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,\ [REDACTED] J. [REDACTED], individually, and\ L.M., individually Defendant(s). **REQUEST FOR ADMISSIONS TO JEFFREY EPSTEIN** COMES NOW the Counter-Plaintiff, Bradley J. [REDACTED], 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. 1. Admit that you have publicly been described as a billionaire. 1. 2. Admit that press reports have described you as a billionaire. 1. 3. Admit that you have never publicly disputed the description of you as a billionaire. 1. 4. Admit that you have never publicly disputed any press reports describing you as a billionaire. 1. 5. Admit that you are a billionaire. 1. 6. Admit that you have been a billionaire sometime within the past 5 years. 1. 7. Admit that you have been a billionaire sometime within the past 10 years. SHARON BOCK-CLERK\ PALM BEACH COUNTY\ CIRCUIT CIVIL / PROBATE\ 2013 FEB 27 PM 3:35\ FILED - 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 q ut er iof a billion dollars at times during the past 5 years. - 12. Admit that you have never paid even oncpenn -in punitive damages to any person who has alleged that you engaged in improper sexual conduct with them while that person was a minor. < 4\\ - 13. Admit that you have never spent even one day in a state or federal prison facility (as opposed to a c o 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. adv. Epstein Case No.: 502009CA040800)00004BAG Request for Admissions to Jeffrey 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 day of February, 2013. Jack Sc Flon No.: 169440 Pri E-mail: jsx®searcylaw.com S dary E-mail(s): mep®searcylaw.com 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 AttoVor J. ?S' C adv. Epstein Case No.: 502009CA040800XXXXMBAG Request for Admissions to Jeffrey Epstein ## COUNSEL LIST Jack A. Goldberger, Esquire jgoldberger@agwpa.com; smahoney@agwpa.com Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein J. M, Esquire staff.efile@pathtojustice.com, Jaffe, Weissing, Fistos & Lehrman, FL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (954) 524-2822 Fred Haddad, Esquire Dee@FredHaddadLaw.com; haddadfm@aol.com Fred Haddad, P.A. One Financial Plaza, Suite/IA\*2 Fort Lauderdale, FL 33394 Phone: (954)-467-6767 Fax: (954)467-3599 Attorneys for Jeffrey Epstein Marc S. Nurik, Esquire marc@nuriklaw.com Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein Lilly Ann la Esquire lsanchez@thelsfirm.com The L-S Law Firm 1441 Brickell Avenue, 15th Floor Miami, FL 33131 Phone: (305)-503-5503 Fax: (305)-503-6801 Attorneys for Jeffrey Epstein Tonja Haddad Coleman, Esquire tonja@tonjahaddad.com; Debbie@Tonjahaddad.com Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: (954)467-1223 Fax: (954)-337-3716 Attorneys for Jeffrey Epstein