EFTA00608263.pdf

Filing # 60921203 E-Filed 08/25/2017 01:54:56 PM 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). MOTION TO COMPEL RESPONSES TO INTERROGATORIES OVER THE OBJECTIONS OF COUNTER-DEFENDANT JEFFREY EPSTEIN BRADLEY J. EDWARDS, by and through his undersigned attorneys, moves this Honorable Court to enter an order compelling Counter-Defendant, Jeffrey Epstein, to answer Interrogatories propounded by Counter-Plaintiff, Bradley J. Edwards, over the Objections of Jeffrey Epstein, and states: I. Counter-Defendant, JEFFREY EPSTEIN, filed Updated Responses to Net Worth Interrogatories propounded by Bradley Edwards. Almost all of the responses raise privilege objections and provide no substantive information. 2. The objections are not well-taken and should be overruled. EFTA00608263 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Motion to Compel Answers to Interrogatories Over Objections of Counter-Defendant, Epstein 3. Movant counsel certifies that a bona fide effort to agree or to narrow the issues on the Motion noticed hereby has been made with the opposing counsel or that because of time considerations such effort has not as yet been possible but will be made prior to the date of the hearing. WHEREFORE, Counter-Plaintiff moves for an Order requiring Counter-Defendant to answer the Net Worth Interrogatories in full within ten (10) days from the date of the Order, and providing that if said Counter-Defendant fails to serve sworn answers within that time be subject to the provisions of Rule 1.380, Florida Rules of Civil Procedure, and a judgment by default entered in favor of the Counter-Plaintiff, or for such other relief as the Court may deem proper under the laws of the State of Florida and the Florida Rules of Civil Procedure. Movant counsel certifies, in good faith, they have conferred or attempted to confer with the person or party failing to make the discovery in an effort to secure the information or material without court action. 2 EFTA00608264 Edwards adv. Epstein Case No.: 502009CA040800XX X X MBAG Motion to Compel Answers to Interrogatories Over Objections of Counter-Defendant, 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 P-CM—day of M stlliSC- 2017. JACK/SCA OLA Florida B No.: 169440 A E-Mail(s): P ary E-Mail: Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorneys or ey . Edwards 3 EFTA00608265 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Motion to Compel Answers to Interrogatories Over Objections of Counter-Defendant, Epstein COUNSEL LIST William Chester Brewer, Esquire Fred Haddad, Es Esquire 250 S Australian Avenue, Suite 1400 West Palm Beac FL 33401 Fred Haddad, P.A. Pho • One Financial Plaza, Suite 2612 Fax Fort 94 Attorneys ore y pstein Phone: Fax: Jack A. Goldberger, Esquire Attorneys or Epstein Tonja Haddad Coleman, Esquire Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fax: Phony Fort 33301 Attorneys for Jeffrey Epstein Phone: Fax: Attorneys for Jeffrey Epstein Farmer Jaffe Weissing Edwards Fistos & Marc S. Nurik, Es Esquire Lehrman, P.L. 425 N Andrews Avenue, Suite 2 One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Fort Lauderdale, FL 33301 Phone: Phone: Fax: Fax: Attorneys or cott othstein 4 EFTA00608266