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:¶
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- Admit that you have publicly been described as a billionaire.
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- Admit that press reports have described you as a billionaire.
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- Admit that you have never publicly disputed the description of you as a billionaire.
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- Admit that you have never publicly disputed any press reports describing you as a billionaire.
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- Admit that you are a billionaire.
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- Admit that you have been a billionaire sometime within the past 5 years.
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- 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¶
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- Admit that you have a reputation as being a billionaire.
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- Admit that your personal net worth has exceeded a billion dollars at times during the past 5 years.
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- Admit that your personal net worth has exceeded half a billion dollars at times during the past 5 years.
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- Admit that your personal net worth has exceeded a q ut er iof a billion dollars at times during the past 5 years.
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- 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\
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- 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¶