property as at each of March I, 2009, October I, 2009, December I, 2009, and August 1, 2012, and at the present date; if the property was disposed of or acquired in different name between any two of foregoing dates, also provide the fair market value at the time of disposition or acquisition; (f) if not gill owned, the value ofall consideration received, directly or indirectly, in connection with the disposition ofthe property, the transferee of the property and your relationship to the transferee; (g) any mortgages or other encumbrances against the property and the balance, if any, of such mortgages or other encumbrances as at each of March 1, 2009, October I, 2009, December I, 2009, and August I, 2012, and at the present date; provide the dates and amounts ofall increases in any such mortgages or other encumbrances at any time on or after December 1, 2009; state the amounts and dates of all mortgage payments made at any time on or after December I, 2009 by any person or entity other than the mortgagor, (h) how you titled the property upon its purchase or acquisition; (i) in the event of any changes in the titleholder on or after December 1, 2009 in connection with which you retained beneficial ownership or effective control of the property, provide the date of such change, state the amount of any consideration paid in connection with the change, identify the new titleholder and the relationship of the new titleholder to you; (i) identify the current titleholder and the relationship ofthe current titleholder to you. (j) specifically identify and state all transfers of the property at any time on or after December I, 2009 as a result of which title was held (a) in the name ofEdwards' spouse, for the benefit ofEdwards' spouse, in a trust under which Edwards' spouse is a trustee or beneficiary, or in the name of any other person in circumstances under which Edwards' spouse has the use, enjoyment or benefit ofthe same or can exercise effective control over the same, or (b) in the name of a dependent child of Edwards, for the benefit of a dependent child of Edwards, in trust under which Edwards' dependent child is a beneficiary, or in the name of any other person in circumstances under which Edwards' dependent child has the use, enjoyment or benefit of the same, or (c) in trust under which Edwards is a trustee or beneficiary, or in the name of any other person in circumstances under which Edwards has the use, enjoyment or benefit of the same or can exercise effective control over the same, state the date of the transfer, identify the new title holder, describe the amount and form ofall consideration exchanged in connection with the transfer, and identify the payor and the payee ofall such consideration exchanged. See definition no. 5 above in preparing the response to this interrogatory with respect to all property which at any time on or after December I, 2009 was acquired, or disposed of, or as to which at any time on or after December 1, 2009 title was transferred to a holder described in any of clauses (a), (b) and (c) of definition no. 5. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 ofCounter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. EFTA00798069 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave ofCourt. 12. If at any time during the period in question you did not own the property that was occupied by your family, whether full-time or part-time, or ifyou do not own the property currently occupied by your family, whether full-time or part-time, set forth the name, address, email address and telephone number ofthe petson(s) who owned or own the property, the arrangement pursuant to which your family occupied or occupies the property (e.g., lease, sub-lease, other arrangement), how such arrangement was memorialized, the amount paid for such occupancy and the frequency of such payment, the commencement date and termination date of that arrangement, and the name, address, email address and telephone number of each of the parties to that arrangement, including without limitation, the payor of any payment made in connection with that arrangement, whether or not the payor is an actual named party to that arrangement. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court. 13. As at each of March 1, 2009, October I, 2009, December I, 2009, and August I, 2012 and as at the present date, provide the following information with respect to each motor vehicle, boat, water craft, or aircraft owned or used by you as at such date, including, without limitation, in connection with any fractional ownership of any of the foregoing: Amount of Date Indebtedness Date Descriptions Cost Acquired if Pledged Pledged Owner (A) Motor Vehicles (specify make, model, VIN, year) (B) Boats and watercraft (specify make, model, SN, EFTA00798070 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories Ste) (C) Aircraft (specify make, model, SN, rar) (D) Fractional Ownership Interests (specify company, description of fractional interest, make, model, SN, year) Specifically identify and state all transfers of the foregoing property at any time on or after December 1, 2009 as a result of which title was held (a) in the name of Edwards' spouse, for the benefit of Edwards' spouse, in a trust under which Edwards' spouse is a trustee or beneficiary, or in the name of any other person in circumstances under which Edwards' spouse has the use, enjoyment or benefit of the same or can exercise effective control over the same, or (b) in the name of a dependent child ofEdwards, for the benefit of a dependent child ofEdwards, in trust under which Edwards' dependent child is a beneficiary, or in the name of any other person in circumstances under which Edwards' dependent child has the use, enjoyment or benefit of the same, or (c) in trust under which Edwards is a trustee or beneficiary, or in the name of any other person in circumstances under which Edwards has the use, enjoyment or benefit ofthe same or can exercise effective control over the same, state the date of the transfer, identify the new title holder, describe the amount and form ofall consideration exchanged in connection with the transfer, and identify the payor and the payee of all such consideration exchanged. See definition no. 5 in preparing the response to this interrogatory at December 1, 2009 and August 1, 2012 and at the present date. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave ofCourt. 14. Set forth the following information regarding all stocks, bonds, options, other securities and other financial instruments (including, but not limited to, any interest in money markets and mutual funds), and commodities directly or indirectly owned by you or held on your behalf at each of March I, 2009, October 1, 2009, December 1, 2009, August 1, 2012 and the present date: Amount of EFTA00798071 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories Record Number of Date Indebted. Description Issuer Owner Units Acquired Cost If Pledged Specifically identify and state all transfers of the foregoing property at any time on or after December 1, 2009 as a result of which record title was held (a) in the name of Edwards' spouse, for the benefit of Edwards' spouse, in a trust under which Edwards' spouse is a trustee or beneficiary, or in the name of any other person in circumstances under which Edwards' spouse has the use, enjoyment or benefit ofthe same or can exercise effective control over the same, or (b) in the name ofa dependent child ofEdwards, for the benefit of a dependent child of Edwards, in trust under which Edwards' dependent child is a beneficiary, or in the name of any other person in circumstances under which Edwards' dependent child has the use, enjoyment or benefit of the same, or (c) in trust under which Edwards is a trustee or beneficiary, or in the name of any other person in circumstances under which Edwards has the use, enjoyment or benefit of the same or can exercise effective control over the same, state the date of the transfer, identify the new record title holder, describe the amount and form of all consideration exchanged in connection with the transfer, and identify the payor and the payee ofall such consideration exchanged. See definition no. 5 in preparing the response to this interrogatory RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery ofadmissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 ofCounter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court. 15. Identify separately for each payor the amounts and dates ofall sources of income paid to or for the benefit of you, whether directly or indirectly, for each and every year from January I, 2009 through the present date: (a)salaries, wages, or commissions: (b)honoraria (c) lecture fees (d)board membership, committee membership, advisory board membership and other management related compensation (including stock options and stock awards) (e) dividends: (f) interest: (g)income from businesses/professional activities: (h)partnership income: (i) limited liability membership income cp income from other investments (k)capital gains: (I) annuities and pensions: EFTA00798072 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories (m) rents and royalties: (n) income from estates and trusts: (o) disposition of commodities (p) disposition ofpersonal assets. (q) contracts or agreements See definition no. 5 in preparing the response to this interrogatory, and report such items separately for each distinct form of ownership in clauses (a), (b) and (c) of definition no. 5 and for each separate report, identify the owner. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave ofCourt. 16. With respect to each of the items set forth in the preceding interrogatory, state the name, address, email address, and telephone number of the source from which the income was received (and, where applicable, provide the account numbers of the accounts in the financial institutions in which such amounts were received by or for the benefit of you). RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court. 17. For each direct or indirect transfer, conveyance, or other disposition by or for the benefit of you, whether for or without consideration, at any time from March 1, 2009 through the present date of any cash, assets or other items of value with a fair market value of in excess of$5,000 provide a description of the property or asset transferred, the date of transfer, the fair market value on the date of transfer, the amount and nature of the full consideration received (if any), whether directly or indirectly, to whom the consideration was paid, and the full name, address, email address, telephone number and the relationship to you of the transferee. See definition no. 5 above in preparing your response to this interrogatory, and include in your response transfers at any time on or after December 7, 2009 by or to any of the persons listed in clauses (a), (b) and (c) of definition no. 5. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 EFTA00798073 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court. 18. At each of March 1, 2009, October I, 2009, December I, 2009, and August 1, 2012 and at the present date, identify each interest directly or indirectly held by you or for your benefit in any Individual Retirement Accounts, Stock Option Plans, pension or profit sharing plans, or any other savings or retirement plans other than those listed in response to previous interrogatories, and include in the response to this interrogatory a description of the type, amount and fair market value ofthe assets held as at such date. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave ofCourt. 19. Has a financial statement, credit application, loan application, lease application, financing application or other financial affidavit or questionnaire for you been prepared at any time during the period from March 1, 2009 through the present date? If so, state: (a) the name, address, email address and telephone number of the person or entity to whom the same was given; (b) the reason the same was prepared; (c) the date the same was prepared and submitted; and (d) the name, address, email address and telephone number of each person to whom the same was delivered and/or who currently has a copy of the same. See definition no. 5 above in preparing your response to this interrogatory, and include in your response financial statements, credit applications, loan applications, lease applications, financing applications or other financial affidavits or questionnaires prepared at any time on or after December 7, 2009 for any ofthe persons listed in clauses (a), (b) and (c) of definition no. 5. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 ofCounter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court. EFTA00798074 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories 20. Identify every legal action (including, without limitation, alternative dispute resolution proceedings) in which you have been a participant, including, but not limited to, as a party or as legal counsel at any time during the period in question, including, but not limited to, the title of the action, the name of the court, the case or index number, the presiding judge, arbitrator or other officiant, the date the action was filed, a brief description of the nature of the action, and the result of the legal action (e.g. judgment for or against of a certain amount). If you participated as counsel in such legal action, state the amount ofall remuneration you have received or which you are entitled to receive in connection with such participation, or if your remuneration is contingent on the outcome of such legal action or is subject to any similar arrangement and there has been no final disposition of such legal action, state in detail the terms of all agreements, understandings, and other arrangements relating to any remuneration you may be entitled to receive in connection with your participation in such legal action. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 ofCounter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court. In addition, this Interrogatory seeks to invade the attorney-client and work product privileges. 21. As at each of March I, 2009, October I, 2009, December 1, 2009, and August 1, 2012 and at the present date, identify every loan and advance extended to and outstanding from you, and in such identification include without limitation the name, address, email address and telephone number of the lender or identify the source of the advance, provide the date of the loan or the advance, the due dates of any installment payments, the maturity date, the principal amount, the rate of interest, the collateral or EFTA00798075 Edwards adv. Epstein Case No.: 502009CA040800X=CMBAG Notice of Serving Answers to Interrogatories security interest given by you, your purpose in borrowing funds, and the date and amount of each repayment. If any such loan or advance was memorialized pursuant to one or more agreements, promissory notes, or other instruments, describe each of the same, all amendments, modifications, and supplements thereto, the dates of the same, and all parties thereto, and identify and state the names, addresses, email addresses, and telephone numbers of all persons in possession or control of any and all embodiments of such agreements, promissory notes, other instruments, amendments, modifications and supplements, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format). Specifically provide the dates and amounts of all increases in the outstanding principal of any such loans or advances at any time on or after December 1, 2009, and the dates and amounts of all loan and advance repayments made at any time on or after December I, 2009 by any person or entity other than the original borrower thereunder. See definition no. 5 above in preparing your response to this interrogatory with respect to each such loan or advance, each such increase in the principal amount thereof, and each such repayment made at any time on or after December I, 2009. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave ofCourt. 22. At each of March I, 2009, October 1, 2009, December I, 2009, and August 1, 2012 and at the present date, identify all credit, debit, and/or automatic teller ("ATM") cards used by you, or controlled by you, regardless of whether such cards are titled in your name, at any time during the period in question, and for each such card, identify, state or describe the name and address of the financial institution that issued the card (i.e. VISA, MasterCard, American Express, bank, etc.), the name of the person to whom the card was issued (i.e, the name printed on the card), the card number printed on such card, the account number assigned by the financial institution for such card, the account debtor for such card and all outstanding account balances in excess of $5,000 as of such date. See definition no. 5 above in preparing your response to this interrogatory, and include in your response all credit, debit and ATM cards issued at any time on or after December 1, 2009 to any of the persons listed in clauses (a), (b) and (c) of definition no. 5. For each such account that is open as of any time on or after December I, 2009, specifically provide the dates and amounts of all increases in account balances in excess of $5,000 at any time on or after December 1, 2009, and the dates and amounts ofall account repayments in excess of $5,000 made at any time on or after December I, 2009 by any person or entity other than Bradley .1. Edwards, his spouse or the account debtor. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 EFTA00798076 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories ofCounter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court. 23. State whether at any time during the period December I, 2009 through the present date a trust was established by you, whether directly or indirectly, as grantor or settlor: (a) for any purpose, in whole or in part, relating to or having any effect of(i) protecting the wealth, assets, income, profits, investments, or other revenue of you or your spouse from legal claims or litigation, (ii) limiting the ability to quantify the actual value of and reducing the amounts of the personal wealth, assets, income, profits, investments or other revenue of you or your spouse, (iii) diverting assets, income, profits, investments or other revenue away from you or your spouse and to any of the persons listed in clauses (a), (b) and (c) of definition no. 5, or (iv) otherwise diverting future assets, income, profits, investments and other revenue away from you or your spouse while retaining effective control and or beneficial ownership or use thereof for yourself or herself or for the benefit of your family, and state, describe or identify: (a) all instruments governing the formation and administration of the trust, including the original trust agreement therefor, and all amendments, modifications, and supplements thereto; (b) the situs of the trust (c) the names, addresses, email addresses and telephone numbers of the settlors or grantors, the trustees, the trust protectors and the beneficiaries of the trust; (d) the assets of the trust, the locations of such assets, and the fair market value of the same at the time of creation and at each of December I, 2009, August 1, 2012 and the present date; (e) the location and persons in possession or control all documents that support your answer to this interrogatory. RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope ofDefinition #5 ofCounter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court. EFTA00798077 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories 24. Identify all federal, state, local and foreign income tax returns filed by or for you, and any businesses, corporations, partnerships, trusts, limited liability c