Draft: efta02772386

PALM BEACH COUNTY. FL SHARON R BOCK. CLERK.•" 121 U- -a • •¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800)OOaMBAG¶

vs.¶

SCOTT ROTHSTEIN individually, J. , individually, Defendant/Counter-Plaintiff.¶

PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO QUASH SUBPOENAS DUCES TECUM AND FOR SANCTIONS¶

Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rules 1.351 and Rule 1.401 of the Florida Rules of Civil Procedure, hereby files this Motion to Quash Defendant/Counter-Plaintiff improperly and impermissibly served Subpoenas Duces Tecum and for sanctions, and states:¶

RODUCTION¶

On September 11, 20 Crallwards served upon Epstein "Subpoenas Duces Tecum Without Deposition" for following non-party individuals; all of whom are Epstein's former counsels: Darren Indyke, Esq., Roy Black, Esq., Knight, Esq., Robert Critton, Esq., L. Ackerman, Jr., Esq., Alan Dershowitz, Esq., and Jack Goldberger, Esq. True and correct copies of these subpoenas are attached hereto as composite "Exhibit A." While there was not a proper Notice of Production from Non-Party as required by Rule 1.351(b) of the Florida Rules of Civil Procedure, Epstein acted in accordance with Rule 1.351 and timely filed a Notice of Objection to the Subpoenas on September 19, 2013. A true and correct copy of same is attached hereto as "Exhibit B." On September 20, 2013, Epstein became aware that¶

had impermissibly served these "Subpoenas Duces Tecum Without Deposition" upon the attorneys simultaneously with serving the copies of the Subpoenas on Epstein. On September 21, 2013 Epstein was also informed that served one of Epstein's former attorneys with a Subpoena Duces Tecum without Deposition for whom a copy was never even sent to Epstein (Lilly MI). Accordingly, Epstein requests that this Court quash the subpoenas, preclude from seeking discovery from Epstein's former counsels on the eve of trial, and award attorneys' fees and costs as sanctions for flagrant disregard for the Rules.¶

MEMORANDUM OF LAW ) ..)1¶

Epstein's former attorneys are irrefutably not parties to thittle As such, Rule 1.351 of the Florida Rules of Civil Procedure governs. Rule 1.351 provides:¶

A party desiring production under this rule shall serve notice as provided in rule 1.080 on every other party of the intent to serve a subpoena under this rule at least 10 days before the subpoena is issued if service is by delivery and 15 days before the subpoena is issued if the service is by mail or e-mail. The proposed subpoena shall be attached to the notice and shall state the time, place, and method for production of the documents or things, and the name and address of the person who is to produce the documents or things, if known, and if not known, a general description sufficient to identify the person or the particular class or group to which the person belongs; shall include a designation of the items to be produced; and shall state that the person who will be asked to produce the documents or things has the right to object to the production under this rule and that the person will not be required to surrender the documents or things. A copy of the notice and proposed subpoena shall not be furnished to the person upon whom the subpoena is to be served. If any party serves an objection to production under this rule within 10 days of service of the notice, the documents or things shall not be produced pending resolution of the objection in accordance with subdivision (d).¶

Fla. R.Civ. P 1.351 (2013). Here, Epstein filed a timely objection to the subpoenas as delineated by the Rule. Conversely in flagrant disregard for this Rule, failed not only to provide the requisite notice, but also immediately and impermissibly served these subpoenas upon Epstein's former attorneys, forcing Epstein to file this Motion. actions mandate that this Court quash the subpoenas, prohibit from seeking the information requested in the improper subpoenas, and award Epstein his costs and fees incurred in responding to impermissible tactics.¶

Epstein's timely objection to the subpoenas duces tecum would have been self-executing and would not have required Epstein to incur the additional costs and fees associated with responding to disregard of procedure. See ABC Liquors, Inc. v. Berkey. 589 So. 2d 457, 458 (Fla.5th DCA 1991); see also Rule 1.351(c) ("If the person upon whom the subpoena is served objects at any time before the production of the documents or things, the documents or things shall not be produced under this rule, and relief may be obtained pursuant to [the rule governing depositions]."). Coiling & Gilbert, P. v. o 56 So. 2d 201, 201 (Fla. 2d DCA 2000). However, because impermis ib1 these subpoenas upon Epstein's former counsel, he must seek redress from th e court, "upon motion made promptly and in any event at or before the time s m e subpoena for compliance therewith, may . . . quash or modify the subpoena if it is unreasonable and oppressive." Fla. R.Civ. P. 1.410(c). Likewise, a party who successfully opposes a subpoena duces tecum may be awarded attorneys' fees. Expeditions Unlimited, Inc. v. Roily Marine Services, Inc., 447 So. 2d 453 (Fla. 4th DCA 1984). Here, subpoenas requesting information from Epstein's former attorneys regarding their representation of him, which were impermissibly served upon them on the eve of trial and without compliance of the Rules of Civil Procedure, are irrefutably and on their faces unreasonable and oppressive, mandating that they be quashed and sanctions awarded. See Exhibit A.¶

While "[i]t is apodictic that one who is a party has no standing to object to a subpoena issued to a non-party witness unless that subpoena asks for documents in which the party claims some personal right or privilege or asks for documents in the party's possession." Engel v. Bigot. 434 So. 2d 954, 957 (Fla. 3d DCA 1983) (Pearson, J., concurring), it is obvious from the face of the subpoenas in the instant case not only that Epstein's timely objection to the issuance of the subpoenas was proper, but also that he has standing to move this court to quash them. Accordingly, attempts to circumvent the Rules, and this privilege, mandate that these subpoenas be quashed and sanctions awarded.¶

CONCLUSION¶

For all of the reasons cited above, and in reliance upon the law cited herein, Epstein requests that this Court enter and Order Quashing Subpoenas, precluding him from seeking this discovery from Epstein's former attorneys on the eve of trial, and awarding attorneys' fees incurred in the bringing of this Motion.¶

WE HEREBY CERTIFY that a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this September 21, 2013.¶

/s/ Tonja Haddad Coleman Tonja Haddad Coleman, Fsq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimile) Attorneys for Epstein
¶

SERVICE LIST¶

CASE NO. 502009CA040800XXXXMBAG¶

Jack Scarola, Esq. jsx@searcylaw.com; mep®searcylaw.com Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409¶

Jack Goldberger, Esq. jgoldberger@agwpa.com; smahoney@agwpa.com 4. 4..? Suite 1400 West Palm Beach, FL 33401 Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South¶

C )O 1¶

Suite 700 Marc Nurik, Esq. 1 East Broward Blvd. "S) Fort Lauderdale, FL 33301¶

J. a, Esq. Srathtojustice.com brar Jaffe Weissing Fistos S 425 N Andrews Avenue Suite 2 C Fort Lauderdale, Florida 33301¶

Fred Haddad, Esq. Dee@FredHaddadLaw.coty 1 Financial Plaza i c Suite 2612 Fort Lauderdalerk1301¶

Tonja Haddad Coleman, Esquire Tonja@tonjahaddad.com; efiling@tonjahaddad.com Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

CASE NO.: 502009CA040800XXXXIViBAG¶

JEFFREY EPSTEIN,¶

Plaintiff(s),¶

vs.¶

COTT ROTHSTEIN individually, J. , individually, and L.M., individually,¶

Defendant(s). cis SUBPOENA WITHOUT DEPOSITION¶

THE STATE OF FLORIDA¶

TO: Alan Dershowitz, Esquire¶

YOU ARE COMMA pear at Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Bou evard, West Palm Beach, Florida, 33409 on October 10, 2013 at 9:00 am. and to have with you at that time and place the following:¶

Ducts Tecum: All documents* reflecting any and all communications between you (or anyone acting on your behalf) and Jeffrey Epstein (or anyone acting on his behalf) which communication related directly or indirectly to the basis for and/or the viability of any claim by Epstein against¶

These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DE IliVS ON. NO TESTIMONY WILL BE TAKEN.¶

*The term "documents" includes but is agt 't tted to all non-identical copies of letters, notes, memoranda, e-mails, faxes, records, transcripts, and entries, regardless of whether they were made manually, mechanical) lectTnically, magnetically, digitally, or by any other ) means, and regardless of whe r they on papers, tape, film, electronic devices, electronic media, as well as application metadata and system metadata, or any other media or thing.¶

If you all to:¶

1. Appear as specified; or
1. Furnish the records instead of appearing as provided above; or
1. Object to this subpoena,

[REDACTED] adv. Epstein
Case No. 502009CA040800XXXXXMBAG
Subpoena to Non-Party
Page3¶

You may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed.¶

DATED this 11^th day of September, 2013.¶

Jack Scarola
Florida Bar No.: 169440
Primary E-mail: jsx@searcylaw.com
Secondary E-mail(s): mep@searcylaw.com
Searcy 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 [REDACTED] J. [REDACTED]¶

NOTA CERTIFIED COPY¶

adv. Epstein Case No. 502009CA040800XXXXIVIBAG Subpoena to Non-Party Page4¶

CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION¶

STATE OF FLORIDA COUNTY OF¶

The undersigned, as custodian of records for es that the attached documents consisting of pages represents a true of I items within my possession, custody or control which are described in the Sas Duces Tecum Without Deposition served on me in the above styled action and each page is numbered by me for identification. Production is complete and has been numbered by the custodian of records.¶

It is further certified that originals 4e items produced are maintained under the direction, custody and control of the tut et¶

The foregoing Certificatio acknowledged before me, an officer duly authorized in the State and County aforesaid to take acknowledgments, this day of 20 , who:¶

is personally known to me; or has produced as identification; and who: did or did not, take an oath,¶

and who executed the foregoing certification, and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited.¶

Notary Public, State of Florida at Large My Commission Expires:
¶

adv. Epstein Case No. 502009CA040800)OOOCMBAG Subpoena to Non-Party Page5¶

COUNSEL LIST¶

Jack A. Goldberger, Esquire jgoldberger©agwpa.com; smahoney@agwpa.corn 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 stafrefile@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.coP* haddadfm@aol.com Fred Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: (954)467-6767 Fax: (954)-467-3599 Attorneys for Jeffrey Epstein¶

Marc S. Nurik, Esquire mareurildaw.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 Tonja Haddad Coleman, Esquire tonjac@tonjahaddad.com; Debbie@Tonj ahaddad.com Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: (954)467-1223 F ax: (954)-337-3716 meys for Jeffrey Epstein¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

CASE NO.: 502009CA040800)OOOCMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff(s),¶

vs.¶

SCOTT ROTHSTEIN, individually, J. L.M., individually, , individually, and¶

Defendant(s).¶

SUBPOENA WITHOUT SS Ito < C4 ON¶

THE STATE OF FLORIDA¶

TO: L. Ackerman, Jr., Esquire*,¶

YOU ARE COMMANDED to pear at Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 10, 2013 at 9:00 a.m. and to have with you at that time and place the following:¶

O Duces Teat Ar, All documents* reflecting any and all communications between you (or anyone acting on your behalf) and Jeffrey Epstein (or anyone acting on his behalf) which communication related directly or indirectly to the basis for and/or the viability of any claim by Epstein against M¶

< \¶

scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.¶

*The term "documents" includes but is ruk ted to all non-identical copies of letters, notes, memoranda, e-mails, faxes, records, transcripts, and entries, regardless of whether they were made manually, mechanically, electronically, magnetically, digitally, or by any other means, and regardless of whether they are on papers, tape, film, electronic devices, electronic media, as well as application metadata and system metadata, or any other media or thing.¶

If you fail to:¶

14/ _ ppear as specified; or
1. Furnish the records instead of appearing as provided above; or
1. Object to this subpoena,

adv, Epstein Case No. 502009CA040800)OC)OCMBAG Subpoena to Non-Party Page3¶

DATED this day of September, 2013.¶

CO S¶

a¶

ar No.: 169440¶

E-mail: jsx®searcylaw.com¶

Mary E-mail(s): mep@searcylaw.com ¶

cy Denney Scarola Barnhart & Shipley, PA.¶

139 Palm Beach Lakes Boulevard¶

West Palm Beach, Florida 33409¶

Phone: (561) 686-6300¶

Fax: (561) 383-9451¶

Attorneys for J.¶

adv. Epstein Case No. 502009CA0408003OOCO4:BAG Subpoena to Non-Party Page4¶

CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION¶

STATE OF FLORIDA COUNTY OF¶

The undersigned, as custodian of records for Sits that the attached documents consisting of pages represents a true of 1 items within my possession, custody or control which are described in the a Duces Tecum Without Deposition served on me in the above styled action and'each' page is numbered by me for identification. Production is complete and has been numbered by the custodian of records.¶

It is further certified that originals of the items produced are maintained under the direction, custody and control of the¶

The foregoing Certificatio acknowledged before me, an officer duly authorized in the State and County aforesaid to take acknowledgments, this day of 20 , who:¶

personally known to me; or produced as identification; and who: or id not, take an oath,¶

and who executed the foregoing certification, and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited.¶

Notary Public, State of Florida at Large My Commission Expires:
¶

adv. Epstein Case No. 502009CA0408005000CMBAG Subpoena to Non-Party Page5¶

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 Lehrman, FL Jaffe, Weissing, Fistos & 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (954) 524-2822¶

Fred Haddad, Esquire Dee@FredHaddadLaw.cot haddadfm@aol.com Fred Haddad, PA One Financial Plaza, Suite 2612 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 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 F : (954)-337-3716 eys for Jeffrey Epstein¶

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, J. L.M., individually, individually, and¶

Defendant(s).¶

9¶

SUBPOENA WITHOUT DEPOSITION¶

THE STATE OF FLORIDA¶

TO: Jack A. Goldberger, Esquire¶

YOU ARE COMMANDED' kto gear at Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 10, 2013 at 9:00 am. and to have with you at that time and place the following:¶

(S\¶

Duces Tecum: All documents* reflecting any and all communications between you (or anyone acting on your behalf) and Jeffrey Epstein (or anyone acting on his behalf) which communication related directly or indirectly to the basis for and/or the viability of any claim by Epstein against¶

*The term "documents" includes but is n notes, memoranda, e-mails, faxes, recur were made manually, mechanically means, and regardless of whether they * %IC2 tied to all non-identical copies of letters, ts, and entries, regardless of whether they tally, magnetically, digitally, or by any other on papers, tape, film, electronic devices, electronic media, as well as application metadata and system metadata, or any other media or thing.¶

If you¶

as specified; or
1. Furnish the records instead of appearing as provided above; or
1. Object to this subpoena,

adv. Epstein Case No. 502009CA040800XXXXMBAO Subpoena to Non-Party Page3¶

DATED this day of September, 2013.¶

CO S¶

Jack a¶

Fl a ar No.: 169440¶

E-mail: jsx@searcylaw.com ¶

notary E-mail(s): mep@searcylaw.com ¶

y Denney Scarola Barnhart & Shipley, P.A.¶

139 Palm Beach Lakes Boulevard¶

West Palm Beach, Florida 33409¶

Phone: (561) 686-6300¶

Fax: (561) 383-9451¶

Attorneys for J.¶

direction, custody and control of the It is further certified that originals of the items produced are maintained under the¶

adv. Epstein Case No. 502009CA040800XXXXMBAO Subpoena to Non-Party Page4¶

CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION¶

STATE OF FLORIDA COUNTY OF¶

The undersigned, as custodian of records for es that the attached documents consisting of pages represents a true of items within my possession, custody or control which are described in the a Duces Tecum Without Deposition served on me in the above styled action page is numbered by me for identification. Production is complete and has been manbere by the custodian of records.¶

4C+ 14k¶

The foregoing Certificati acknowledged before me, an officer duly authorized in the State and County aforesaid to take acknowledgments, this day of 20_, who:¶

[ is personally known to me; or [ has produced as identification; and who: [ did or [ did not, take an oath,¶

and who executed the foregoing certification, and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited.¶

Notary Public, State of Florida at Large My Commission Expires:
¶

adv. Epstein Case No. 502009CA040800)OOOGMBAG Subpoena to Non-Party Page5¶

COUNSEL LIST¶

Jack A. Goldberger, Esquire jgoldberger@agwpasom; smalioney@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 Farmer, 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 2612 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 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¶

ro¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

CASE NO.: 502009CA040800)OOCXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff(s),¶

vs.¶

SCOTT ROTHSTEIN individually, individually, and L.M.,¶

Defendant(s).¶

SUBPOENA WITHOUT liS t ki ON¶

THE STATE OF FLORIDA¶

TO: Darren K. Indyke, Esquire 301 East 66th Street, #10B New York, NY 10065¶

YOU ARE COMMAND appear at Seamy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 10, 2013 at 9:00 am. and to have with you at that time and place the following:¶

*The term "documents" includes but is n notes, memoranda, e-mails, faxes, recor Ste o v%1 Call non-identical copies of letters, ts, and entries, regardless of whether they were made manually, mechanically ctonically, magnetically, digitally, or by any other means, and regardless of whether they are on papers, tape, film, electronic devices, electronic media, as well as application metadata and system metadata, or any other media or thing.¶

If you¶

ar as specified; or
1. Furnish the records instead of appearing as provided above; or
1. Object to this subpoena,

adv. Epstein Case No. 507.009CA040800XXXXMBAG Subpoena to Non-Party Page3¶

DATED this (( day of September, 2013.¶

No.: 169440 E-mail: jsx®searcylaw.com ndary E-mail(s): mep®searcylaw.com y Denney Scarola Barnhart & Shipley, P.A. 39 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for J.¶

adv. Epstein Case No. 502009CA040800XXIOCMBAG Subpoena to Non-Party Page4¶

CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION¶

STATE OF FLORIDA COUNTY OF¶

The undersigned, as custodian of records for es that the attached documents consisting of pages represents a true co of items within my possession, custody or control which are described in the Duces Tecum Without Deposition served on me in the above styled action )page is numbered by me for identification. Production is complete and has been nurnhere y the custodian of records.¶

It is further certified that originals of the items produced are maintained under the direction, custody and control of the uncle * dr¶

The foregoing Certificatio acknowledged before me, an officer duly authorized in the State and County aforesaid to take acknowledgments, this day of 20 , who:¶

[ ] is personally known to me; or [ ] has produced as identification; and who: ] Sid or 'd not, take an oath,¶

and who executed the foregoing certification, and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited.¶

Notary Public, State of Florida at Large My Commission Expires:
¶

adv. Epstein Case No. 502009CAG40800)000043A0 Subpoena to Non-Party PageS¶

COUNSEL LIST¶

Jack A. Goldberger, Esquire jgoldberger@agwpa.com; stnahoney®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. 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®FredHaddadLa .cont haddadfm@aol.com Fred Haddad, P.A. One Financial Plaza, Suite 2612 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 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¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

CASE NO.: 502009CA040800XXDOCMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff(s),¶

vs.¶

l Ca1•1' ROTHSTEIN individually, J. individually, and L.M., individually,¶

Defendant(s).¶

SUBP I ENA WITH¶

THE STATE OF FLORIDA¶

TO: Robert Critton, Esquire¶

YOU ARE COMMANDE6er to at Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 10, 2013 at 9:00 a.m. and to have with you at that time and place the following:¶

Duces Tecu÷(..) All document? reflecting any and all communications between you (or anyone acting on your behalf) and Jeffrey Epstein (or anyone acting on his behalf) which communication related directly or indirectly to the basis for and/or the viability of any claim by Epstein against¶

2 .:S.C 2 *The term "documents" includes but is not flitted to all non-identical copies of letters, notes, memoranda, e-mails, faxes, records, transcripts, and entries, regardless of whether they were made manually, mechanically, electronically, magnetically, digitally, or by any other means, and regardless of whether they are on papers, tape, film, electronic devices, electronic media, as well as application metadata and system metadata, or any other media or thing.¶

If you fail to:¶

ppear as specified; or
1. Furnish the records instead of appearing as provided above; or
1. Object to this subpoena,

adv. Epstein Case No. 502009CA040800)OOCXMBAG Subpoena to Non-Party Page3¶

CO¶

AS A"¶

DATED this day of September, 2013.¶

+6s¶

Jack¶

Flo o.: 169440¶

E-mail: jsx@searcylaw.com ¶

ndary E-mail(s): mep@searcylaw.com ¶

y Denney Scarola Barnhart & Shipley, P.A.¶

39 Palm Beach Lakes Boulevard¶

West Palm Beach, Florida 33409¶

Phone: (561) 686-6300¶

Fax: (561) 383-9451¶

Attorneys for J.¶

adv. Epstein Case No. 502009CA04080030CXXMEIAG Subpoena to Non-Party Page4¶

CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION¶

STATE OF FLORIDA COUNTY OF¶

The undersigned, as custodian of records for Ortifies that the attached documents consisting of pages represents a true of items within my possession, custody or control which are described in the aft a Duces Tecum Without Deposition served on me in the above styled action and each page is numbered by me for identification. Production is complete and has been numbered by the custodian of records.¶

It is further certified that originals of ,the items produced are maintained under the direction, custody and control of the¶

The foregoing Certificati sePias acknowledged before me, an officer duly authorized in the State and County aforesaid to take acknowledgments, this day of, 20 , who:¶

[ ] is personally known to me; or ] ' has produced as identification; and who: (I did or ( 1 did not, take an oath,¶

and who executed the foregoing certification, and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited.¶

Notary Public, State of Florida at Large My Commission Expires:
¶

adv. Epstein Case No. 502009CA040800)OOOMBAG Subpoena to Non-Party Page5¶

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 staffefile@pathtojustice.com Jaffe, Weissing, Lehrman, FL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (954) 524-2822¶

Fred Haddad, Esquire Dee@FredHaddadLay(,com, haddadfm@aol.corn Fred Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: (954)467-6767 Fax: (954)467-3599 Attorneys for Jeffrey Epstein¶

Marc S. Nurik, Esquire marc@nurildaw.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 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¶

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, J. individually, and L.M., individually,¶

Defendant(s).¶

SUBPOENA WITHOUTiDzps1TION¶

THE STATE OF FLORIDA¶

TO: E. Knight, Esquire¶

cos¶

YOU ARE COMMA 14t to at Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Bou ard, West Palm Beach, Florida, 33409 on October 10, 2013 at 9:00 am. and to hgve with you at that time and place the following:¶

Duces Tecu A+ O All documents* reflecting any and all communications between you (or anyone acting on your behalf) and Jeffrey Epstein (or anyone acting on his behalf) which communication related directly or indirectly to the basis for and/or the viability of any claim by Epstein against¶

adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Paget¶

scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the icopies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DENS," N. NO TESTIMONY WILL BE TAKEN.¶

*The term "documents" includes but is n AIStSed, o all non-identical copies of letters, notes, memoranda, e-mails, faxes, records ' , and entries, regardless of whether they were made manually, mechanically cally, magnetically, digitally, or by any other means, and regardless of whe on papers, tape, film, electronic devices, electronic media, as well as application metadata and system metadata, or any other media or thing.¶

If you tto:¶

ppear as specified; or
1. Furnish the records instead of appearing as provided above; or
1. Object to this subpoena,

adv. Epstein Case No. 502009CA040800300C.XMBAG Subpoena to Non-Party Page3¶

DATED this day of September, 2013.¶

Jack S¶

Flo o.: 169440¶

E-mail: jsx@searcylaw.com ¶

ondary E-mail(s): mep@searcylaw.com ¶

y Denney Scarola Barnhart & Shipley, P.A.¶

139 Palm Beach Lakes Boulevard¶

West Palm Beach, Florida 33409¶

Phone: (561) 686-6300¶

Fax: (561) 383-9451¶

Attorneys for J.¶

C0 4v¶

adv. Epstein Case No. 502009CA040800)COCXMBAG Subpoena to Non-Party Paget¶

CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION¶

STATE OF FLORIDA COUNTY OF¶

The undersigned, as custodian of records for certifies that the attached documents consisting of pages represents a true co of 1 items within my possession, custody or control which are described in the a Duces Tecum Without Deposition served on me in the above styled action age is numbered by me for identification. Production is complete and has been y the custodian of records.¶

It is further certified that originals p4je i ms produced are maintained under the direction, custody and control of the undeiade¶

<<')¶

The foregoing Certificatiots acknowledged before me, an officer duly authorized in the State and County aforesaidAito take acknowledgments, this day of 20 , who:¶

[ ] is personally known to me; or [ ] has produced as identification; and who: [ did or' [ -]-- - did not, take an oath,¶

and who executed the foregoing certification, and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited.¶

Notary Public, State of Florida at Large My Commission Expires:
¶

adv. Epstein Case No. 502009CA040800)OOOCMBAG Subpoena to Non-Party Page5¶

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. Esquire staff.efile®pathtojustice.com IIII, 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.cor%r haddadfm@aol.com Fred Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: (954)467-6767 Fax: (954)-467-3599 Attorneys for Jeffrey Epstein¶

Marc S. Nurik, Esquire marc@nurildaw.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 Tonja Haddad Coleman, Esquire tonj a@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¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

CASE NO.: 502009CA040800)OOONBAG¶

JEFFREY EPSTEIN,¶

Plaintiff(s),¶

vs.¶

SCOTT ROTHSTEIN individually, J. individually, and L.M.,¶

Defendant(s).¶

-(1 /9¶

SUBPOENA WITHOUT DEPOSITION¶

THE STATE OF FLORIDA¶

TO: Roy Black, Esquire¶

YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 10, 2013 at 9:00 a.m. and to have witlityou at that time and place the following:¶

( \¶

Duces Tecum OAll documents* reflecting any and all communications between you (or anyone acting on your behalf) and Jeffrey Epstein (or anyone acting on his behalf) which communication related directly or indirectly to the basis for and/or the viability of any claim by Epstein against M.¶

These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the, copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the produ to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEP QSIT1tON. NO TESTIMONY WILL BE TAKEN.¶

*The term "documents" includes but is no /St ill ) non-identical copies of letters, notes, memoranda, e-mails, faxes, records, , and entries, regardless of whether they were made manually, mechanically ly, magnetically, digitally, or by any other means, and regardless of whethgtey, on papers, tape, film, electronic devices, electronic media, as well as application metadaafa and system metadata, or any other media or thing.¶

( If you f¶

ar as specified; or
1. Furnish the records instead of appearing as provided above; or
1. Object to this subpoena,

to this subpoena as directed. You may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond¶

DATED this icor— day of September, 2013.¶

adv. Epstein Case No. 502009CAG40800XXXXMBAG Subpoena to Non-Party Page)¶

O C¶

C 7Ze -¶

Jack¶

Flo o.: 169440¶

ary E-mail: jsx@searcylaw.com ¶

econdary E-mail(s): mep@searcylaw.com ¶

y Denney Scarola Barnhart & Shipley, P.A.¶

39 Palm Beach Lakes Boulevard¶

est Palm Beach, Florida 33409¶

Phone: (561) 686-6300¶

Fax: (561) 31611¶

Attorneys for J.¶

adv. Epstein Case No. 502009CA040800)OOOCMEAG Subpoena to Non-Party Pago4¶

CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION¶

STATE OF FLORIDA COUNTY OF¶

The undersigned, as custodian of records for es that the attached documents consisting of pages represents a true co y of items within my possession, custody or control which are described in the b- Duces Tecum Without Deposition served on me in the above styled action ge is numbered by me for identification. Production is complete and has been y the custodian of records.¶

It is further certified that originals ihe s produced are maintained under the direction, custody and control of the and ejit ed ie¶

The foregoing Certi fleets acknowledged hefts' c mc, an officer duly authorized in the State and County afor 'd to take acknowledgments, this day of 20_, who:¶

11 f 1 joduced as identification; and who: [ not, take an oath, ally known to me; or¶

and who executed the foregoing certification, and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited.¶

Notary Public, State of Florida at Large My Commission Expires:
¶

adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party PaSe5¶

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.contr haddadfin®aol.co Fred Haddad, P. One Financial to 2612 Fort Lauderdale, FL 33394 Phone: (954)467-6767 Fax: (954)-46.7-3599 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¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant,¶

vs.¶

SCOTT ROTHSTEIN, individually, J. , individually,¶

Defendant/Counter-Plaintiff.¶

Case No. 50 2009 CA 040800XXXXMBAG¶

r04¶

PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S NOTICE OF OBJECTION PURSUANT TO RULE 1.351 OF THE FLORIDA RULES OF CIVIL PROCEDURE¶

Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.351 of the Florida Rules of Civil Procedure, hereby files this Objection to Defendant/Counter-Plaintiff Bradley "Subpoena Without Deposition" which Epstein ass crhes c l intends to serve upon the following non-party individuals on or about Se tembe, 2013: Darren Indyke, Esq., Roy Black. Esq., Knight, Esq., Robe L. Ackerman, Jr., Esq., Alan Dershowitz, Esq., and Jack Goldberger, Esq.¶

Said objection is self-executing. and there is no need for Epstein to specify his objections at this time. See v. Stardust Cruisers, Inc., 690 So .2d 743 (Fla. 5th DCA 1997); v. Stardust Cruisers, Inc., 690 So. 2d 743, 744 (Fla. 5th DCA 1997). "Mjhen any objection is¶

failed to file a proper Notice of Production from Non-Party as required by Rule 1.351 of the Florida Rules of Civil Procedure. See also Fonn 1.921 of the Florida Rules of Civil Procedure.¶

filed, Rule 1.351 ceases to be available." ABC Liquors, Inc. v. Berkey. 589 So. 2d 457, 458 (Fla. 5th DCA 1991); see also Rule 1.351(c) ("If the person upon whom the subpoena is served objects at any time before the production of the documents or things, the documents or things shall not be produced under this rule, and relief may be obtained pursuant to (the rule governing depositions]."). , Coiling & Gilbert, P.A. v. Pope, 756 So. 2d 201, 201 (Fla. 2d DCA 2000).¶

WE HEREBY CERTIFY that a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this September9, 2013.¶

is/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. 'Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 71h Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimile) Attorneys for Epstein
¶

SERVICE LIST¶

CASE NO. 502009CA040800XXXXMBAG¶

Jack Scarola, Esq. jsx@searcylaw.com; mep@searcylaw.com Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409¶

Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Jack Goldberger, Esq. jgoldberger@agwpa.com; smahoney@agwpa.com West 1400 Palm Beach, FL 33401¶

C¶

O S¶

Marc Nurik, Esq. 1 East Broward Blvd. "S)C Suite 700 Fort Lauderdale, FL 33301¶

J. Esq. (S" .tbra thtojustice.com Jaffe Weissing 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301¶

Fred Haddad, Esq. Dee@FredHaddadL4i.com 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301¶

Tonja Haddad Coleman, Esquire Tonja@tonjahaddad.com; efiling@tonjahaddad.com Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale. FL 33301 Attorneys for Jeffrey Epstein¶

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PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO QUASH SUBPOENAS DUCES TECUM AND FOR SANCTIONS¶

RODUCTION¶

MEMORANDUM OF LAW ) ..)1¶

CONCLUSION¶

SERVICE LIST¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

Defendant(s). cis SUBPOENA WITHOUT DEPOSITION¶

CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION¶

COUNSEL LIST¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

SUBPOENA WITHOUT SS Ito < C4 ON¶

CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION¶

COUNSEL LIST¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

SUBPOENA WITHOUT DEPOSITION¶

CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION¶

COUNSEL LIST¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

SUBPOENA WITHOUT liS t ki ON¶

CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION¶

COUNSEL LIST¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

SUBP I ENA WITH¶

CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION¶

COUNSEL LIST¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

SUBPOENA WITHOUTiDzps1TION¶

CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION¶

COUNSEL LIST¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

SUBPOENA WITHOUT DEPOSITION¶

CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION¶

COUNSEL LIST¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA¶

PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S NOTICE OF OBJECTION PURSUANT TO RULE 1.351 OF THE FLORIDA RULES OF CIVIL PROCEDURE¶

SERVICE LIST¶