EFTA01107365.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, Case No. 50 2009CA040800XXXXMB AG v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L M., individually, Defendants. EPSTEIN'S FIRST REOUEST FOR ADMISSIONS TO EDWARDS Plaintiff, JEFFREY EPSTEIN, pursuant to Fla. R. Civ. P. 1.370, requests that Defendant, BRADLEY J. EDWARDS ("Edwards" and/or "You" and/or "Your") admit or deny the following: 1. Admit that in Your March 23, 2010 deposition You testified under oath (at page 12), there are only three cases in existence against Jeffrey Epstein in which You represent a plaintiff (Jane Doe, L.M. and E.W.). 2. Admit that the testimony described in Request No. 1 is false. 3. Admit that in Your March 23, 2010 deposition you testified under oath You only filed three cases against Jeffrey Epstein. 4. Admit that the testimony described in Request No. 3 is false. 5. Admit that the Motion to Proceed Anonymously (DE #3) asserted that L.M. "was an identified victim by the FBI and U.S. Attorney's office in a criminal investigation against the Defendant, Jeffrey Epstein." EFTA01107365  6. Admit that the assertion in Request No. 5 is false. 7. Admit that in paragraph 8 of Your answer to the Complaint in this action, You asserted that "RRA never filed a lawsuit on behalf of L.M." 8. Admit that the assertion described in Request No. 7 is false. 9. Admit that in paragraph 8 of Your answer to the Complaint in this action, by You asserted that lawsuits filed on behalf of L.M. and other victims "were filed EDWARDS prior to any association with or knowledge of RRA." 10. Admit that the assertion described in Request No. 9 is false. 11. Admit that in paragraph 9 of the Complaint (DE #1) in Case No. 09-CV-81092 it is alleged that Epstein "coerc[ed] or forc[ed] the then-minor L.M. to perform oral sex on him." 12. Admit that the allegations described in Request No. -11 are false. 13. Admit that in paragraph 17 of Your answer to the Complaint in this action, You admitted that "[r]elevant to this action, EPSTEIN is currently named as a defendant in three civil actions alleging, inter alia, sexual assault and battery that were handled by RRA and its attorneys including EDWARDS prior to its implosion — one of which is filed in federal court (Jane Doe v. Epstein, Case No. 08-CIV-80893, U.S.D.C. S.D. Fla.)(Jane Doe is a named Defendant herein), and two of which have been filed in state court in the 15" Judicial Circuit Court, Palm Beach County, State of Florida, (L.M. v. Epstein, Case No. 502008C A028051XXXXMB AB; E.W. v. Epstein, Case No. 502008CA028058XXXXMB AB), (hereinafter collectively referred to as the "Civil Actions," and L.M is a named Defendant herein). The Civil Actions were all filed in August and September of 2008." 14. Admit that Scott Rothstein was involved in the decision to file the Complaint EFTA01107366 (DE #1) in Case No. 09-CV-81092. 15. Admit that Russell Adler was involved in the decision to file the Complaint (DE #1) in Case No. 09-CV-81092. 16 Admit that in her September 24, 2009 deposition L.M. testified under oath (at page 71), that she never had oral sex with Epstein. 17. Admit that You caused to be filed a Complaint (DE #1) on behalf of L.M. in the case styled L.M. v. Ieffrey Epstein, Case No. 09-CV-81092 in the United States District Court, Southern District of Florida, Miami Division on July 24, 2009. A copy of the Complaint is attached as Exhibit A. 18. Admit that a Complaint (DE #1) was filed on behalf of L.M. in the case styled L.M. v. Jeffrey Epstein, Case No. 09-CV-81092 in the United States District Court, Southern District of Florida, Miami Division, under Your name, Florida Bar number and e-mail address while you were employed by Rothstein, Rosenfeldt & Adler ("RRA"). 19. Admit that the Complaint (DE #1) in Case No. 09-CV-81092 is two hundred thirty-four (234) pages, contains six hundred forty-four (644) paragraphs and one hundred fifty- six (156) counts. 20. Admit that in Your March 23, 2010 deposition You testified under oath (at page 226) that You had no other professional e-mail addresses while at RRA except 21. Admit that a Motion to Keep True Name Sealed in Envelope (DE #2) was filed in Case No. 09-CV-81092 under Your name, Florida Bar number and e-mail address. 22. Admit that a Motion to Proceed Anonymously (DE #3) was filed on behalf of L.M. in Case No. 09-CV-81092 under Your name, Florida Bar number and e-mail address. EFTA01107367  Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. Mail to the following addressees on this IF day of June, 2010: Gary M. Farmer, Jr., Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Atterbury Goldberger & Weiss, P.A. Lehrman, PL 250 Australian Avenue South, Suite 1400 425 N. Andrews Avenue, Suite 2 West Palm Beach, FL 33401-5012 Fort Lauderdale, FL 33301 Fax: 561-835-8691 fax Co-Counsel for Defendant Jeffrey Epstein Attorneys for Defendant, L.M. Jack Scarola, Esq. MARC S. NURIK, ESQ. Searcy Denney Scarola Barnhart & Shipley, P.ALaw Offices of Marc S. Nurik 2139 Palm Beach Lakes Blvd. One East Broward Boulevard West Palm Beach, FL 33409 Suite 700 Fort Lauderdale FL 33301 F Fax Attorneys for Defendant Bradley Edwards Attorneys for Defendant Scott Rothstein FOWLER WHITE BURNETT, P.A. Attorneys for Plaintiff Jeffrey Epstein Espirito Santo Plaza 1395 Brickell Avenue, 14th Floo Miami, Florida 33131 305.789.9200 305.789.9201 fax By: '. Sanchez, Esq. da Bar No. 195677 EFTA01107368 07/07/2010 13:39 FAX 5616845816 SEARCY DENNEY 1001/004 #2,1874/mep IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003OOaMBAG JEFFREY EPSTEIN, Plaintiff, vs.' SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, EDWARDS' RESPONSE TO FIRST REQUEST FOR ADMISSIONS Defendant/Counterplaintiff, BRADLEY J. EDWARDS, hereby files his Response to Plaintiff, JEFFREY EPSTEIN'S First Request for Admissions to Edwards dated June 18, 2010 as hollows: I 1. Denied. The transcript is accurate but Request for Admission No. 1 does not acc&ately describe the testimony. 2. Denied. A Complaint was filed in Federal Court against Jeffrey Epstein on behalf of L.M., but never served. 3. Denied. 4. Denied on the grounds that no such testimony was given. 5. Admitted. 6. Denied. 7. Admitted. EFTA01107369 07/07/2010 13:40 FAI 5616845816 SEARCY DENNEY a002/004 Case No.: 502009CA040800X)OOCv1BA0 EDWARDS' REPONSE TO FIRST REQUEST FOR ADMISSIONS Page 2 of 4 8. Denied. While a second Complaint was filed in Federal Court on behalf of L.M., it was never served and, therefore, RRA never prosecuted a lawsuit on behalf of L.M. except for the (suit filed prior to Edwards' association with RRA. 9. Admitted. 10. Denied. See response to Request for Admission No. 8. 11. Admitted. 12. Admitted. This allegation which is accurate as to E.W. was mistakenly carried over to L.M. in the drafting of the Complaint on behalf of L.M. 13. Admitted. 14. Denied. 15. Denied. 16. Admitted. 17. Admitted. 18. Admitted. 19. Admitted. 20. Admitted. 21. Admitted. 22. Admitted. 23. Admitted_ 24. Admitted. 25. Admitted. EFTA01107370 07/07/2010 13:40 FAX 5818845816 SEARCY DENNEY a003/004 Case No.: 502009CA040800X3COLMBAO EDWARDS' REPONSE TO FIRST REQUEST FOR ADMISSIONS Page 3 of 4 26. Admitted. 27. Admitted. 28. Admitted. 29. Admitted. 30. Denied. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Fax and U.S. Mail to all counsel on the attache day of July, 2010. Jack S Flori No.: 169440 Sea b enney Scarola Barnhart & Shipley, P.A. 21 alm Beach Lakes Boulevard est 33409 Phone: Fax: (561) 383-9451 Attorneys for Bradley J. Edwards EFTA01107371 07/07/2010 13:41 FAX 6616846816 SEARCY DENNEY e004/004 Case No.: 502009CA040800XXXXMBAG EDWARDS' REPONSE TO FIRST REQUEST FOR ADMISSIONS Page 4 of 4 COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach FL 33401 PhOne Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Fariner, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: Fax: (954)-524-2822 ill uir Fowler White Burnett, P.A. 777 S Flagler Drive, Suite 901 West PiiiiiiS3401 Phone: Fax: (561)-802-9976 Attorneys for Jeffrey Epstein Law Offices of Marc S. NuriJc One E Broward Blvd., Suite 700 Fort La FL 33301 Phone: Fax: (954)-745- Attorneys for Scott Rothstein EFTA01107372