EFTA01080969.pdf

06/09/2011 14:19 FAX 5618845816 SEARCY DENNEY 11001/004 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXIMAG JEFFREY EPSTEIN, Plaintiff(s), VS. . SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M, individually, Defendant(s). I gLAINTIFFS' REQUEST FOR PRODUCTION TO JEFFREY EPSTEIN Defendant/Counterplaintiff, Bradley J. Edwards by and through his undersigned counsel, reqdests, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that Plaintiff/Counterdefendant, Jeffrey Epstein, produce and permit Bradley J. Edwards to inspect and lcopy each of the following documents*: 1. Any and all documents* reflecting, relating to, or suggesting that Edwards had knowledge about Rothstein's commission of or attempt to commit any fraud prior to the public disclosure of Rothstein's criminal conduct. 2. Any and all documents* which in any way support the claim or claims that Epstein is pursuing against Edwards. 3. All emails that Epstein intends to use or may use as a trial exhibit. 4. All documents* that rebuts, refutes, and/or contradicts the claims Epstein is putting against Edwards. EFTA01080969 06/09/2011 14:19 FAX 5616845816 SEARCY DENNEY R1002/004 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Reqiest for Production to Jeffrcy Epstein 5. Statements from anyone that in any way support the claims Epstein is pursuing against Edwards. "'Documents" shall include, but not be limited to all non-identical copies of writings, drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data compilations from which information can be obtained, translated, if necessary, by the party to wham the request is directed through detection devices into reasonably usable form. "Thicuments" also include all electronic data as well as application metadata and system metadata. All inventories and rosters of your information technology (IT) systems—e.g., hardware, software and data, including but not limited to network drawings, lists of computing devices (servers, PCs, laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps and security tools and protocols. It is requested that the aforesaid production be made within thirty days of service of this request at the offices of Searcy Denney Scarola Barnhart & Shipley, M., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida. Inspection will be made by visual observation, examination and/or copying. 2 EFTA01080970 06/09/2011 14:20 FAX 5616845816 SEARCY DENNEY itoo3/004 Edwards adv. Epstein Case No.: 502009CA040800,000CMBAG Rainest for Production to Jeffrey Epstein I HEREBY CERTIFY that a true and correct copy of e foregoing has been furnished by Fax1and U.S. Mail to all Counsel on the attached list, this r day of June, 2011. Jack a Flo ear No.: 169440 S Denney Scarola Barnhart & Shipley 9 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorneys 3 EFTA01080971 06/09/2011 14:20 FAX 5616845816 SEARCY DENNEY U1004/004 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAO Request for Production to Jeffrey Epstein COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, PA, Attome For: Jeffre E. stein Fame; Jaffe, Weissing, Edwards, Fistos & Lehrman, PL (111.1 6/ Maje S. Nurik Lay{ Offices of Marc S. Nurik Attorney For: Sc Jos4ph L. Ackerman, Jr., Esquire Fowler White Burnett, P.A. Attorney For: Jeffrey Epstein Martin Weinberg, Es uire Martin Weinberg, 4 EFTA01080972