EFTA01106932.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT EPSTEIN'S RESPONSES TO INTERROGATORIES 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 hereby files his responses to Defendant/Counter-Plaintiff Bradley Edward's Interrogatories to Jeffrey Epstein: A. With regard to all communications that occurred at any time prior to the filing of your civil lawsuit against Bradley Edwards in which communication you expressed the position that Bradley Edwards was a knowing participant in the efforts of Scott Rothstein to defraud investors (the Scott Rothstein Ponzi scheme) or that Bradley Edwards engaged in any misconduct relating to the Scott Rothstein Ponzi scheme, state the following: 1. a detailed description of the contents of the communication; 2. all participants in and parties to the communication; 3. the date, time, place and circumstances of the communication EFTA01106932  including how the communication was made; 4. whether, when, how and why the contents of the communication were ever subsequently related to any other person; 5. whether and how the contents of the communication were ever memorialized in any manner and, if so, the identity of everyone having custody of such memorialization. B. With regard to any request, direction, or authorization to sue Bradley Edwards communicated by you at any time prior to the filing of your civil lawsuit against Bradley Edwards, state the following: 1. a detailed description ofthe contents ofthe communication; 2. all participants in and parties to the communication; 3. the date, time, place and circumstances of the communication including how the communication was made; 4. whether, when, how and why the contents of the communication were ever subsequently related to any other person; 5. whether and how the contents of the communication were ever memorialized in any manner and, if so, the identity of everyone having custody of such memorialization. WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this September 20, 2013. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONIA HADDAD, PA 315 SE Th Street Suite 301 Fort Lauderdale, Florida 33301 (facsimile) EFTA01106933  SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . ; Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . ; Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradle , dwards, E . Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Es 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Ton'a Haddad Coleman, Esquire Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein EFTA01106934