EFTA00792321.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). REQUEST FOR ADMISSIONS TO JEFFREY EPSTEIN COMES NOW the Counter-Plaintiff, Bradley J. Edwards, by and through his undersigned counsel and propounds the following Request for Admissions pursuant to Rule 1.370 Florida Rules of Civil Procedure, requesting that Counter-Defendant, Jeffrey Epstein, admit the truth of the facts set forth as follows: 1. Admit that you have publicly been described as a billionaire. 2. Admit that press reports have described you as a billionaire. 3. Admit that you have never publicly disputed the description of you as a billionaire. 4. Admit that you have never publicly disputed any press reports describing you as a billionaire. 5. Admit that you are a billionaire. 6. Admit that you have been a billionaire sometime within the past 5 years. 7. Admit that you have been a billionaire sometime within the past 10 years. EFTA00792321 Edwards adv. Epstein Case No.: 502009CA040800)OOOCMBAG Request for Admissions to Jeffrey Epstein 8. Admit that you have a reputation as being a billionaire. 9. Admit that your personal net worth has exceeded a billion dollars at times during the past 5 years. 10. Admit that your personal net worth has exceeded half a billion dollars at times during the past 5 years. 11. Admit that your personal net worth has exceeded a quarter of a billion dollars at times during the past 5 years. 12. Admit that you have never paid even one penny in punitive damages to any person who has alleged that you engaged in improper sexual conduct with them while that person was a minor. 13. Admit that you have never spent even one day in a state or federal prison facility (as opposed to a county jail) as punishment for any sex-related crime. Pursuant to the Rules of Civil Procedure, each fact on which admission is requested shall be deemed admitted if not denied or if no reply is received on or before March 28, 2013. 2 EFTA00792322 Edwards adv. Epstein Case No.: 502009CA040800)OOOCMBAG Request for Admissions to Jeffrey Epstein I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve ll to all Counsel on the attached list, this i i fr- day of February, 2013. Jack S Flori. No.: 169440 P" E-mail: S dary E-mail(s): cy 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 3 EFTA00792323 Edwards adv. Epstein Case No.: 502009CA040800)OOOO4BAG Request for Admissions to Jeffrey Epstein COUNSEL LIST Jack A. Goldber •uire Marc S. Nurik, Esquire Law Offices of Marc S. Nurik Atterbury, Goldberger & Weiss, P.A. One E Broward Blvd., Suite 700 250 Australian Avenue South, Suite 1400 Fort Lauderdale, FL 33301 West Palm Beach, FL 33401 Phone: (954)-745-5849 Phone: (561)-659-8300 Fax: (954)-745-3556 Fax: (561)-835-8691 Attorneys for Scott Rothstein Attorneys for Jeffrey Epstein Lilly Ann Sanchez, Esquire Bradley J. EdwardsEsquire Farmer, Jaffe, Weissing, Edwards, Fistos & 1441 Brickell Avenue, 15th Floor Lehrman, FL Miami, FL 33131 425 North Andrews Avenue, Suite 2 Phone: (305)-503-5503 Fort Lauderdale, FL 33301 Fax: (305)-503-6801 Phone: (954) 524-2820 Attorneys for Jeffrey Epstein Fax: (954) 524-2822 Tonja Haddad Coleman Es uire Fred Haddad •titre Tonja Haddad, P.A. Fred Haddad, P.A. 315 SE 7th Street, Suite 301 One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33301 Fort Lauderdale, FL 33394 Phone: (954)467-1223 Phone: (954)467-6767 Fax: (954)-337-3716 Fax: (954)-467-3599 Attorneys for Jeffrey Epstein Attorneys for Jeffrey Epstein 4 EFTA00792324