IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 502009CA040800XXXXMBAG
JEFFREY EPSTEIN,
PlaintifUCounter-Defendant, v .
SCOTT ROTHSTEIN individually, and individually,
Defendants/Counter-Plaintiff. GO
#### PLAINTIFF/COUNTER-DEFENDANT'S EMENTAL MOTION COMPEL DI 1
PlaintifdCounter-Defendant, Jeffrey Epstein ' pursuant to Florida Rule of Civil Procedure 1.380, moves for an order compel' dant/Counter-Plaintiff, J. a"), to provide complete and res A a swers to interrogatories dated July 12, 2017, September 5, 2017, and October 13 1 n to produce all documents responsive to requests for production dated September 5, October 13, 2017, and in support states:
#### INTRODUCTION
is a vic .m. rewards that tit it brings. Although represented alleged sexual abuse victims, and brough gg at nst Epstein on behalf of them, himself, is clearly not a victim despite what he n claims in this lawsuit. To the contrary, fame, fortune and success grew substantially as a direct and proximate result of his multi-faceted litigation with Epstein. is a lawyer who enjoys the spotlight and all of the financial
This motion supplements Epstein's prior motions to coin el from including Epstein's Motion to Compel Discovery Responses from filed on September 25, 2017.
To be clear, Epstein takes no issue with legitimate advocacy on behalf of his clients. However, at the time Epstein filed his abuse of process action against information existed that would lead a reasonably cautious person to have probable cause to allege a connection between and the sinister Ponzi scheme of his law partner, Scott Rothstein. There is no dispute that the Ponzi scheme's continued success was due in part to lawsuits against Epstein and co-defendant Scott Rothstein's law firm, Rothstein dler. As is now well-known, that law firm created and perpetrated a Ponzi scheme that •purported legal settlements of purported legal claims and the sale of interests to inves rs, ultimately resulted in losses of over \$1 billion. As the Ponzi scheme was coming Milstein seized onto the Epstein files to create scintillating civil claims that were n3t/jt.) i;)t sold. Investors were provided "estimates" of the value of purported claims and, up Sip 'n ton and belief, were provided alleged 8 c x details of the cases and evidence that would b s t, tort multi-million-dollar settlements from Epstein. Investors accepted the alleg ts settlements as conveyed by these Florida Bar i scheme stayed alive. licensed attorneys, they invested,
, while the Ponzi scheme was in MI swing and in dire need appearing to take steps in the Epstein litigations that were beyond The record is clear that of additional investor fun the limits of typi an investor. y for any reasonable litigation attorney, but perhaps very motivating to ' actions appeared to a reasonably cautious person to be an abuse of the process of this whelp fmancially support the continuation of the Rothstein Rosenfeldt Adler law firm, which was, in reality, mostly a Ponzi scheme. For example, filed a federal lawsuit against Epstein based on alleged sexual abuse --- but never served the lawsuit on Epstein. The lawsuit was unnecessary and duplicative of an already existing lawsuit pending in state court. Yet the filing just sat there, in the public records, available for investors to review and use to attempt to calculate present values for anticipated settlements based on numbers and alleged information provided by the Rothstein Rosenfeldt Adler law firm. In other litigations, irrelevant and invasive discovery was pursued -- the type of discovery that makes no sense to an experienced litigator but may be enticing to an investor. sought to turn inside out and upside down every personal and private detail of Epstein's life. In addition, at a desperate point of Rothstein's Ponzi scheme, asked the federal court to require Epstein to post a \$15 million bond to secure any potential ' nt claiming that Epstein was fraudulently transferring his assets. The federal court den' in#45rjquest, and noted that the motion was "entirely devoid of evidence of [Epstein's] ce i udulent transfers." abusive tactics were calculated to pressure and h• 'atea as they placed in some of his most valuable social relationships • ntion of improperly extracting a better result in the cases was pursing c ent or through the use of improper, irrelevant and highly prejudicial evidence) and e utilized by the firm as further enticements to their prospective investors in fu the ofr Ponzi scheme. These actions appeared to have no reasonable relationship c !mss to the were not undertaken "in the p a reasonably cautious per have probable cause to perceive such actions as the connected fuel brought on behalf of alleged victims and tice." All of these actions combined would certainly lead feeding the Ponz erne fife at the Rothstein Rosenfeldt Adler law firm.
As w I be monstrated at trial, Epstein had a reasonable belief of the connection between rn\\othstein iel based on I) public information from the government and investors caught in the Ponzi scheme; 2) allegations and news reports that Rothstein used cases against Epstein to dupe third parties into investing in non-existent settlements; 3) abusive use of discovery and motions practice; and 4) ME' commencement of a case in federal court when a duplicative case was already pending in state court.
In response, has counterclaimed for malicious prosecution which he has also used to further grow his public profile and generate business. In so doing, seeks several types of purported damages from Epstein: (a) injury to his reputation; (b) mental anguish, embarrassment, and anxiety; (c) fear of physical injury to himself and members of his family; (d) the loss of value of time required to be diverted from his professional responsibilities; and (e) the cost of defending against Epstein's claims. See Fourth Amended Counterclaim.
While Epstein denies that has stated a claim, and denies has suffered any damages whatsoever, he is nonetheless entitled to discovery o wants to litigate, which include each item of alleged damages, MA;, • 1 esses, and late disclosure of an expert report. As described below, Ed ! , es to provide Epstein with the relevant information he needs and is entitled too its1 ri e requested discovery, which clearly relates to prevented from offering evidence at tri prejudiced in this counterclaim by needs to provide the nt issues in this case, or he needs to be issues. Epstein has been, and continues to be, efusal to comply with his discovery obligations.
### INTERROGATORIES DARED JULY 12. 2017 — TRIAL WITNESSES AND EXHIBITS
- 1. On July 1 , Epstein served interrogatories to about v sses i preparation for trial. Exhibit A. insuffi
- 2. ugust 11, 2017, uses. Exhibit B.
- 3. In interrogatory number 1, Epstein asked: seeking information served his answers, which contain incomplete and
As to every individual identified on your List of Trial Witnesses, and each category/group of witnesses listed thereon, please provide with particularity the following:
The proper name, address, telephone number, electronic mail address, or other means of contact for each witness.
4. Preventing Epstein from contacting trial witnesses, failed to provide a single telephone number or e-mail address for any of his 157 witnesses. Instead, provided office addresses, office addresses for attorneys, and, for some witnesses, no addresses at all. It would be impossible for Epstein to attempt to contact 157 trial witnesses by engaging in a letter writing campaign. It is also highly unlikely that the provided mailing addresses are means of contact with these witnesses. The information provided is insufficient, de E tein of his right to contact trial witnesses in this case, and has prevented Epstein f rly preparing for trial. Epstein requests that be compelled to fully respond iding means of contact for every individual identified on his list of trial witnesses. If rmation is not provided by the Court's order, Epstein requests they be stricken from t\\
1. In interrogatory number 2, Epstei
As to every individual ident category/group of witn the following: our List of Trial Witnesses, and each ereon, please provide with particularity
Each contested including identi for Malicious Pro e expected to be addressed by the witness, particularity as to which element(s) of your claim ion this witness's testimony is applicable.
6. In onset does not identify the factual issues expected to be addressed by each witness. simply provides boilerplate responses, and states that many of the witnesses s the probable cause or malice elements of the malicious prosecution claim, that their inn were true, and that discovery would have provided relevant information. The response is insufficient, and provides Epstein with no notice of the actual factual issues to be addressed at trial by each of these witnesses.
1. In interrogatory number 3, Epstein asked:
As to every individual identified on your List of Trial Witnesses, and each category/group of witnesses listed thereon, please provide with particularity the following:
A detailed description of the testimony expected to be presented at trial by the witness as to each contested factual issue and element of your claim against Epstein.
8. Instead of answering with a detailed description of the testimony, e pected to be presented at trial by each witness, again provides boilerplate respons states that many of the witnesses will address the probable cause or malice ele the malicious prosecution claim, that their claims were true, and that discovery provided relevant information. This response is insufficient, and provides E ctb ' ) w no notice of the actual testimony expected to be presented at trial by each of th 'tn ) s. q
e 9. In interrogatory number 4, Epstein ask@i
10. pon1T, nlaiown at this time which exhibits will be introduced through which witness," is b r c h o re able and insufficient. has several hundred exhibits listed on his exhibit lis :\$11o 150 witnesses. The case is on the eve of trial. It is beyond belief that which trial exhibits he currently "expects" may be introduced into evidence by each witn1 s. While things may certainly change, and it is therefore unknown what exhibits ultimately will be introduced through each witness, that is not the question asked of Epstein is entitled to know, as of this moment in time, view as to which exhibits he expects to introduce into evidence by what witnesses.
As to every individual identifi List of Trial Witnesses, and each category/group of witnesses th n, please provide with particularity the following:
A description of the Fribit List number of each exhibit expected to be introduced into the witness.
11. In interrogatory number 5, Epstein asked:
As to every individual identified on your List of Trial Witnesses, and each category/group of witnesses listed thereon, please provide with particularity the following:
A description of the Trial Exhibit List number of each exhibit introduced through other means about which the witness is expected to testify, together with a description of the witness' expected testimony regarding each exhibit.
12. response, "Unknown at this time which exhibits will be introduced through which witness," is, again, both remarkable and nonresponsive. exhibits listed on his exhibit list and over 150 witnesses. On the eve of t which trial exhibits he currently "expects" may be introduced at trial witnesses. It is also unrealistic that has no idea what any of the hundreds of listed exhibits. While things unknown what testimony ultimately will be introduc is Epstein is entitled sS suw,y of this moment in time, position, a t what he expects a witness to testify and what exhibit. question asked of as to exhibits introduced through other the expected testimony will be re, 1 hundred ds must know ed about by certain imony may be regarding ly change, and it is therefore each witness at trial, that is not the
01. In sum, Edw nses to the interrogatories dated July 12, 2017, contain incomplete and insufficie pones, and deprive Epstein of the right to know the witnesses and evidence to be us responsive m at trial. Epstein requests this Court to compel to provide appropriate responses to the questions posed.
01. On September 5, 2017, Epstein served interrogatories on M, seeking information about alleged damages. Exhibit C.
### TERROGATORIES DATED SEPTEMBER 5. 2017- DAMAGES
15. On October 5, 2017, served his answers, which contain incomplete and insufficient responses. Exhibit D.
regarding any m whether it re any o 19. Under Flo le of Civil Procedure 1.280(b)(1), "[p]arties may obtain discovery nvileged, that is relevant to the subject matter of the pending action, the claim or defense of the party seeking discovery or the claim or defense of
16. While all known facts paint the picture that profited immensely from litigation with Epstein, claims to have been damaged by this litigation. As noted above, is claiming damages of: (a) injury to his reputation; (b) mental anguish, embarrassment, and anxiety; (c) fear of physical injury to himself and members of his family; (d) the loss of value of time required to be diverted from his professional responsibilities; and (0) the cost of defending against Epstein's claims. See Fourth Amended Counterclaim.
01. To discover the facts on these issues, Epstein propounded jrrbr ries regarding damages claims, including questions about em story, earnings and net worth, financial compensation agreements relating to his repj rta in Epstein-related cases, and the specific basis for MI damages claim.
01. responded with almost a S block, objecting and refusing to answer 37 of the 39 interrogatories. x ple, refuses to reveal the ways he profited from litigation with Epstein, the moneypetprade m such litigation, and the money he will likely continue to make in the future litigation. ortment of deals based on his "trademark" Epstein
01. The information sought is relevant and necessary because is seeking damages for, among other things, injury to reputation and loss of value of time diverted from professional responsibilities. Thus, claims he has lost money as a practicing attorney because he was handling one additional case -- this case — adverse to Epstein. In making such a
claim, has put his employment history, earnings and net worth at issue, as these issues are relevant to determining whether he has, in fact, suffered a "loss" based on his involvement in this case.
21. has taken an unreasonable, obstructionist approach to discovery to prevent Epstein from preparing to defend the damages claims at trial. If wants to withdraw his damage claims, Epstein will evaluate and consider a narrowing of the discovery. presently alleged, 'Mr damages claims require the provision of the informatio as requested.
01. refuses to say where he has worked, what pos d, and what salary he has been paid. See, e.g., interrogatory numbers 1, 2, 3, 6.
01. While claims he has suffered et 16ss, he refuses to provide any information about any purported loss during the ti ' dRon. See, e.g., interrogatory numbers 7, 8, 9, 10, 11, 12, 13, 14.
01. While claims t ve S saS'I tered injury to reputation, he refuses to provide information regarding legal work number 20. s obtained and profited from. See, e.g., interrogatory
Ci.) 25. o provide information regarding how he has profited directly from litigation involvi stem. See, e.g., interrogatory numbers 25, 26, 28, 29.
26. terrogatory number 32, Epstein directly asked to describe in detail, quanti plain the alleged losses in this case:
> Please describe in detail, quantify and explain the financial loss, including the amount that you contend to have suffered as described in your Fourth Amended Counterclaim, to wit:
- a. injury to your reputation;
- b. mental anguish, embarrassment and anxiety;
- c. fear of physical injury to you and members of your family;
d. the loss of value of your time required to be diverted from your professional responsibilities;
e. the cost of defending against Epstein's claims.
27. On this basic question, which seeks to understand what is claiming in this case, dodges the question and provides no substantive response:
> RESPONSE: Each of the listed elements of damage is presently unliqu'dated and will be established by the verdict of the jury empaneled to hear case and entrusted with theassibility to render a verdict that full irly compensates for every element of damage by im in the past and continues to be sustained by him in the future will be instructed, there is no exact measure for such damag erdict is required to take all evidence presented to them under n and to be fair, just and reasonable under the circumstances as th fin4 them to exist.
28. The response is inadequate and fails to info Thy in of the basis for the losses claimed. Epstein asked to describe in detail c t purported losses, to quantify each of the losses he contends to have suffered, and ai them. provide the specific, detailed information thtt uested should be required to
01. Epstein also asked Ed t his use of Epstein's name to promote his practice. In interrogatory number 34, Ep
> Please describe tail and identify with specificity every social media out site, blog, printed materials, seminar materials, or any ?,ttier p t or published media on which you, your law firm, or any soma on with which you are affiliated has ever advertised, ( efere s, or otherwise places the name of Jeffrey Epstein, and inchlde a detailed description and the date(s) of each and every such cfcience, advertisement, placement, publication, dissemination, or romotion, identify the persons or groups of persons to whom the same was made, and state the locations where made, and state whether or not the materials used in connection with such reference, advertisement, placement, publication, dissemination, or promotion are in your possession or control, or are still available on line or in print, and identify the persons or website from whom such materials may be obtained.
30. again, dodges the question:
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. . . .
31. Obviously, if is publicizing his involvement in litigation adverse to Epstein, has not suffered the damages he claims relating to such litigation.
01. Moreover, while claimed in his discovery response that such publications were irrelevant, now plans to rely on similar or the very same evidence t lish damage to his reputation, and has made a late disclosure of an expert's report whic n n such evidence. Epstein is entitled to the information requested, and needs the inform e his own expert to testify about the number of people who may have read articles d' sir pstein's allegations tying to the Ponzi scheme.
01. In interrogatory number 35, Epste dwards about evidence supporting purported damage to reputation:
> Please describe with part and all evidence, circumstances and events upon whic asserting that your reputation was damaged as alleg Counterclaim, including, without limitation, speci ribing how that damage is attributable to Epstein's lawsu agar you.
34. er was non-responsive:
NSEY The allegations of Epstein's maliciously filed t are defamatory per se.
35 in did not ask for ME opinion as to the potential defamatory nature of the Compla Epstein asked to describe, with particularity, all evidence upon which he relies to assert that his reputation was damaged. should be compelled to provide such information. Alternatively, the jury should be instructed that it cannot consider any evidence in support of purported damage to reputation other than the Complaint in this case.
36. In interrogatory number 36, Epstein asked about the purported loss of value of time required to be diverted from professional responsibilities:
> Please explain in detail the amount of time required to be diverted from your professional responsibilities including, but not limited to, the time lost, each date on which the time was lost, the case/matter on which you would have otherwise spent the time, your billable hourly rate, if any, you allege to have lost, and for each case/matter identified, please provide the amount of come derived by you, your firm, or any entity acting on your behalf in the atter. Please detail all other evidence, methods and calculations on which end to rely to quantify the damages you claim are attributable to div ed from your professional responsibilities as alleged in your C im.
37. response is woefully deficient:
RESPONSE: Time diverted from Bradl responsibilities is reflected in previously p updated prior to the expiration of discov objects to the interrogatory.... ' professional e records and will be ter-Plaintiff, however,
38. refers Epstein to time, but provides no information as to the case/matter on which he would have otherwi nt e time, his billable hourly rate allegedly lost, and the amount of income derived on tter. Nor does provide evidence, methods and calculations pursuant to wh' c: e dw tifies the purported damages. The information requested is relevant and necessary to defe ards' claim that he was damaged by spending time on this matter. shquld co polled to provide such information. Alternatively, the jury should be instructed it'rnot consider any evidence in support of purported loss of value of time required ed from professional responsibilities.
01. In sum, responses to the interrogatories dated September 5, 2017, are incomplete and insufficient. Epstein has been, and continues to be, prejudiced by IM refusal to provide relevant information pursuant to the discovery process. The Court should compel to provide responsive, full, and appropriate responses to the questions posed. Alternatively,
the Court should prohibit from presenting evidence to the jury that was not disclosed in response to corresponding discovery requests.
### REOUEST FOR PRODUCTION DATED SEPTEMBER 5. 2017 - DAMAGES
40. On September 5, 2017, Epstein served a request for production on seeking documents about damages claims. Exhibit E.
01. On October 5, 2017, and made boilerplate objections. Exhibit F. served his response, which object 10 requests
01. With respect to Request number 1, Epstein sought:
A copy of all documents that relate to, or refer information requested in, or that you referred responses to, Plaintiff/Counter-Defendant Defendant/Counter-Plaintiff J. contemporaneously herewith. or Jude, any and all way in providing your tein's Interrogatories to lating to Damages, served
O IS
43. objected to Request nprn I the basis of attorney work product.
01. objection lacks it pstein is entitled to all documents that relate to, reference, or support the basis for )positions on the issues presented by the interrogatories. See, e.g., Grinnell Corp. v. Pal 21 Ocean Blvd., Ltd., 924 So. 2d 887 (Fla. 4th DCA 2006). The work product doctrine do protect the documents that have been requested, and should be ordered to pro them immediately.
01. ests numbers 2-10 directly relate to the issue of damages claimed by
- . A copy of all documents that reflect, any and all promises, instruments, contracts, agreements, understandings, and arrangements, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format), and all amendments, modifications and supplements thereto, memorializing, any business arrangements between you and any and all law firms through which you rendered legal services at any time during the period in question, including, without limitation, cost sharing, fee splitting, fee percentage, profit sharing and/or profit participation terms and conditions including, but not limited to, your provision of legal services during your affiliation with Rothstein Rosenfeldt and Adler.
3. A copy of all documents reflecting, any and all instruments, agreements, contracts, understandings, and arrangements, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format), and all amendments, modifications and supplements thereto, memorializing, any and all trust arrangements, guardian arrangements, custodial arrangements or similar arrangements established by and/or for the benefit of each of LM, EW, and Jane Doe regarding the receipt, administration and/or payment or distribution of the proceeds of settlement of claims by LM, EW, or Jane Doe against Jeffrey Epstein.
1. A copy of all documents reflecting, any and all promises, contracts, agreements, understandings, and arrangements, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format), and all amendments, modifications and supplements thereto, memorializing, any and all arrangements that you and/or your law firm and/or any other lawyer and/or law firm have or at any time during the period in question had with LM, EW, or Jane Doe, which in any way relate to allegations by LM, EW, or Jane Doe against Jeffrey Epstein, including without limitation engagement letters, retainer letters, fee sharing arrangements, common interest or joint defense agreements, royalty agreements, publishing agreements, literary rights agreements, any other agreements relating to media rights, film rights, television rights, publishing rights, book rights, photograph rights, story rights, agency, or similar matters relating to allegations concerning Jeffrey Epstein.
1. A copy of all documents reflecting, any and all promises, contracts, agreements, understandings, and arrangements, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format), and all amendments, modifications and supplements thereto, memorializing, any and all arrangements that you, any law firm through which you have provided legal services, [REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman PL and/or any other lawyer and/or law firm have or at any time during the period in question had with any and all attorneys, investigators, other professionals, contractors and consultants and witnesses with respect to this case or any other case involving the claims of each of LM, EW, and Jane Doe against Jeffrey Epstein, including without limitation engagement letters, retainer letters, fee sharing arrangements, common interest or joint defense agreements, royalty agreements, publishing agreements, literary rights agreements, any other agreements relating to media rights, film rights, television rights, publishing rights, book rights, photograph rights, story rights, agency, or similar matters relating to allegations concerning Jeffrey Epstein.
1. A copy of all documents reflecting, and all promises, contracts, agreements, understandings, and arrangements, whether written, oral or in electronic
format (including, without limitation, in emails, texts or other digital or electronic format), and all amendments, modifications and supplements thereto, memorializing, any and all arrangements that Paul Cassell, Jack Scarola, Searcy Denney Scarola Barnhart & Shipley PA, or Boies Schiller Flexner LLP have or at any time during the period in question had with any and all attorneys (including, without limitation, you, any law firm through which you then rendered legal services, and [REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman PL), investigators, other professionals, contractors and consultants and witnesses with respect to this case and any other case involving the claims of each of LM, EW, and Jane Doe against Jeffrey Epstein, including without limitation engagement letters, retainer letters, fee sharing arrangements, common interest or joint defense agreements, royalty agreements, publishing agreements, literary rights agreements, any other agreements relating to media rights, film rights, television rights, publishing rights, book rights, photograph rights, story rights, agency, or similar matters relating to allegations concerning Jeffrey Epstein.
7. A copy of all documents, including, without limitation, checks, wire transfer instructions, wire transfer confirmations, bank statements, email confirmations, Notices of Distribution and other documents, reflecting any and all payments or distributions made by you, any law firm through which you provided legal services and/or Farmer, Jaffe, Weissing, [REDACTED], Fistos & Lehrman PL regarding the proceeds of settlement paid by Jeffrey Epstein in connection with the claims of LM, EW, and Jane Doe against Jeffrey Epstein, including, without limitation, payments or distributions made to or for the benefit of LM, EW or Jane Doe (including, without limitation, to any trusts or similar arrangements or accounts of which any of LM, EW, or Jane Doe were then beneficiaries), payments made to Paul Cassell, payments made to any other law firm or individual lawyer, payments made to investigators, consultants, advisors, or other professionals, payments made to other contractors and payments made to witnesses.
1. A copy of all documents, including, without limitation, checks, wire transfer instructions, wire transfer confirmations, bank statements, email confirmations, Notices of Distribution and other documents, reflecting in respect of the proceeds of settlement paid by Jeffrey Epstein in connection with the claims of LM, EW, and Jane Doe against him any and all amounts retained by or allocated to you, any law firm through which you then provided legal services, and/or [REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman PL as reimbursement of costs and expenses or in payment for legal services rendered.
1. A copy of all documents reflecting payments by you, Rothstein, Rosenfeldt & Adler, [REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman PL and/or any other law firm through which you have provided legal services and/or any
other lawyer and/or law firm to L.M., E.W., Jane Doe, [REDACTED] [REDACTED]), any investigators, paraprofessionals, other attorneys, other contractors or persons (including, without limitation, witnesses, publicity agents, public relations firms, book publishers, authors, journalists, bloggers, reporters, literary agents, syndicators, newspaper publishers, film or television producers, news agencies, television networks, other media outlets or entities engaged in similar business), which payments in any way relate to any federal or Florida state cases against Jeffrey Epstein or any other claims against Jeffrey Epstein in which you or your clients were involved.
10. A copy of all documents reflecting payments made to you, Rothstein, Rosenfeldt & Adler, [REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman PL and/or any other law firm through which you have provided legal services and/or any other lawyer and/or law firm, or made to or for the benefit of L.M. E.W., Jane Doe, [REDACTED] [REDACTED]), by any investigators, paraprofessionals, other attorneys, other contractors or other persons (including, without limitation, publicity agents, public relations firms, book publishers, authors, journalists, bloggers, reporters, literary agents, syndicators, newspaper publishers, film or television producers, news agencies, television networks, other media outlets or entities engaged in similar business), which payments in any way relate to any federal or Florida state cases against Jeffrey Epstein or any other claims or allegations against Jeffrey Epstein in which you or your clients were involved.
01. [REDACTED] offers the same boilerplate objection to Requests numbers 2-10, claiming they are overly broad, seek information that is irrelevant and immaterial, not reasonably calculated to lead to the discovery of admissible evidence, requests attorney work product and attorney-client materials, and is protected by rights to financial privacy.
01. Edwards claims to have suffered losses in the form of injury to reputation; mental anguish, embarrassment and anxiety; fear of physical injury; loss of value of time required to be diverted from professional activities; and cost of defense.
01. These requests are all reasonably likely to lead to the discovery of admissible evidence on these damages issues. [REDACTED] financial privacy objection lacks merit because [REDACTED] seeks damages relating to his alleged injury to those same finances (i.e., he was unable to devote more time to professional activities that allegedly caused him losses).
01. The Court should compel to produce all documents responsive to the request for production dated September 5, 2017.
### EXPERT WITNESS DISCOVERY DATED OCTOBER 13. 2017
50. On October 13, 2017, Epstein served expert witness discovery on which consisted of interrogatories and a request for production. Exhibits G and H, respectively.
01. In the request to produce, Epstein sought customary expert disci formation, including copies of depositions of expert taken in other acti rendered by experts applicable to any issues in this case, corresponds and any experts, documents furnished or made available to documents considered or reviewed by expert or upon which in evaluating, investigating or formulating his or her opinions.
01. In response to this discovery, rovidcd only a portion of the requested documentation and failed to provide a w nse to the specific requests.
01. Instead, stein:
Please confirm ip f the materials provided by Dropbox, and further confirm that th aterials, together with Dr. Jansen's report and the informatio osed last week regarding Dr. Jansen, satisfy the expert witn d' v ry you recently propounded. If there is anything else you be e you eed, please let me know with specificity what that is.
54. ' response to Epstein's expert discovery is inappropriate and insufficient.
irst, Epstein cannot confirm that the materials fully satisfy the request for production because only knows the universe of responsive documents.
56. Second, upon review of the documents did provide, it appears that failed to provide documentation in response to several of the requests, including:
- a. Copies of Jansen's deposition transcripts (RFP 1)
- b. Correspondence between IMIM counsel and Jansen (RFP 3)
- c. Copies of all materials made available to Jansen (RFP 4)
- d. Copies of all materials Jansen relied upon (RFP 5)
- e. Any other information reviewed by Jansen (RFP 6)
- f. All documents or tangible items pertaining to the scope of employment of Jansen and compensation for his services (RFP 7q)
- g. All documents or tangible items pertaining to the percentage income earned as an expert witness (RFP 7e)
- h. Records of payments made to Jansen by t omeys in the last ten years (RFP 8)
- i. Documents created by Jansen in connectio case (RFP 10)
- j. Copies of Jansen's publications (RFP
- k. Jansen's draft opinions (RFP 1
- 1. Jansen's fee schedule (RFc hi
- m. Copies of Jansen's r ex reports (RFP 14)
- n. Copies of any fining to Jansen (including orders on Ftye or Daubert mptfb P 15)
- o. Statement dNefisen's compensation, rate, amount paid to date, amount ate, and an estimate of the amount of time Jensen expects n the case moving forward (Interrogatory 15a-b) subject matter of Jensen's opinions in other cases (Interrogatory
urther, has failed to respond to all of the expert witness interrogatories.
58. responses to the expert witness discovery served on October 13, 2017, are incomplete and insufficient. On the eve of trial, Epstein once again is being prejudiced by refusal to provide relevant information pursuant to the discovery process. The Court should compel to provide responsive, full, and appropriate responses to the expert witness discovery. Alternatively, the Court should prohibit from presenting purported expert witness testimony at trial.
#### CONCLUSION
For the reasons stated above, this Court should grant Epstein's Supplemental Motion to Compel Discovery.
Wherefore, Epstein respectfully requests that this Court compel e complete and responsive answers to interrogatories dated July 12, 2017, September d October 13, 2017, and to produce all documents responsive to requests for produ on eptember 5, 2017, and October 13, 2017, and grant such other and further relief ash Co deems just and proper.
### ERTIFICATE OF S
I certify that the foregoing document has Service List below on November 7, 2017, throu Rule of Judicial Administration 2.516(bX1). to the attorneys listed on the s e-filing portal pursuant to Florida
+6s
& ROCKENBACH, P.A. 5 Palm Beach Lakes Boulevard, Suite 301 est Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601 [fax]
By: /s/ Scott J. Link Scott J. Link (FBN 602991) Kara Berard Rockenbach (FBN 44903) Angela M. Many (FBN 26680) Primary: Scott@linkrocklaw.com Primary: Kara@linkrocklaw.com Primary: Angela®Iinkrocklaw.com Secondary: Tina@linkrocklaw.com Secondary: Troy@linkrocklaw.com Secondary: Tanva(alinkrocklaw.com Secondary: Eservice®IinIcrocIdaw.com
Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein
#### SERVICE LIST
| Jack Scarola
Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, FL 33409
mep@searcylaw.com
jsx@searcylaw.com
scarolateam@searcylaw.com
Co-Counsel for Defendant/Counter-Plaintiff
[REDACTED] J. [REDACTED]
| Nichole J. Segal
Burlington & Rockenbach, P.A.
Courthouse Commons, Suite 350
444 West Railroad Avenue
West Palm Beach, FL 33401
njs@FLAAppellateLaw.com
kbt@FLAAppellateLaw.com
Co-Counsel for Defendant/Counter-Plaintiff
[REDACTED] J. [REDACTED]
|
| -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| [REDACTED] J. [REDACTED]
Pottinger LLC
425 N. Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301-3268
brad@epllc.com
staff.efile@pathtojustice.com
Co-Counsel for Defendant/Counter-Plaintiff
[REDACTED] J. [REDACTED]
| Marc S. Nurik
Law Offices of Marc S. Nurik
One E. Broward Boulevard, Suite 700
Ft. Lauderdale, FL 33301
marc@nuriklaw.com
Counsel for Defendant Scott Rothstein
[REDACTED]
|
| Tonja Haddad Coleman
315 S.E. Seventh Street, Suite 301
Ft. Lauderdale, FL 33301
tonja@tonjahaddad.com
efiling@tonjahaddad.com
Co-Counsel for Plaintiff/Counter-Defendant
Jeffrey Epstein
| Fred Haddad
Haddad & Navarro, PLLC
1 Financial Plaza, Suite 2612
Fort Lauderdale, FL 33394
dee@haddadandnavarrolaw.com
Co-Counsel for Plaintiff/Counter
|
# EXHIBIT A
NOT A CERTIFIED COPY
IN THE CIRCUIT COURT OF THE H1 1EENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant,
Case No. 50 2009 CA 0408003OOO(MA°
v.
I. a, et al.,
Defendants/Counter-Plaintiff.
# NOTICE OF PROPOUNDING /14RR c GATORIES
Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through hii undersigned counsel, hereby certifies that the original of this Notice was filed with the Court and a copy of the Notice, together with the original Interrogatories, was propounded to through his counsel by electronic service, to be answered under oath within the time prescribed by the Florida Rules of Civil Procedure, this July 12, 2017.
JUDGE: HAFELE
C'
/s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954A67.1223 954.337.3716 (facsimile) Tonja@TonjaHaddad.com Efiling@TonjaHaddad.com
#### SERVICE LIST
CASE NO. 502009CA040800)OCXXMBAG
Jack Scarola, Esq. jsz@searcylaw.com; mep@searcylaw.com Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409
Jack Goldberger, Esq. Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 jgoldberger@agwpa.com; smahoney@agwpa.com West Palm Beach, FL 33401
CO
Marc Nurilc, Esq. "SC 1 East Broward Blvd. ) Suite 700 Fort Lauderdale, FL 33301
J. . Esq. athtojustice.com br ?14/> A Jaffe Weissing 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fist
Fred Haddad, Esq. Dee@FredHaddadLaw.com 315 SE 7th Street, Suite 301' Fort Lauderdale, FL 33301
Tonja Haddad Coleman, Esquire Tonja@toujahaddad.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 hENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant,
Case No. 50 2009 CA 040800XXXXMBAG
v.
J. et al., JUDGE: HAFE
Defendants/Counter-Plaintiff.
#### PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S INTERROGATORIES TO BRADLEY
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.340 of the Florida Rules of Civil Procedure hereby propounds the following Interrogatories on Defendant/Counter-Plaintiff this July 12, 2017.
It is requested that the aforesaid answers be served upon Epstein within thirty (30) days of today's date.
#### INTERROGATORIES
As to every individual identified on your List of Trial Witnesses, and each category/group of witnesses listed thereon, please provide with particularity the following:
- 1. The proper name, address, telephone number, electronic mail address, or other means of contact for each witness:
ANSWER:
- 2. Each contested factual issue expected to be addressed by the witness, including identifying with particularity as to which element(s) of your claim for Malicious Prosecution this witness's testimony is applicable:
ANSWER:
iS 4)C)
- 3. A detailed description of the testimicpct ny ed to be presented at trial by the witness as to each contested factual issue and element of your claim against Epstein:
ANSWER:
- 4. A description of the Trial Exhibit List number of each exhibit expected to be introduced into evidence by the witness:
ANSWER:
- 5. A description of the Trial Exhibit List n ber of each exhibit introduced through other means about which the witness is expected to testify, together with a description of the witness' expected testimon arcling eachexhibit:
ANSWER: C.)
A S tar
+it-)
STATE OF
COUNTY OF
The foregoing instrument was acknowledged before me this day of 2017 by who is personally known to meorwho has produced as identificatio ho did/did not take an oath.
C
iS)C) (SEAL) (Notary signature)
(Notary name - print) NOTARY PUBLIC, State of Florid
+6s
# EXHIBIT B
NOT A CERTIFIED COPY
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).
NOTICE OF SERVING ANSWERS TO INTERROGATORIES\
PROPOUNDED BY COUNTER-DEFENDANT JEFFREY EPSTEIN
[REDACTED] J. [REDACTED], by and through his undersigned counsel, hereby files this Notice of Serving Answers to Interrogatories with the Court propounded by the Counter-Defendant, Jeffrey Epstein, on July 12, 2017, which have been furnished to the attorneys for the Counter-Defendant.
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 11TH day of AUGUST, 2017.
JACK SCAROLA\
Florida Bar No.: 169440\
Attorney E-Mail(s): jsx@searcylaw.com; and\
mmecann@searcylaw.com\
Primary E-Mail: scarolateam@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]
[REDACTED] ADV. EPSTEIN\
Case No.: 502009CA040800XXXXMBAG\
Notice of Serving Answers to Interrogatories
COUNSEL LIST
William Chester [REDACTED], Esquire\
wcblaw@aol.com; wcblawasst@gmail.com\
250 S Australian Avenue, Suite 1400\
West Palm Beach, FL 33401\
Phone: (561)-655-4777\
Fax: (561)-835-8691\
Attorneys for Jeffrey Epstein
Jack A. Goldberger, Esquire\
jgoldberger@agwpa.com; smahoney@agwpa.com\
Atterbury Goldberger & Weiss, P.A.\
250 Australian Avenue S, Suite 1400\
West Palm Beach, FL 33401\
Phone: (561)-659-8300\
Fax: (561)-835-8691\
Attorneys for Jeffrey Epstein
[REDACTED] J. [REDACTED], Esquire\
staff.efile@pathtojustice.com\
[REDACTED] Jaffe Weissing [REDACTED] Fistos & Lehrman, P.L.\
425 N Andrews Avenue, Suite 2\
Fort Lauderdale, FL 33301\
Phone: (954)-524-2820
Fred Haddad, Esquire\
Dee@FredHaddadLaw.com; Fred@FredHaddadLaw.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
Tonja Haddad Coleman, Esquire\
tonja@tonjahaddad.com; efiling@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
Marc S. Nurik, Esquire\
marc@nuriklaw.com\
One E Broward Blvd., Suite 700\
Fort Lauderdale, FL 33301\
Phone: (954)-745-5849\
Fax: (954)-745-3556\
Attorneys for Scott Rothstein
NOT A CERTIFIED COPY
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).\
\_\_\_\_\_/
NOTICE OF SERVING ANSWERS TO INTERROGATORIES\
PROPOUNDED BY COUNTER-DEFENDANT JEFFREY EPSTEIN
[REDACTED] J. [REDACTED], by and through his undersigned counsel, hereby files this Notice of Serving Answers to Interrogatories with the Court propounded by the Counter-Defendant, Jeffrey Epstein, on July 12, 2017, which have been furnished to the attorneys for the Counter-Defendant.
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 11th day of AUGUST, 2017.
\_\_\_\_\_\
JACK SCAROLA\
Florida Bar No.: 169440\
Attorney E-Mail(s): [jsx@searcylaw.com](mailto:jsx@searcylaw.com); and\
[mm@cann@searcylaw.com](mailto:mm@cann@searcylaw.com)\
Primary E-Mail: [scarolateam@searcylaw.com](mailto:scarolateam@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]
[REDACTED] ADV. EPSTEIN\
Case No.: 502009CA040800XXXXMBAG\
Notice of Serving Answers to Interrogatories
COUNSEL LIST
William Chester [REDACTED], Esquire\
wcblaw@aol.com; wcblawasst@gmail.com\
250 S Australian Avenue, Suite 1400\
West Palm Beach, FL 33401\
Phone: (561)-655-4777\
Fax: (561)-835-8691\
Attorneys for Jeffrey Epstein
Jack A. Goldberger, Esquire\
jgoldberger@agwpa.com; smahoney@agwpa.com\
Atterbury Goldberger & Weiss, P.A.\
250 Australian Avenue S, Suite 1400\
West Palm Beach, FL 33401\
Phone: (561)-659-8300\
Fax: (561)-835-8691\
Attorneys for Jeffrey Epstein
[REDACTED] J. [REDACTED], Esquire\
staff.efile@pathtojustice.com\
[REDACTED] Jaffe Weissing [REDACTED] Fistos & Lehrman, P.L.\
425 N Andrews Avenue, Suite 2\
Fort Lauderdale, FL 33301\
Phone: (954)-524-2820
Fred Haddad, Esquire\
Dee@FredHaddadLaw.com; Fred@FredHaddadLaw.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
Tonja Haddad Coleman, Esquire\
tonja@tonjahaddad.com; efiling@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
Marc S. Nurik, Esquire\
[marc@nuriklaw.com](mailto:marc@nuriklaw.com)\
One E Broward Blvd., Suite 700\
Fort Lauderdale, FL 33301\
Phone: (954)-745-5849\
Fax: (954)-745-3556\
Attorneys for Scott Rothstein
NOT A CERTIFIED COPY
#### INTERROGATORIES
As to every individual identified on your List of Trial Witnesses, and each category/group of witnesses listed thereon, please provide with particularity the following:
1. The proper name, address, telephone number, electronic mail address, or others o'iVcontact for each witness:
### ANSWER: CO
| | DESCRIPTION GE SES |
| ----------------------------------------------------------------------------------- | -------------------------------------------------------------------------------- |
| 2-3 (Expected to refuse to testify on | c e t of the claim for Malicious Prosecution). Consistent |
| 2 | (formerly Kell |
| damages. Will testify to the truth of the claims prosecuted by | against Epstein, the likelihood |
| that the dips, | very conducted by would have resulted in relevant information to proving aspects |
| of the vaus sexual abuse cases being prosecuted by | at the time, including on the issue of |
| 3. a4, a Marcinkova | |
| c Mica Dubno | |
| 2-3 Expected to testify about each element of malicious prosecution except bonafide | |
| cases being prosecuted by | at the time, including on the issue of punitive |
| dams es | Sub ect to assertions of privilege |
| 4. do Stan Pottinger | |
#### DESCRIPTION OF WITNESSES
49 Twin Lakes Road, Suite 100 South Salem NY 10590
2-3 Expected to testify about the malicious prosecution elements of absence of .robable cause and malice. Will testify to the truth of the claims prosecuted by against Epstein, the likelihood that the discovery conducted by would have resulted in relevant information to proving aspects of the va 'ous sexual abuse cases being prosecuted by at the time, including on the e of punitive dame es through her own knowledge and experiences with Epstei
. do Peter Guirguis, Esq. O MINTZ & GOLD LLP 600 Third Avenue, 25th Floor, New York 10016 C )
2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecined by Edwards against Epstein, the likelihood that the discovery conducted by would have,,re \\st4t,1 in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive dame :es through her own knowledge and experiences with Epstein. ls ,),
6. do Peter Guirguis, Esq. MINTZ & GOLD LLP 600 Third Avenue, 25th Floo New York, 10016
> 2-3 Expected to testi about the malicious prosecution elements of absence of probable cause and malice. Will testify to the Dal of the claims prosecuted by against Epstein, the likelihood that the discovery cot{ducted by would have resulted in relevant information to proving aspects of the various sexual\\ 6iffe cases being prosecuted by at the time, including on the issue of punitive damages,through her own knowledge and experiences with Epstein.
7 Nadia °Olt 13 I I i erside Drive, Suite 800 i . oaks, CA 91423-2449
> -3 Expected to testify about the malicious prosecution elements of absence of probable cause and alice. Will testify to the truth of the claims prosecuted by against Epstein, the likelihood that the discovery conducted by would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by at the time, including on the issue of punitive dam es throu:h her own knowledge and experiences with Epstein.
8. do Robert Josefsberg, Esq. PODHURST ORSECK, PA, 25 W FLAGLER STREET, STE 800, MIAMI, FL 33131
| DESCRIPTION OF WITNESSES | |
| ------------------------ | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
| | 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by [REDACTED] against Epstein, the likelihood that the discovery conducted by [REDACTED] would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by [REDACTED] at the time, including on the issue of punitive damages through her own knowledge and experiences with Epstein.
|
| 9. | Robert Josefsberg, Esquire
PODHURST ORSECK, PA,
25 W FLAGLER STREET, STE 800,
MIAMI, FL 33131
2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by [REDACTED] would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. Will confirm the propriety of [REDACTED] actions.
|
| 10. | Detective [REDACTED] Recarey
Palm Beach Police Department
345 South County Road
Palm Beach, FL 33480
2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by [REDACTED] against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by [REDACTED] at the time, including on the issue of punitive damages.
|
| 11. | Chief Michael Reiter
Palm Beach Police Department
345 South County Road
Palm Beach, FL 33480
2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by [REDACTED] against Epstein, the likelihood that the discovery conducted by [REDACTED] would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by [REDACTED] at the time, including on the issue of punitive damages.
|
| 12. | John Connolly
c/o [REDACTED] & Schuster
1230 6th Avenue
New York, New York 10020
2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by [REDACTED] against Epstein, the likelihood that the discovery conducted by [REDACTED] would have resulted in relevant information to proving aspects of
|
| DESCRIPTION OF WITNESSES | |
| ------------------------ | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| | the various sexual abuse cases being prosecuted by [REDACTED] at the time, including on the issue of punitive damages. |
| 13. | Charles Lichtman, Esquire
350 East Las Olas Boulevard Suite 1000
Fort Lauderdale, FL 33301 |
| | 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify as to the falsity of the claims made by Epstein against Edwards and the propriety of [REDACTED] actions. |
| 14. | William Scherer, Esquire
633 S Federal Hwy #800
Fort Lauderdale, FL 33301 |
| | 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify as to the falsity of the claims made by Epstein against [REDACTED]. |
| 15. | Antonio [REDACTED] (Tony)
Palm Coast, Florida |
| | 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by [REDACTED] against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by [REDACTED] at the time, including on the issue of punitive damages through his own knowledge and experiences with Epstein. |
| 16. | Records Custodian of Palm Beach Police Department
345 South County Road
Palm Beach, FL 33480 |
| 17. | Records Custodian of United States Attorney's Office for the Southern District of Florida |
| 18. | Records Custodian of the Federal Bureau of Investigations |
| 19. | Spencer Kuvin, Esquire
1800 S. Australian Avenue, #400
West Palm Beach, Florida 33409 |
| | 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by [REDACTED] against Epstein, the likelihood that the discovery conducted by [REDACTED] would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by [REDACTED] at the time, including on the issue of punitive damages. Will also confirm the leadership role played by [REDACTED] in the prosecution of civil claims against Epstein and the propriety of [REDACTED] actions. |
| 20. | Theodore Leopold, Esquire
2925 PGA Boulevard
Palm Beach Gardens, Florida 33410 |
•
| DESCRIPTION OF WITNESSES | |
| ------------------------ | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| | 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by [REDACTED] against Epstein, the likelihood that the discovery conducted by [REDACTED] would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by [REDACTED] at the time, including on the issue of punitive damages. Will also confirm the leadership role played by [REDACTED] in the prosecution of civil claims against Epstein and the propriety of [REDACTED] actions.
|
| 21. | Rinaldo Rizzo
c/o Robert [REDACTED]
228 East 45th Street 17th Floor
New York, NY 10017
2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by [REDACTED] against Epstein, the likelihood that the discovery conducted by [REDACTED] would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages through his own knowledge and experiences with Epstein.
|
| 22. | Adam Horowitz, Esquire
425 N ANDREWS AVE., SUITE 2
FT. LAUDERDALE, FL 33301
2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by [REDACTED] against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by [REDACTED] at the time, including on the issue of punitive damages. Will also confirm the leadership role played by [REDACTED] in the prosecution of civil claims against Epstein and the propriety of [REDACTED] actions.
|
| 23. | Isidro M. [REDACTED], Esquire
[REDACTED] Law Firm, P.A.
224 Datura Street, Suite 900
West Palm Beach, FL, 33401
2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by [REDACTED] against Epstein, the likelihood that the discovery conducted by [REDACTED] would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by [REDACTED] at the time, including on the issue of punitive damages. Will also confirm the leadership role played by [REDACTED] in the prosecution of civil claims against Epstein and the propriety of [REDACTED] actions.
|
| 24. | All of the Lawyers who Represented Victims of Jeffrey Epstein.
2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by [REDACTED] against Epstein, the likelihood that the discovery conducted by [REDACTED] would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by [REDACTED] at the time, including on the issue of
|
| DESCRIPTION OF WITNESSES | |
| ---------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| | punitive damages. Will also confirm the leadership role played by [REDACTED] in the prosecution of civil claims against Epstein and the propriety of [REDACTED] actions. |
| WITNESSES WHICH MAY BE CALLED IF NEED ARISES | |
| | 2-3. Each of the witnesses listed below as numbered 25-157 (with the exception of records custodians) has information pertaining to the malicious prosecution elements of absence of probable cause and malice. If called, each could provide information regarding the truth of the claims prosecuted by [REDACTED] against Epstein, and the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by [REDACTED] at the time, including on the issue of punitive damages. |
| 25. | [REDACTED]
1040 South Shore Drive
Miami Beach, FL 33141 |
| 26. | Landon [REDACTED]
c/o New York Times
620 Eighth Avenue
New York, NY 10018 |
| 27. | Oren Kramer
c/o Boston Provident, L.P.
717 5th Avenue #12A
New York, NY 10022 |
| 28. | [REDACTED] LaVecchio
United States Attorney's Office Southern District of Florida
Broward Financial Center
Fort Lauderdale, Florida. Will also confirm the leadership role played by [REDACTED] in the prosecution of civil claims against Epstein and the propriety of [REDACTED] actions. |
| 29. | [REDACTED]
c/o Brad Edwards, [REDACTED] Jaffe Weissing
425 North Andrews Avenue
Fort Lauderdale FL 33301 |
| 30. | Evgenia Ignatieva
1650 Broadway, #910
New York, NY 10019 |
| 31. | Anouska [REDACTED]
536 N. Edinburgh Avenue,
Los Angeles, CA 90048 |
| 32. | Angelique [REDACTED]
c/o Adam Horowitz
[REDACTED], JAFFE, WEISSING, ET AL.
425 N ANDREWS AVE., SUITE 2
FT. LAUDERDALE, FL 33301 |
| 33. | [REDACTED]
c/o Jack Scarola
SEARCY DENNEY, ET AL. |
| | 2139 PALM BEACH LAKES BLVD. West Palm Beach, FL 33409 | DESCRIPTION OF WITNESSES |
| --- | -------------------------------------------------------------------------------------------------------------- | -------------------------------------- |
| 34. | c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 | |
| 35. | Brandy Brenson c/o Spencer Kuvin | |
| | 1800 South Australian Ave #400 West Palm Beach, Florida, 33409 c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA | 4 11.14" :) |
| | 25 W FLAGLER STREET, STE 800 MIAMI FL 33131 | C5 |
| 37. | c/o Spencer Kuvin | ' |
| | West Palm Beach, Florida, 33409 | 4(I P ) 1800 South Australian Ave #400 |
| 38. | c/ Esq. JAFFE, WEISSING 425 N ANDREWS AVE., S Fr. LAUDERDALE, FL | |
| 39. | Paul Cassell, Esq. 383 S. University S | |
| | Lake Slt City Utah, 8 12 | |
| 40. | c/o Adam Horo | |
| | FARMEEIAF VEISSING, ET AL. 425 N ^REWS AVE., SUITE 2 | |
| | FT ERDALE, FL 33301 | |
| 41. | Da res | |
| | 1 Clark Street | |
| | Hilli odCA 90069 | |
| 42. | leis c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 | |
| 43. | c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 | |
| | DESCRIPTION OF WITNESSES MIAMI FL 33131 |
| --- | ------------------------------------------------------------------------------------------------------------------------ |
| ' | do Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 |
| 45. | Prince Andrew Albert Christian of York, Buckingham Palace Road London SW1A IAA Frederic Feklcai Address Current! Unknown |
| 47. | CA) do Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 |
| 48. | Lesley Groff do Mike 1114 Avenue of the Americas New York, NY 10036 |
| 49. | Dave Rogers do Bruce Reinhart 505 S. Flagler Drive, Ste 300 West Palm Beach, FL 33 |
| 50. | do Adam Horowitz |
| | JAFFE, G, ET AL. |
| | 425 N ANDRE AVE., SUITE 2 |
| | FT. LAUDERD L 33301 |
| 51. | Leigh Sk atri |
| | do Ro sefsberg, Esq. |
| | PO RSECK, PA |
| | F GLER STREET, STE 800 L 33131 |
| 52. | eager' Dorshel • Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI FL 33131 |
| 53. | do Adam Horowitz JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 |
| | DESCRIPTION OF WITNESSES |
| --- | ---------------------------------------------------------------------------------------------------- |
| 54. | do Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 |
| 55. | Tod Meister 101 Seminole Avenue Palm Beach FL 38480 O C) |
| 57. | do Robert Josefsberg, Esq. PODHURST ORSECK, PA, |
| | /c ) 25 W FLAGLER STREET, STE 800 MIAMI FL 33131 |
| 58. | do Spencer Kuvin 1800 South Australian Ave #400 West Palm Beach, Florida, 3340 |
| 59. | do Marshall Dore Louis 40 NW third Street, Suit Miami, FL 33128 |
| 60. | Jason Richards |
| | Federal Bureau Investigation |
| | 16320 NW 2nd A ., IAMI, FL 33169 |
| 61. | Shawna era |
| | do Bra e dwards, Esq. |
| | F J FE, WEISSING, ET AL. |
| | A 'REWS AVE., SUITE 2, ERDALE, FL 33301 |
| 62. | ca JAFFE, WEISSING, ET AL. |
| 63. | do Adam Horowitz FARMER, JAFFE, WEISSING, ET AL 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 |
| | DESCRIPTION OF WITNESSES |
| --- | ----------------------------------------------------------------------------------------------------- |
| 64. | do Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 |
| 65. | do Adam Horowitz, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 |
| 66. | Nezbitt Kurkendall |
| | Federal Bureau of Investigation O 'S C 16320 NW 2" AVE. MIAMI FL 33169 |
| 67. | ' do Isidro M. Law Firm, P.A. |
| | 224 Datura Street, Suite 900 'S West Palm Beach, FL, 33401 |
| 68. | Igor Zinoview Address Crrently Unknown |
| 69. | ( S" Address Current) Unknown |
| 70. | 9 East 71 Street New York, NY 10021 |
| 71. | Seth Lehrman 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 |
| 72 | Matt Weissing 425 N ANDREWS AVE., SUITE 2 |
| | Fr. LAUDERDALE, FL 33301 |
| 73. | Maria Villafana 500 S. Australian Avenue, 11400 |
| | West Palm Beach, FL 33401. Will also confirm the er ip role played by in the prosecution |
| | of civil claims against Epstein and the propriety of actions. |
| 74. | Any additional individuals identified as victims by the United states Attorney's Office and whose |
| 75. | Leslie Wexner Three Limited Parkway |
| 76 | Donald Trump c/o Alan Garten, Esq. 725 Fifth Avenue |
I
t
| DESCRIPTION OF WITNESSES | |
| ------------------------ | ------------------------------------------------------------------------------------------------------------------- |
| | New York, NY 10022. Subject to the assertions of privilege |
| 77. | Larry Visoski
1131 PINE POINT ROAD
RIVIERA BEACH, FL 33401 |
| 78. | Maritza Vasquez
1293 SW 21 st Terrace
Miami, FL 33145 |
| 79. | Maximilia [REDACTED]
C/O ATTORNEY WILLIAM UNROCH
140 WEST END, APT 30-BW
NEW YORK, NY 10023 |
| 80. | [REDACTED]
c/o Spencer Kuvin
1800 S. Australian Avenue, #400
West Palm Beach, Florida 33409 |
| 81. | [REDACTED]
2915 SHARE RD 111
TALLAHASSEE, FL 31312 |
| 82. | [REDACTED]
c/o Robert Josefsberg, Esq.
PODHURST ORSECK, PA
25 W FLAGLER STREET, STE 800
MIAMI, FL 33131 |
| 83. | David Copperfield (David Seth Kokin)
11675 GLOWING SUNSET LN
LAS VEGAS, NV 89135 |
| 84. | [REDACTED]
12247 72ND CT N
WEST PALM BEACH, FL 33412 |
| 85. | Michael Fisten
Weston, FL |
| 86. | Russell Adler
Delray Beach, FL |
| 87. | Marie Alessi
6791 FAIRWAY LAKES DR.
BOYTON BEACH, FL 33472 |
| 88. | Janusz Banasiak
358 EL BRILLO WAY
PALM BEACH FL, 33480 |
| 89. | Beata Banasiak
358 EL BRILLO WAY
PALM BEACH, FL 33480 |
| 90. 91. 92. | DESCRIPTION OF WITNESSES Juan Alessi 6791 FAIRWAY LAKES DR. BOYTON BEACH, FL 33472 Michael 53320 AVENIDA MADERO LA QUINTA CA 92253 Jerry Goldsmith 13285 SILVER FOX LN WEST PALM BEACH, FL 33418-7942 4•4' Rosalie |
| ----------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
| 93. | 53320 AVENIDA MADERO LA QUINTA CA 92253 |
| 94. | Valdson Cotrin C Y Address Currently Unknown |
| 95. | 301 E 66TH ST APT 11P NEW YORK, NY 10065 |
| 96. | Cecelia Unknown South Africa |
| 97. | Glenn 1040 5TH AVE UNIT 15A NEW YORK, NY 10028-0137 |
| 98. | Abigail Wexner Three Limited Parkway |
| | Columbus, Ohio 43206 ) |
| 99. | Officer Munyan |
| | Palm Beach Police De ent 345 South County Road Palm Beach, FL 33480 |
| 100. | Officer Minot Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 |
| 101 | Sgt. Sorge Palm Beach Police Department 345 South County Road Palm Beach FL 33480 |
| 103. | Arnold Paul Prospari 215 WESTMINSTER RD WEST PALM BEACH, FL 33405-1654 |
I
| | DESCRIPTION OF WITNESSES |
| ---- | ------------------------------------------------------------------------------------- |
| 104. | ill Pagnano FLAGLER DR STE 301 WEST PALM BEACH, FL 33401 |
| 105. | Stephan Kosslyn 28 GARFIELD ST |
| | CAMBRIDGE • 02138-1802 |
| 106. | Cecile Dejongh 23 8 ESTATE MAFOLIE I |
| | ST VI 00802 Tommy Mottola |
| 107 | AS' . 302 CARIBBEAN RD PALM BEACH FL 33480-3012 |
| 108. | Mike Sanka 449 S BEVERLY DR STE 101 BEVERLY HILLS, CA 90212 |
| 109. | IIIIIIIL105 'S C4A) ) |
| 110. | William "Bill |
| | 5645 CORAL 1 DR # 391 CORAL SPRINGS FL 33076 |
| III. | Howard Rubenstein 1345 AVENUE OF THE AM NEW YORK, NEW YORK 101 |
| 112. | Robert Meister |
| | 101 SEMINOLE AVE i PALM BEACH FL 33480,1 |
| 113. | Todd Meister 101 SEMINOLE AVE PALM BEACH, FL 33480 |
| 114. | President William J. Clinton |
| 115. | William Hammond aM.Fontana Place |
| | = Palm Beach, FL |
| 116. | Robert Roxburgh 5600 North Flagler Dr, 0250 West Palm Beach, Florida |
| 117 | Michele Pagan Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 |
| | DESCRIPTION OF WITNESSES |
| ---- | ----------------------------------------------------------------------------------------------------------------------------------- |
| 118. | Michele Dawson
Palm Beach Police Department
345 South County Road
Palm Beach, FL 33480 |
| 119. | Amy Fortimer
12309 N OLD COUNTRY RD
WELLINGTON, FL 33414 |
| 120. | [REDACTED]
345 SOUTH ST APT 6E
NEW YORK, NY 10009 |
| 121. | [REDACTED]
371 NW TRESCO WAY APT 208
JENSEN BEACH, FL 34957 |
| 122. | [REDACTED]
5159 Kingston Court,
West Palm Beach, Florida |
| 123. | [REDACTED]
9 PINTA RD
MIAMI FL 33133-2607 |
| 124. | Latasha Lowe
c/o Adam Horowitz
[REDACTED], JAFFE, WEISSING, ET AL.
425 N ANDREWS AVE., SUITE 2
FT. LAUDERDALE, FL 33301 |
| 125. | [REDACTED]
115 Sunshine Blvd
West Palm Beach, Florida |
| 126. | Zack Bryan
1150 Larch Way
Wellington, Florida |
| 127. | [REDACTED]
223 W AVENUE 37
LOS ANGELES, CA 90065-3241 |
| 128. | Larry
11148 COLLEEFIELD DR.
WELLINGTON, FL 33449 |
| 129. | Story Cowles
801 S OLIVE AVE UNIT 201S
WEST PALM BEACH, FL 33401 |
| 130. | Alan Dershowitz
26 RESERVOIR ST
CAMBRIDGE, [REDACTED] 02138
or
TUDOR CITY PL |
| DESCRIPTION OF WITNESSES | |
| ------------------------ | ---------------------------------------------------------------------------------------------------------- |
| | APT 7K
NEW YORK, NY 10017. Subject to assertions of privilege |
| 131. | Michael Dawson
Palm Beach Police Department
345 South County Road
Palm Beach, FL 33480 |
| 132. | Salaam Kahlid Monroe
119 MENORES AVE APT 3
CORAL GABLES, FL 33134 |
| 133. | Jelitza Negrette
503 CHANDLERS WARF
PORTLAND, ME 04101 |
| 134. | Sergia [REDACTED]
825 BRICKELL BAY DR., #1141
MIAMI, FL 33131 |
| 135. | Cassandra [REDACTED]
5011 EL CLARK CIRCLE
WEST PALM BEACH, FL 33415 |
| 136. | Randee Speciale
PALM BEACH VICTIM SERVICES
205 N DIXIE HIGHWAY # 5.1100
WEST PALM BEACH, FL 33401 |
| 137. | [REDACTED]
Address Currently Unknown |
| 138. | Steven Hoffenberg
Address Currently Unknown |
| 139. | Michael Stroll
Address Currently Unknown |
| 140. | Douglas Shoettle
243 Riverside, Dr.
New York, NY 10025 |
| 141. | Ghislaine Maxwell
Address Currently Unknown |
| 142. | Records Custodian
Amazon |
| 143. | Records Custodian
Yellow Cab |
| 144. | Records Custodian
Citrix Systems, Inc. |
| 145. | Records Custodian
Federal Bureau of Investigation |
| 146. | Records Custodian
Milton Girls Juvenile Facility |
| | DESCRIPTION OF WITNESSES |
| ---- | ---------------------------------------------------------------------------------------------------------------------------------- |
| | 5770 EAST MILTON ROAD
MILTON, FL |
| 147. | Records Custodian
School District of Palm Beach County
3344 FOREST [REDACTED] BLVD, SUITE C-124
West Palm Beach, FL 33406 |
| 148. | Records Custodian
St. Mary's Medical Center
901 45 th STREET
West Palm Beach, FL 33401 |
| 149. | Records Custodian
WELLINGTON REGIONAL HOSPITAL
10104 FORREST [REDACTED] BLVD
WELLINGTON, FL 33414 |
| 150. | All witnesses that Defendants have listed on their Witness List not objected to by Plaintiff, Jane Doe. |
| 151. | All rebuttal witnesses. |
| 152. | All People on Jeffrey Epstein's Inmate Visitor Log while he was in jail. |
| | WITNESS TESTIMONY EXPECTED TO BE PRESENTED BY MEANS OF DEPOSITION |
| 153. | Mark Epstein
30 VANDAM STREET
NEW YORK, NY 10013 |
| 154. | [REDACTED] (Adriana Mucinska)
St. Mary's Medical Center, Esq. |
| 155. | Louella Rabuyo
358 EL BRILLO WAY
PALM BEACH, FL 33480 |
| 156. | Alfredo Rodriguez
11349 SW 86TH LN, Miami, FL
C/O Federal Public Defender or Bureau of Prisons |
| 157. | Scott Rothstein
c/o Mark Nurik
One East Broward Boulevard, Suite 700
Fort Lauderdale, Florida 33301 |
2. Each contested factual issue expected to be addressed by the witness, including identifying with particularity as to which element(s) of your claim for MaliciousProsecution this witness's testimony is applicable:
ANSWER: See response to number 1.
3. A detailed description of the testimony expected to be presented at tr contested factual issue and element of your claim against Epstein: tness as to each
ANSWER: See response to number 1.
4. A description of the Trial Exhibit List numb., ,,"lip s,, Gexhibit Cexpected to be introduced into evidence by the witness:
ANSWER: Unknown at this time w )(bib will be introduced through which witness.
5. A description of the Trial about which the witness s expec testimony regarding each t: ist number of each exhibit introduced through other means to testify, together with a description of thewitness' expected
ANSWER: U n at Ibis time the exhibits about which each witness will testify.
STATE OF Florida\
COUNTY OF Broward
The foregoing instrument was acknowledged before me this 11th day of\
August, 2017 by Brad Edwards, who is personally known\
to me or who has produced as identification and who did/did\
not take an oath.
*X* [Handwritten signature]
(SEAL)\
*[Handwritten signature]*\
(Notary signature)
Maria Kellichian\
(Notary name - print)\
NOTARY PUBLIC, State of Florida
# EXHIBIT C
NOT A CERTIFIED COPY
#### 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 040800XXXXMBAG
v. Aft,
J. et al., JUDGE: HAFe
Defendants/Counter-Plaintiff.
C
#### e NOTICE OF ROGATORIES
PROPOUNDINGit, Plaintiff/Counter-Defendant, Jeffrey Epst 14e/ i * %n"), by and through his undersigned counsel, hereby certifies that the original of No was filed with the Court and a copy of the Notice, together with the original Inte was propounded to through his counsel by electronic servic C a4 swered under oath within the time prescribed by the Florida Rules of Civil Procedu September 5, 2017.
/s/ Tonja Haddad Coleman
Tonja Haddad Coleman, Esq.
Fla. Bar No.: 0176737
Tonja Haddad, PA
5315 SE 7th Street
Suite 301
Fort Lauderdale, Florida 33301
954.467.1223
954.337.3716 (facsimile)
Tonja@TonjaHaddad.com
Efiling@TonjaHaddad.com
#### 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 Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401
Marc Nurik, Esq. 1 East Broward Blvd. Suite 700 Fort Lauderdale, FL 33301
J. Esq. abra mthtojustice.com Jaffe Weissing Fis 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301
Fred Haddad, Esq. 315 SE 7th Street, S e 30 Dee@FredHaddadLaw.c Fort Lauderdale, 3301
Tonja Had Tonja@ton Law 315 SE 7th Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein an, Esquire d.com; efiling@tonjahaddad.com Tonja Haddad, P.A. treet, Suite 301
JEFFREY EPSTEIN,
Plaintiff,
v.
SCOTT ROTHSTEIN, individually,
J, Individually, and L.M., individually.
Defendants.
IN THE CIRCUIT COURT OF THE 1,11•TEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO.502009CA040800XXXXMBAG
JUDGE: HAFELE
"St\\
#### PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OGATORIES TO DEFENDANT/COUNTER-PLAINTIFF BRADLE J. ARDS
Plaintiff/Counter-Defendant Jeffrey Epstein, by and his undersigned counsel and pursuant to Rule 1.340 of the Florida Rules of Civil Pr ereby propounds the attached interrogatories upon Defendant/Counter-Plaintiff ME, and requests answers thereto in accordance with the applicable Flo ' a R of Civil Procedure. A copy of Certification has been filed with the Court as provi in Rule 1.340 of the Florida Rules of Civil Procedure.
### DEFi1i61J AND INSTRUCTIONS
### DEFINITIONS
1. "Documen \`documents" include, but are not limited to, all paper material of any kind, whether, printed, punched, filmed or made in any way; recording tapes or wires, film, phot s, movies or any graphic matter however produced or reproduced; and all mechanical o sound recordings or transcripts thereof.
ecord" includes, but is not limited to, all books of account or other books of every kind, jou alss,edgers, statements, instruments, files, messages, writings of every kind, and other internal or Cher data and other information of every description made or received by you in the regular course of business or otherwise, regardless of the mode in which it is recorded; the original of any such record includes the data or the information comprising a record stored or transmitted in or by means of any electronic, computerized, mechanized, or other information storage or retrieval or transmission system or device which can, upon request, generate, regenerate, or transmit the precise date or other information comprising the record, and an original also includes the visible date or other information so generated, regenerated, or transmitted if it is legible or can be made legible by enlargement or other process.
3. "Identify" or "identification" when used in reference to an individual person means to state their full name, present address (business and residential), if known, and his present employment position and business affiliation, electronic mail addresses and telephone numbers for home and/or business, if known. When used in reference to a person other than an individual person, "identify" or "identification" means to state whether that person is a corporation, partnership, or other organization, and the name, present and last known address, principle place of its business and its telephone number. Once any person has been properly identifier, it shall be sufficient thereafter when identifying that person to state only their name.
1. "Identify" or "identification" when used in reference to a d or documents means to state the date, the author of (or, if different, the signor or signo ddress, type of document (e.g., letter, memorandum, telegram, chart, sketch or dia y other means of identifying with sufficient particularity to meet the requirements for in usion in a request for production of documents pursuant to Rule 1.350 of the Florid' ivil Procedure. If any such document was, but no longer is, in your possession o to your control, state what disposition was made of it and the reason for that disposi • of identifying any document, a true and correct copy may be annexed to and incorpo answers to these interrogatories. If any such document has already been produced, o rence to the document is necessary to enable its identification.
1. "You" or "your" or "Edward ei s'6 J, , and any entity owned or controlled by J. di rectly, and any agents, representatives and any other person or entity directly or in on his behalf. When this definition is specifically or rev terest therein, that is held a in the name of rein, to the extent that there exists an asset or item of income, profit referred to in any interrogatory pro spouse, for the benefit of Edw ouse, in a trust under which 1 pS . ot a trustee or beneficiary, or in the name of an er person in circumstances under which spouse has the use, enjoyment or ben e same or can exercise effective control over the same or (b) in the name of a depen nt c f for the benefit of a dependent child of, in trust under which Ed ndent child is a beneficiary, or in the name of any other person in circumstances ich de ndent child has the use, enjoyment or benefit of the same, or (c under which is a trustee or beneficiary, or in the name of any other person in ces under which has the use, enjoyment or benefit of the same or can ex • ective control over the same, and such asset, liability, or item of income, profit or revenue Id have been included in response to that interrogatory as being held directly or indirectly by or for benefit, but for the fact that an action, request, instruction or direction previously made by or on behalf of resulted in such asset, liability, or item of income, profit or revenue being delivered, allocated, distributed, or transferred to and held as provided in clause (a), (b) or (c) of this definition no. 5, instead of being delivered, allocated, distributed, or transferred to and held by, then for the purposes of determining whether to include such asset, liability or item of income, profit or revenue, or interest therein, in the response to that interrogatory, when "you" or "your" or ME' is used to refer to the ownership thereof, such term shall also refer to any of the circumstances described in clause (a), (b) or (c) of this definition no. 5.
- 6. "Defendant/Counter-Plaintiff' refers to J.
- 7. "Counterclaim" refers to the Counterclaim filed by Epstein.
- 8. "Communication" means and includes any oral or written exchange of words, thoughts or ideas to any other person(s), whether person to person, in a group, by t phone, by letter, by telex or by any other process, electric, electronic or otherwise. All such nications in writing shall include, without limitation, printed, typed, handwritten ther readable documents, correspondence, diaries, logbooks, minutes, notes, studies, su forecasts.
- 9. "Person" means and includes any natural perso association, firm, or any other private organization, governmental a the plural.
- 10. "Refer," "relate," "related," or "relati warranting, prove, proving or tending to prove, dispro or containing, constitute or constituting, describe o or assessing, record or recording. against Jeffrey ration, partnership, r entity, and includes and includes warrant or ing, tending to disprove, contain g, referring, state or stating, assess
- 11. "And" or "or" shall be cons nctively and disjunctively so as to require the broadest possible response to any paysrlar est.
- 12. At all times used h hrase "period in question" shall refer to January 1, 2006 to present. form.
- 13. Words shall be collbtfhed either in the singular or plural and masculine or feminine
A. Yo shall answer each interrogatory separately and fully in writing under oath, unless yo it, in which event you shall state the reasons for your objection and shall answe tent the interrogatory is not objectionable.
### INSTRUCTIONS
B. An interrogatory otherwise proper is not objectionable merely because the answer involves an opinion or contention that relates to a fact or calls for a conclusion or asks for information not within the personal knowledge of the party. You shall respond to such an interrogatory by giving the information that you have and the source on which the information is based.
C. You shall not leave any part of an interrogatory unanswered merely because you have interposed an objection to another part of the interrogatory.
D. Where you object to any interrogatory or sub-part thereof, the objection shall state with specificity all grounds. Any ground not stated in an objection shall be waived.
E. Where you assert a claim of privilege in objecting to any interrogatory or sub-part thereof, and you do not provide an answer on the basis of such assertion:
1. The attorney asserting the privilege shall in the obj n to the interrogatory or sub-part thereof identify the nature of the privilege (includin roduct) which is being claimed and if the privilege is being asserted in connection wi m r defense governed by state law, indicate the state's privilege rule being invoked; an
1. The following information shall be provid (abjection, unless divulgence of such information would cause disclosure of the alleg leged information:
a. For documents: (1) the type of t; (2) general subject matter of the document; (3) the date of the document; (4) such o 1 fo ion as is sufficient to identify the document for a subpoena duces return, induct' appropriate, the author of the document, the addressee of the document, and, wheftn nt, the relationship of the author and addressee to each other;
b. For oral co cati s: (I) the name of the person making the communication and the names of person hile the communication was made and, where not apparent, the relationship of the ent to the person making the communication; (2) the date and place of communican subject matter of the communication.
F. You are to sign ers, and your attorney is to sign any objections.
G. You shall copy of the answers, and objections if any, within the time limits prescribed by Rule th Florida Rules of Civil Procedure.
#### DAMAGES INTERROGATORIES TO
1. State the full name, address, telephone number and description of business for each of your employers (including as an independent contractor, if applicable), at any time during the period in question, and for each employer provide the dates of employment, nature of work, title, position, salary, and description of your duties for such employer, as well as any changes in title, position or duties during your employment during the period in question, any termination thereof and the reasons for such change.
RESPONSE:
(S SA 2. State the full name, address, telephone number, type of entity (i ludi g, without limitation, corporation, partnership, limited partnership, limited liability .. ...ra, sole proprietorship or other entity) and description of the business conducted of eac s enterprise with which you have been affiliated as a principal (including as an own, director, partner, manager, member, shareholder, or in any similar capacity) at any the period in question, as well as the dates of such affiliation, the nature of such any changes during the period in question in the nature of such affiliation, and the f such changes, as well as any income, profits, distributions, salary, commission, or connection with such affiliation.
RESPONSE:
3. State the full name, companies, partnerships, other entities or b ess e question as a me member, an a state the d email any pa received fo ress and telephone number of all corporations, limited liability partnerships, limited liability corporations, sole proprietorships rprises for which you have served at any time during the period in of the Board of Directors, a member of the Board of Trustees, a committee and member, a member of senior management, or in some similar capacity, ce, describe the capacity in which you served, state the full name, address, elephone number of each person to whom you reported in such capacity, and if t, compensation, fee, honorarium, other remuneration or other consideration was such service, state the nature (whether cash or other consideration), frequency, dates, and amounts thereof, and state the dates such service terminated, if applicable, and any reasons therefor.
RESPONSE:
4. Identify each person or entity for whom you performed services for a fee amounting to \$5,000 or more, or on a contingency basis or under some other financial arrangement during the period in question, and provide the dates of service, the nature of the services performed, the terms of the business arrangement with respect to the performance of such services, the dates of any payments for such services and the amounts paid or the amounts owed for such services, and identify the person or persons to whom or which such amounts were paid or such amounts are owed. If you performed such services through a law firm, state the name of the law firm through which you performed such services in addition to the other information requested herein.
#### RESPONSE:
5. At any time during the period in question did you have any interest in a corporation, partnership, limited partnership, limited Habil\* • o including, without limitation, professional service entities? each such entity, the dates on which you held your inte such interest, if applicable, all amounts and other conside and all amounts and consideration received, directlyprindite interest and in connection with the disposition of, and telephone numbers of all other controlling managers, seniors, trust protectors, trustees above in preparing the response to this i any time on or after December 7, 2 ownership thereof at any time on o O SA (5%) percent or more y, trust or other entity, to the name and address of es on which you disposed of u paid to acquire such interest, • y, in connection with holding such ntcrest, and include the names, addresses rs, partners, members, officers, directors, ciaries of such entity. See definition no. 5 with respect to any such interest acquired at uch interest in which there was a change in the ember 7, 2009.
#### RESPONSE:
6. With res provision by you of legal services at any time during the period in question, for each gement through which you provided legal services, describe in detail how you p gal services, whether as an individual, as a sole proprietor, through a professional corporatio a professional partnership, a professional limited liability company, a professional association, or similar entity, or through a combination of any of the foregoing, and for each entity through which you provided such legal services describe in detail all agreed (whether or not followed) and de facto business arrangements with respect to your provision of legal services through such entity, including, without limitation, cost sharing, fee splitting, fee percentage, profit sharing and/or profit participation. If any such business arrangement was memorialized pursuant to an agreement, describe the agreement, all amendments, modifications, and supplements thereto, the dates of the same, and all parties thereto, and identify and state the names, addresses, email
addresses, and telephone numbers of all persons in possession or control of embodiments of such agreement, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format). If the actual business arrangement with respect to your provision of legal services through such entity differed from any memorialized business arrangement, describe the difference and the reasons therefor.
## RESPONSE:
7. Identify by name, address, and telephone number, each and every dom oreign bank, brokerage and/or other financial institution in which there was an accou t in your name or over which you have had signatory authority or other such control riod in question, and provide the account number, the type of account, starting date on hic you had opened such account or had signatory authority or other such control over it. ch account provide the account balance, if any, at March 1, 2009, October 1, 2009, Deeem 1, 2009, and August 1, 2012 and the account balance, if any, at the present date. If ths4tartin ate of the account was a date between any two of the foregoing dates, provide the opening account balance at the starting date. See definition no. 5 above in preparing the respo c to this interrogatory for all such accounts opened at any time on or after December 7, 2009\`
#### RESPONSE:
8. Furnish the following financi rmation with respect to you as of March I, 2009, October I, 2009, December 1, 2009, 1ygust 1, 2012 and as of the present date:
| Assets | ?S e Cost (\$) Fair Market Value (\$) |
| ------ | ----------------------------------- |
| 2. C | er value of insurance |
| 3. | receivable |
| 4. No | receivable |
- 12. Limited Liability Company Interests
- 13. Stocks, bonds, options financial contracts or other securities
- 14. Interests in Commodities
- 15. Pensions or annuities
- 16. Precious and semi-precious stones
- 17. Jewelry
- 18. Artwork
- 19. Antiques
- 20. Watches
- 21. Gold
- 22.
- 23. Silver Musical Instruments
- 24. Other collections (coins, stamps, pens, memorabilia, etc.)
- 25. Contracts or Agreements
"OA
#### b. Liabilities Face Amount (\$) airl1arket Value (\$)
- 1. Loans on insurance
- 2. Accounts payable
- 3. Credit balances payable
- 4. Leases payable
- 5. Notes payable
- 6. Mortgages
- 7. Accrued real estate taxes
- 8. Liens payable
- 9. Judgments
- 10. Reserves
See definition no. 5 above in prej rMg the response to this interrogatory with respect to assets and liabilities reported at 1, 2009, August 1, 2012 and the present date. Provide separate assets and liabilities bles or ch distinct form of ownership described in clauses (a), (b) and (c) of definition no. d for ch separate assets and liability table, identify the owner thereof.
9. Provide the following information relating to your insurance policies in force as at each of March I, 2009, October 1, 2009, December 1, 2009, and August 1, 2012, and as now in force:
Policy No. Cash Surrender Value and Description Insurer Policy Amount Accumulated Dividends
- (3)
- (4)
Policy Loan No. and Description Date Made
See definition no. 5 above in preparing the response August 1, 2012 and as now in force, and for each s each distinct form of ownership described in cl each separate table, identify the owner thereo this in\[nte riogatory at December 1, 2009 and A itk rejerting date provide separate tables for ), (b) and (c) of definition no. 5, and for
RESPONSE:
10. As at each of March at the present date connection there payee of eac outstandin preparing 't presen G4¢ October 1, 2009, December 1, 2009, and August 1, 2012 and as each account receivable and note receivable held by you, and in set forth the name, address and telephone number of the debtor, identify the count receivable and note receivable, and provide the amount then such account receivable and note receivable. See definition no. 5 above in nse to this interrogatory at December 1, 2009 and August 1, 2012 and as at the
RESPONSE:
Automatic Premium Payments Date Made
co
11. At any time during the period in question did you own, claim an interest in, or possess, or control, whether directly or indirectly, in your own name, through ownership by entities in which you hold an interest or control, or through trusts in which you are grantors, trustees or beneficiaries, any real property? If your answer to this interrogatory is in the affirmative, state or identify:
- (a) the dates of acquisition and disposition;
- (b) the property's address;
- (c) the type of property (i.e., house, condominium, commercial building, investment property, etc.);
- (d) the cost of the property at the time purchased;
- (e) fair market value of the property as at each of March I, 2009, October 1, 2 mber 1, 2009, and August 1, 2012, and at the present date; if the property was disposed uired in different name between any two of foregoing dates, also provide the fair nlarltQ e at the time of disposition or acquisition;
- (f) if not still owned, the value of all consideration received, directly r dWctfy, in connection with the disposition of the property, the transferee of the property an lationship to the transferee;
- (g) any mortgages or other encumbrances against the propert d balance, if any, of such mortgages or other encumbrances as at each of March 1, b r 1, 2009, December I, 2009, and August I, 2012, and at the present date; pro s and amounts of all increases in any such mortgages or other encumbrances at an n after December 1, 2009; state the amounts and dates of all mortgage payments e on or after December I, 2009 by any person or entity other than the mortgagor;
- (h) how you titled the property upon its p
- (i) in the event of any changes in the tit which you retained beneficial owners such change, state the amount of a the new titleholder and the rela
- (i) identify the current titlehold
- (j) specifically identify and state 2009 as a result of whic spouse, in trust of any other pe benefit of the dependent c uisition; !der or after December 1, 2009 in connection with p'or effective control of the property, provide the date of sleration paid in connection with the change, identify e new titleholder to you; e relationship of the current titleholder to you. sfers of the property at an time on or after December 1, as helci i the name of spouse, for the benefit of er which spouse is a trustee or beneficiary, or in the name mstances under which spouse has the use, enjoyment or exercise effective control over the same or ) in the name of a wards, for the benefit of a dependent child of, in trust under which t child is a beneficiary, or in the name of any other person in circumstances under wards' de ndent child has the use, enjoyment or benefit of the same, or (c) in trust unde hich is a trustee or beneficiary, or in the name of any other person in circumstances under which has the use, enjoyment or benefit of the same or can exercise effective control over the same, state the date of the transfer, identify the new title holder, describe the amount and form of all consideration exchanged in connection with the transfer, and identify the payor and the payee of all such consideration exchanged.
See definition no. 5 above in preparing the response to this interrogatory with respect to all property which at any time on or after December 1, 2009 was acquired, or disposed of, or as to which at any time on or after December 1, 2009 title was transferred to a holder described in any of clauses (a), (b) and (c) of definition no. 5.
RESPONSE:
12. If at any time during the period in question you did not own the property that was your family, whether full-time or part-time, or if you do not own the property cu by your family, whether full-time or part-time, set forth the name, address telephone number of the person(s) who owned or own the property, the which your family occupied or occupies the property (e.g., lease, sub-I how such arrangement was memorialized, the amount paid for such of such payment, the commencement date and termination date of tha address, email address and telephone number of each of the parti without limitation, the payor of any payment made in conn or not the payor is an actual named party to that arrangem "S ) upied by occupied less and ent pursuant to e arrangement), d the frequency ement, and the name, to tlf9tdTangement, including, that arrangement, whether
RESPONSE:
13. As at each of March I, 2 I, 2009, December 1, 2009, and August 1, 2012 and as at the present date, provide th 11 mg information with respect to each motor vehicle, boat, water craft, or aircraft o ed or used by you as at such date, including, without limitation, in connection with any frac enhip of any of the foregoing:
| | Amount of |
| ------------------------- | -------------------------------------------------------- |
| | S Date Indebtedness Date |
| Descri | o O Cost iNlired if Pledged Pledged Owner |
| (A) Mo | les |
| (specify year) model, SN, | ake, model, VIN, (B) Boats and watercraft (specify make, |
year)
#### (C) Aircraft
(specify make, model, SN, year)
#### (D) Fractional
Ownership Interests (specify company, description of fractional interest, make, model, SN, year)
Specifically identify and state all transfers of the foregoing prope DecemberAl_2009 as a result of which title was held a in the name benefit of spouse, in a trust under which in the name of any other person in circumstances under w enjoyment or benefit of the same or can exercise effective of a dependent child of for the benefit of a which dependent child is a benefici circumstances under which dependen same, or (c) in trust under which person in circumstances under which Edw can exercise effective control over the holder, describe the amount and f transfer, and identify the payor an time on or after ards' spouse, for the stee or beneficiary, or wards' spouse has the use, the same or (b) in the name child of in trust under e name of any other person in h the use, enjoyment or benefit of the beneficiary, or in the name of any other as me use, enjoyment or benefit of the same or the date of the transfer, identify the new title onsideration exchanged in connection with the of all such consideration exchanged.
See definition no. 5 in preparin 1, 2012 and at the present date. nse to this interrogatory at December I, 2009 and August
1 °14.9
### RESPONSE:r 4S
14/ )
14. Set forth the following information regarding all stocks, bonds, options, other securities and other fmancial instruments (including, but not limited to, any interest in money markets and mutual funds), and commodities directly or indirectly owned by you or held on your behalf at each of March 1, 2009, October 1, 2009, December 1, 2009, August 1, 2012 and the present date:
Amount of
Record Number of Date Indebted. Description Issuer Owner Units Acquired cot If Pledged
Specifically identify and state all transfers of the foregoing property at any time on or after December 1, 2009 as a result of which record title was held (a) in the name of spouse, for the benefit of IM\[ spouse, in a trust under which IMM spouse is a trustee or beneficiary, or in the name of any other person in circumstances under which the use, enjoyment or benefit of the same or can exercise effective control over the s the name of a de ndent child of, for the benefit of a dependent child of under which dependent child is a beneficiary, or in the name of circumstances under which de ndent child has the use, enjo nefit of the same, or (c) in trust under which is a trustee or beneficiary, or i the i e of any other person in circumstances under which has the use, enjoyme it of the same or can exercise effective control over the same, state the date of the Iran er, i entify the new record title holder, describe the amount and form of all consideration in connection with the transfer, and identify the payor and the payee of all such con in exchanged. See definition no. 5 in preparing the response to this interrogatory "S ) spouse has e, or (b) in in trust rson in
### RESPONSE:
15. Identify separately for each pa for the benefit of you, whether d' c t through the present date: ounts and dates of all sources of income paid to or directly, for each and every year from January 1, 2009
- (a) salaries, wages, o commissions:
- (b) honoraria
- (c) lecture
- (d) board e e ip, committee membership, advisory board membership andk agement related compensation (including options and
- (e) di nds:
- (f) inte t:
- (g) income from businesses/professional activities:
- (h) partnership income:
- (i) limited liability membership income
- (j) income from other investments
- (k) capital gains:
- (1) annuities and pensions:
- (m) rents and royalties:
- (n) income from estates and mists:
- (o) disposition of commodities
- (p) disposition of personal assets.
- (q) contracts or agreements
See definition no. 5 in preparing the response to this interrogatory, and report such items separately for each distinct form of ownership in clauses (a), (b) and (c) of definition no. 5 and for each separate report, identify the owner.
#### RESPONSE:
O
16. With respect to each of the items set forth in the precedi in atory, state the name, address, email address, and telephone number of the source f ch the income was received (and, where applicable, provide the account numbers of in the financial institutions in which such amounts were received by or for the ben
### RESPONSE:
17. For each direct or indirect you, whether for or without c date of any cash, assets or oth provide a description of on the date of transfer, th directly or indirec address, telepho in preparing on or afte definiti veyance, or other disposition by or for the benefit of, at any time from March 1, 2009 through the present s of value with a fair market value of in excess of \$5,000 roperty or asset transferred, the date of transfer, the fair market value nt and nature of the full consideration received (if any), whether to 'm the consideration was paid, and the full name, address, email ber and the relationship to you of the transferee. See definition no. 5 above e to this interrogatory, and include in your response transfers at any time er 7, 2009 by or to any of the persons listed in clauses (a), (b) and (c) of
#### RESPONS
18. At each of March 1, 2009, October 1, 2009, December 1, 2009, and August 1, 2012 and at the present date, identify each interest directly or indirectly held by you or for your benefit in any Individual Retirement Accounts, Option Plans, pension or profit sharing plans, or any other savings or retirement plans other than those listed in response to previous interrogatories, and include in the response to this interrogatory a description of the type, amount and fair market value of the assets held as at such date.
#### RESPONSE:
19. Has a financial statement, credit application, loan application, lease application or other financial affidavit or questionnaire for you been pre the period from March I, 2009 through the present date? If so, state: address and telephone number of the person or entity to whom the the same was prepared; (c) the date the same was prepared address, email address and telephone number of each pe and/or who currently has a copy of the same. See definitio to this interrogatory, and include in your response fin c applications, lease applications, financing appljeati s questionnaires prepared at any time on or after D clauses (a), (b) and (c) of definition no. 5. lion, financing y time during e, address, email given; (b) the reason led; and (d) the name, om the same was delivered e in preparing your response merits, credit applications, loan other financial affidavits or r 7, 2009 for any of the persons listed in
#### RESPONSE:
20. Identify ev egal T tion * (including, without limitation, alternative dispute resolution proceedings) i .0 have been a participant, including, but not limited to, as a party or as legal counse e during the period in question, including, but not limited to, the title of the action, y of the court, the case or index number, the presiding judge, arbitrator or other offici to the action was filed, a brief description of the nature of the action, and the result of the leg non (e.g. judgment for or against of a certain amount). If you participated as counsel in such legal action, state the amount of all remuneration you have received or which you are entitled to receive in connection with such participation, or if your remuneration is contingent on the outcome of such legal action or is subject to any similar arrangement and there has been no final disposition of such legal action, state in detail the terms of all agreements, understandings, and other arrangements relating to any remuneration you may be entitled to receive in connection with your participation in such legal action.
#### RESPONSE:
21. As at each of March 1, 2009, October 1, 2009, December 1, 2009, and August 1, 012 and at the present date, identify every loan and advance extended to and outstanding fro ou, and in such identification include without limitation the name, address, email addres elephone number of the lender or identify the source of the advance, provide the dat= v he I an or the advance, the due dates of any installment payments, the maturity date, th amount, the rate of interest, the collateral or security interest given by you, your pu t, rrowing funds, and the date and amount of each repayment. If any such loan or as memorialized pursuant to one or more agreements, promissory notes, or other ins, describe each of the same, all amendments, modifications, and supplements thereppiske s of the same, and all parties thereto, and identify and state the names, addressei, em it addresses, and telephone numbers of all persons in possession or control of any and all embodiments of such agreements, promissory notes, other instruments, amendments, zoodifications and supplements, whether written, oral or in electronic format (including, wi lirCation, in emails, texts or other digital or electronic format). Specifically provide the da bunts of all increases in the outstanding principal of any such loans or advances at anytii e o r after December 1, 2009, and the dates and amounts of all loan and advance repayrients made at any time on or after December 1, 2009 by any person or entity other than the o,Oginal borrower thereunder. See definition no. 5 above in preparing your response to this inte a with respect to each such loan or advance, each such increase in the principal amount th each such repayment made at any time on or after December 1, 2009.
### RESPONSE:
22. At each of March 1, 2009, October 1, 2009, December 1, 2009, and August 1, 2012 and at the present date, identify all credit, debit, and/or automatic teller ("ATM") cards used by you, or controlled by you, regardless of whether such cards are titled in your name, at any time during the period in question, and for each such card, identify, state or describe the name and address of the financial institution that issued the card (i.e. VISA, MasterCard, American Express, bank, etc.), the name of the person to whom the card was issued (i.e, the name printed on the card), the card
number printed on such card, the account number assigned by the financial institution for such card, the account debtor for such card and all outstanding account balances in excess of \$5,000 as of such date. See definition no. 5 above in preparing your response to this interrogatory, and include in your response all credit, debit and ATM cards issued at any time on or after December I, 2009 to any of the persons listed in clauses (a), (b) and (c) of definition no. 5. For each such account that is open as of any time on or after December 1, 2009, specifically provide the dates and amounts of all increases in account balances in excess of \$5,000 at any time on or after December I, 2009, and the dates and amounts of all account repayments in excess of \$5,000 made at any time on or after December 1, 2009 by any person or entity other than J. his spouse or the account debtor.
#### RESPONSE:
O C
23. State whether at any time during the period 009 through the present date a trust was established by you, whether directly or ind\* grantor or settlor:
- (a) for any purpose, in whole or in part, relating or having any effect of (i) protecting the wealth, assets, income, profits, investments, or nue of you or your spouse from legal claims or litigation, (ii) limiting the ability to F e actual value of and reducing the amounts of the personal wealth, assets, income, estments or other revenue of you or your spouse, (iii) diverting assets, income, profi inv ents or other revenue away from you or your spouse and to any of the persons listed in cl a), (b) and (c) of definition no. 5, or (iv) otherwise diverting future assets, income, p ts, investments and other revenue away from you or your spouse while retaining effective control beneficial ownership or use thereof for yourself or herself or for the benefit of your ily, d state, describe or identify:
- (a) all instru \_ovtfning the formation and administration of the trust, including the original trust agree = the for, and all amendments, modifications, and supplements thereto;
- (b) the ' trust
- (c) the n es, addresses, email addresses and telephone numbers of the settlors or grantors, the trustees, th trust protectors and the beneficiaries of the mist;
- (d) the assets of the trust, the locations of such assets, and the fair market value of the same at the time of creation and at each of December 1, 2009, August 1, 2012 and the present date;
- (e) the location and persons in possession or control all documents that support your answer to this interrogatory.
### RESPONSE:
24. Identify all federal, state, local and foreign income tax returns filed by or for you, and any businesses, corporations, partnerships, trusts, limited liability companies or other entities owned or controlled by you for any calendar or fiscal year falling within the period, inc identification without limitation, a description of the return, the identity of the tax the return was filed, the date the return was filed, the government agency was filed, including the location, service center and address of the govern such return was filed, the period for which the return was filed, then addresses and telephone numbers of all persons to whom a copy of th who currently hold a copy of the return, and for each such return, i reported income in such return and the separate amounts deriv de in such or whom ich e return y with which dresses, email delivered and/or each of source of all such source.
#### RESPONSE:
25. State, identify and desc i particularity all promises, contracts, agreements, understandings, and arrangeme written, oral or in electronic format (including, without limitation, in emails, texts or o or electronic format) that you and/or your law firm have had with any and all attorne nvestigators, paraprofessionals, and other contractors or individuals (including wi for services provided to or for the benefit of LM, EW, Jane Doe and/or Virginia Giu (n at any time during the period in question, including, without limitation, engag t lett rs, retainer letters, fee sharing arrangements, common interest or joint defense agree Jude in your response the format in which any such promises, contracts, agreements nde tandings and arrangements are embodied, the names, addresses, email addresses • one numbers of all persons to whom such embodiments have been delivered or tran the dates of such delivery or transmission, and whether to your knowledge such embodime are in the possession or control of such persons.
#### RESPONSE:
26. State, identify, and describe with particularity all promises, contracts, agreements, understandings, and arrangements, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format) that you and/or your law firm have or at any time during the period in question had with any and all attorneys, investigators, paraprofessionals, and other contractors or individuals (including, without limitation witnesses for services provided to or for the benefit of you, LM, EW, Jane Doe and/or M) in connection with this Action, or any other matters pertaining to or involving Jeffrey Epstein. Include in your response the format in which any such promises, contracts, agreements, understandings and arrangements are embodied, the names, addresses, email addresses and telephone numbers of all persons to whom such embodiments have been delivered or transmitted, the dates of such delivery or transmission, and whether to your knowledge such embodiments are in the possession or control of such persons; RESPONSE: A Co's
01. State, identify, and describe with particularity prises, contracts, agreements, understandings, and arrangements at any time during od n question, whether written, oral or in electronic format (including, without limitatio, texts or other digital or electronic format) between Jack Scarola, Searcy Denney S hart & Shipley PA, or Boies Schiller Flexner LLP, and/or any and all attorneys, inv t to, paraprofessionals, and other contractors or individuals (including, without limitatio wan ) for services provided to or for the benefit of you in connection with this Action or any other'matters pertaining to Jeffrey Epstein. Include in your response the format in whit ny such promises, contracts, agreements, understandings and arrangements are embodied, \`addresses, email addresses and telephone numbers of all persons to whom such em ave been delivered or transmitted, the dates of such delivery or transmission, and etheij t your knowledge such embodiments are in the possession or control of such persons;
?Se
RESPONSE:
rIN
28. State, identify, and describe with particularity all promises, contracts, agreements, understandings, and arrangements, whether written, oral or in electronic format including, without limitation, in emails, texts or other digital or electronic format) that you, Jaffe, Weissing, Fistos & Lehrman PL and/or any other law firm through which you have provided legal services and/or any other lawyer and/or law firm have or at an time during the period in question have had with LM, EW, Jane Doe or which in any way relates to allegations by LM, EW, Jane Doe or against Jeffrey Epstein, including without limitation engagement letters, retainer letters, fee sharing arrangements, common interest or joint defense agreements, royalty agreements, publishing agreements, literary rights agreements, any other agreements relating to media rights, film rights, television rights, publishing rights, book rights, photograph rights, story rights, agency, or similar matters relating to allegations concerning Jeffrey Epstein. Include in your response the format in which any such promises, contracts, agreements, understandings and arrangements are embodied, the names, addresses, email addresses and telephone numbers of all persons to whom such embod ents have been delivered or transmitted, the dates of such delivery or transmission, and r to your knowledge such embodiments are in the possession or control of such person
#### RESPONSE:
29. State, identify, and describe with particularity all understandings, and arrangements, whether written, oral or in limitation, in \_emails Ltexts or other digital or electronic fo (nee n have or at any time during the pin. in agents, public relations firms, book publishers, au publishers, film or television producers, news a, similar business which in any way relates to al (nee ) against Jeffrey Epstein, incl letters, royalty agreements, publishing a management agreements, any other rights, publishing rights, book ri relating to allegations concemi any such promises, contracts, names, addresses, email add embodiments have been whether to your kno ( s ledg , , contracts, agreements, c format (including, without, EW, Jane Doe or Virginia uestion have had with publicity, to agents, syndicators, newspaper evision networks, entities en a ed in y LM, EW, Jane Doe or out limitation engagement letters, retainer literary rights agreements, agency agreements, relating to media rights, film rights, television aph rights, story rights, agency, or similar matters stein. Include in your response the format in which nts, understandings and arrangements are embodied, the and telephone numbers of all persons to whom such or transmitted, the dates of such delivery or transmission, and embodiments are in the possession or control of such persons.
#### RESPONSE:
av
30. For each payment or distribution made by you and/or your law firm, any entity with which you are affiliated, or pursuant to a joint agreement, regarding the proceeds of settlement paid by Jeffrey Epstein in connection with the settlement of claims of LM, EW, and Jane Doe against Jeffrey Epstein, state, identify, and describe the amount of payment, the date of payment, the payee, and any promises, contracts, agreements, understandings and arrangements regarding said payment, and all amendments, modifications and supplements of the same, pursuant to which such payment was made. Include in your response the aggregate amount of such proceeds of settlement
for each of LM, EW, and Jane Doe retained by you and/or your law firm, the amount of such retained proceeds allocated to the reimbursement of expenses, the amount of such retained proceeds retained by your law firm as its share of any contingency fee, and the amount of such retained proceeds allocated to you as distinguished from your law firm (whether or not paid to you) as your share of the fee payable.
**RESPONSE:**
31. State, identify, and describe with particularity any and all trust arrangements, guardian arrangements, custodial arrangements, or similar arrangements, including accounts established by and/or for the benefit of each of LM, EW, and Jane Doe regarding the receipt, administration, and/or payment or distribution of the proceeds of settlement of claims by LM, EW, or Jane Doe against Jeffrey Epstein. Include in your response a description of the agreements, contracts and instruments, and all amendments, modifications and supplements thereto pursuant to which such arrangements were established, the dates of the same, the names, addresses, email addresses, and telephone numbers of all settlors, grantors, trustees, guardians, custodians, other fiduciaries, and beneficiaries (including, without limitation, contingent beneficiaries) of such arrangements, the names of the account holders, the names of the authorized signatories, the account numbers and the names, addresses, telephone numbers of individual contacts of the financial institutions for all accounts established to receive and hold such proceeds of settlement.
**RESPONSE:**
32. Please describe in detail, quantify, and explain the financial loss, including the amount that you contend to have suffered as described in your Fourth Amended Counterclaim; to wit:
- a. injury to your reputation;
- b. mental anguish, embarrassment and anxiety;
- c. fear of physical injury to you and members of your family;
- d. the loss of the value of your time required to be diverted from your professional responsibilities;
- e. the cost of defending against Epstein's claims.
#### RESPONSE:
33. Please identify with specificity the manner by which you determined that any perceived injury to your reputation, mental anguish, embarrassment and anxiety, fear of injury, and any other damage you allege to have suffered by Epstein's filing suit against you in December 2009 was attributable to the lawsuit and not to being partners with Scott Rothstein/a partner at RRA.
CO SA
34. Please describe in detail and identify with specificity eve media outlet, website, blog, printed materials, seminar materials, or any other printed media on which you, your law firm, or any association with which you are aff ever advertised, references, or otherwise places the name of Jeffrey Epstein, and i ailed description and the date(s) of each and every such reference, advertiseme, e ent, publication, dissemination, or promotion, identify the persons or groups of hom the same was made, and state the locations where made, and state whether of e materials used in connection with such reference, advertisement, placement, tcan, dissemination, or promotion are in your possession or control, or are still avayl4 e or in print, and identify the persons or website from whom such materials may be
#### RESPONSE:
### RESPONSE:
(Th(S" 117145r
%obi
35. Pleasilescribe with particularity any and all evidence, circumstances and events upon which you rely in asserting that your reputation was damaged as alleged in your Counterclaim, including, without limitation, specifically describing how that damage is attributable to Epstein's lawsuit against you.
#### RESPONSE:
36. Please explain in detail the amount of time required to be diverted from your professional responsibilities including, but not limited to, the time lost, each date on which the time was lost, the case/matter on which you would have otherwise spent the time, your billable hourly rate, if any, you allege to have lost, and for each case/matter identified, please provide income derived by you, your firm, or any entity acting on your behalf in that mat all other evidence, methods and calculations on which you intend to rely to q you claim are attributable to time diverted from your professional respo your Counterclaim. amount of se detail th damages as alleged in
### RESPONSE:
37. For eacirant or distribution made by ASts o tein, Rosenfeldt & Alder, =, Jaffe, Weissing, , Fistos & Lehrman P or iefy other law firm through which you have provided legal services and/or any other er or law firm to Beth Williamson in connection with any claims asserted against Je state, identify, and describe the amount of the payment, the date of payment, the he payment proceeds, the reasons for the payment, and any promises, contracts, , understandings and arrangements regarding said payment, and all amendments, ions and supplements of the same, pursuant to which such payment was made.
liN(S
YYY
'....) C 38. Fo yment or distribution made by you, Rothstein, Rosenfeldt & Adler, =, Jaffe, Weissing, wards, Fistos & Lehrman PL and/or any other law firm through which you have provided legal services and/or any other lawyer and/or law firm to L.M., E.W., Jane Doe, any other purported victims, any investigators, paraprofessionals, other attorneys, other contractors or individuals (including, without limitation, witnesses), and any publicity agents, public relations firms, book publishers, authors, journalists, bloggers, reporters, literary agents, syndicators, newspaper publishers, film or television producers, news agencies, television networks, or entities engaged in similar business, which payment in any way relates to claims against Jeffrey Epstein, state, identify, and describe the amount of payment, the date of payment, the source of the payment
proceeds, the reasons for the payment, and any promises, contracts, agreements, understandings and arrangements regarding said payment, and all amendments, modifications and supplements of the same, pursuant to which such payment was made.
#### RESPONSE:
39. For each receivable due at an i time during the relevant period to y Adler, , Jaffe, Weissing, Fistos & Lehrman PL and/ which you have provided legal services from any other lawyer Doe, any other purported victims, any investigators, parapro any publicity agents, public relations firms, book pu reporters, literary agents, syndicators, newspaper pub agencies, television networks, or entities engaged in relates to the instant case or any other case aga Jeffrey Epstein, state, identify, and describe source of the payment prorfteds, the rca agreements, understandings and arran modifications and supplements of the 10N ein, Rosenfeldt & y ther law firm through firm, L.M., E.W., Jane s, any other contractors, and thors, journalists, bloggers, m or television producers, news mess, which receivable in any way Epstein or any other claims against t of payment, the date of payment, the for lfie payment, and any promises, contracts, garding said payment, and all amendments, uant to which such payment was made.
#### RESPONSE:
+6s
4:Ai
State of County of
Before me, the undersigned authority, this day personally appeared J. who produced as Identification, and who first being duly sworn, says that he has read the foregoing, and that all of the matters are true and correct.
Sworn and Subscribed before me this
NOTARY PUBLIC, STATE 0
# EXHIBIT D
NOT A CERTIFIED COPY
#### IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502009CA040800=MBAG
JEFFREY EPSTEIN,
Plaintiff(s),
vs.
SCOTT ROTHSTEIN, individually, J. L.M., individually, individually, and
Defendant(s).
(Or
#### NOTICE OF SERVING ANSWERS TO INTERROGATORIES
J. by and through his undersigned counsel, hereby files this Notice of Serving Answers to Interrogatories with the Court propounded by Jeffrey Epstein on September 5, 2017, and said Answers to Interrogtories have been furnished to the attorneys for Jeffrey Epstein.
I HEREBY CERTIFY to all Counsel on the attached list, this day of CY-41/ex' , 2017. e and correct copy of the foregoing was sent via E-Serve
- C
AROLA
Florida Bar No.: 16944
Attorney E-Mail(s): jsxesearcylaw.com; and mmccann@searcylaw.com
Primary E-Mail: \_searolateam@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 J.
[REDACTED] adv. Epstein\
Case No.: 502009CA040800XXXXMBAG\
Notice of Serving Answers to Interrogatories
**COUNSEL LIST**
William Chester [REDACTED], Esquire\
wcblaw@aol.com; wcblawasst@gmail.com\
250 S Australian Avenue, Suite 1400\
West Palm Beach, FL 33401\
Phone: (561)-655-4777\
Fax: (561)-835-8691\
Attorneys for Jeffrey Epstein
Jack A. Goldberger, Esquire\
jgoldberger@agwpa.com; smahoney@agwpa.com\
Atterbury Goldberger & Weiss, P.A.\
250 Australian Avenue S, Suite 1400\
West Palm Beach, FL 33401\
Phone: (561)-659-8300\
Fax: (561)-835-8691\
Attorneys for Jeffrey Epstein
[REDACTED] J. [REDACTED], Esquire\
staff.efile@pathtojustice.com\
[REDACTED] Jaffe Weissing [REDACTED] Fistos & Lehrman, P.L.\
425 N Andrews Avenue, Suite 2\
Fort Lauderdale, FL 33301\
Phone: (954)-524-2820\
Fax: (954)-524-2822
Fred Haddad, Esquire\
Dee@FredHaddadLaw.com; Fred@FredHaddadLaw.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
Tonja Haddad Coleman, Esquire\
tonja@tonjahaddad.com; efiling@tonjahaddad.com\
Tonja Haddad, P.A.\
315 SE 7th Street, Suite 301\
Fort Lauderdale, FL 33301\
Phone: (954)-467-1223
adv. Epstein Case No.: 502009CA040800)OOOCMBAG Notice of Serving Answers to Interrogatories Fax: (954)-337-3716 Attorneys for Jeffrey Epstein
Marc S. Nurik, Esquire marc@nurildaw.com One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556
Attorneys for Scott Rothstein esA Co
#### DAMAGES INTERROGATORIES TO J.
1. State the full name, address, telephone number and description of business for each of your employers (including as an independent contractor, if applicable), at any time during the period in question, and for each employer provide the dates of employment, nature of work, title, pos•tion, salary, and description of your duties for such employer, as well as any changes in title, pos. n or duties during your employment during the period in question, any termination thereof an easons for such change.
RESPONSE: Objection: The information sought is not relevant, material or rekrna y calculated to lead to the discovery of admissible evidence. The interrogatory seeks to i ade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarilybroad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds tie n pximum number permitted without leave of Court.
"Irc 2. State the full name, address, telephone number, type of entity (including, without limitation, corporation, partnership, limited partnership, limited liability corporation, sole proprietorship or other entity) and description of the business conducted of each business enterprise with which you have been affiliated as a principal (including as an owner, officer, director, partner, manager, member, shareholder, or in any similar capacity) at any time during the period itiquestion, as well as the dates of such affiliation, the nature of such affiliation, any changes duri g_the period in question in the nature of such affiliation, and the reasons for such changes, as well as any I &tie, profits, distributions, salary, commission, or bonus paid in connection with such affiliatio
RESPONSE: 'on: The information sought is not relevant, material or reasonably calculated to lead to the f admissible evidence. The interrogatory seeks to invade the economic privacy of the Cou • WIT and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
3. State the full name, address and telephone number of all corporations, limited liability companies, partnerships, limited partnerships, limited liability corporations, sole proprietorships other entities or business enterprises for which you have served at any time during the period in question as a member of the Board of Directors, a member of the Board of Trustees, a committee member, an advisory board member, a member of senior management, or in some similar capacity, state the dates ofiervice, describe the capacity in which you served, state the full name, address, email address and telephone, number of each person to whom you reported in such capacity, and if any payment, compensation, fee, honorarium, other remuneration or other consideration was received for such service, state the nature (whether cash or other consideration), frequency, dates, and amounts thereof, and state the dates such service terminated, if applicable, and any reasons therefor.
RESPONSE: Objection: The information sought is not relevant, ten or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantial e maximum number permitted without leave of Court.
6 C)\*
4. Identify each person or entity for whom you performed services for a fee amounting to \$5,000 or more, or on a contingency basis or under some other financial arrangement during the period in question, and provide the dates of service, the nature of the services performed, the terms of the business arrangement with respect to the performance of such services, the dates of any payments for such services and the amounts paid or the amounts owed for such services, and identify the person or persons to whom or which such amounts were paid or such amounts are owed. If you performed such services through a law firm, state the name of the law firm through which you performed such services in addition to the other information requested herein.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
5. At any time during the period in question did you have any interest of five (5%) percent or more in a corporation, partnership, limited partnership, limited liability company, trust or other entity, including, without limitation, professional service entities? If so, state the name and address of each such entity, the dates on which you held your interest, the dates on which you disposed of such interest, if applicable, all amounts and other consideration you paid to acquire such interest, and all amounts and consideration received, directly or indirectly, in connection with holding such interest and in connection with the disposition of such interest, and include the names, addresses and telephone numbers of all other controlling shareholders, partners, members, officers, directors, managers, settlers, trust protectors, trustees, and beneficiaries of such entity. See definition no. 5 above in preparing the response to this interrogatory with respect to any such interest acquired at any time on or after December 7, 2009 or any such interest in which there was a change in the ownership thereof at any time on or after December 7, 2009.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
6. With respect to the provision by G you 4¢of legal services at any time during the period in question, for each distinct arrangement through which you provided legal services, describe in detail how you provided legal services, whether as an individual, as a sole proprietor, through a professional corporation, a professional partnership, a professional limited liability company, a professional association, or similar entity, or through a combination of any of the foregoing, and for each entity through which you provided such legal services describe in detail all agreed (whether or not followed) and de faro business arrangements with respect to your proVision of legal services through such entity, including, without limitation, cost sharing, fee splitting, fee percentage, profit sharing and/or profit participation. If any such business arrangement was memorialized pursuant to an agreement, describe the agreement, all amendments, modifications, and supplements thereto, the dates of the same, and all parties thereto, and identify and state the names, addresses, email addresses, and telephone numbers of all persons in possession or control of embodiments of such agreement, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format). If the actual business arrangement with respect to your provision of legal services through such entity differed from any memorialized business arrangement, describe the difference and the masons therefor.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous.
adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories
Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
In addition, this Interrogatory seeks to invade the attorney-client and work product privileges
A
7. Identify by name, address, and telephone number, each and every domestic and foreign ank, brokerage and/or other financial institution in which there was an account maintained in your name or over which you have had signatory authority or other such control during the period in question, and provide the account number, the type of account, starting date on which you had opened such accountor had signatory authority or other such control over it. For each such account provide the account balance, if any, at March I, 2009, October I, 2009, December 1, 2009, and August 1,2012 and the account balance, if any, at the present date. If the starting date of the account was a date between any two of the foregoing dates, provide the opening account balance at the starting date. See definition no. 5 above in preparing the response to this interrogatory for all such accounts opened at any time on or after December, 2009.
RESPONSE: Objection: The information sought is notiAl tinv' material or reasonably calculated to lead to the discovery of admissible evidence. The intern story seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the\\extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
8. Furnish the fqowing financial information with respect to you as of March I, 2009, October I, 2009, Decemb 2009, and August 1, 2012 and as of the present date:
| Assets | Cost (\$) | Fair Market Value (\$) |
| ------------------------------------------------------------------ | -------- | --------------------- |
| 1. Cash | | |
| 2. Cash surrender value of insurance | | |
| 3. Accounts receivable | | |
| 4. Notes receivable | | |
| 5. Real estate, including fractional interests | | |
| 6. Motor Vehicles | | |
| 7. Boats and other watercraft, including fractional interests | | |
| 8. Aircraft, including fractional interests | | |
| 9. Club Memberships | | |
| 10. Interests in Trusts | | |
| 11. Partnership Interests | | |
| 12. Limited Liability Company Interests | | |
| 13. Stocks, bonds, options financial contracts or other securities | | |
adv. Epstein Case No.: 502009CA040800XXXXM BAG Notice of Serving Answers to Interrogatories
- 14. Interests in Commodities
- 15. Pensions or annuities
- 16. Precious and semi-precious stones
- 17. Jewelry
- 18. Artwork
- 19. Antiques
- 20. Watches
- 21. Gold
- 22. Silver
- 23. Musical Instruments
- 24. Other collections (coins, stamps, pens, memorabilia, etc.)
- 25. Contracts or Agreements
#### b. Liabilities Face Amount (\$) Fair rket &lue (\$)
- 1. Loans on insurance
- 2. Accounts payable
- 3. Credit balances payable
- 4. Leases payable
- 5. Notes payable
- 6. Mortgages
- 7. Accrued real estate taxes
- 8. Liens payable
- 9. Judgments
- 10. Reserves
See definition no. 5 above in preparingt≤ **iesp se to this interrogatory with respect to assets and liabilities reported at December I, 2009, A it I, 2012 and the present date. Provide separate assets and liabilities tables for each distinct form of o rship described in clauses (a), (b) and (c) of definition no. 5, and for each separate assets and liability to, dentify the owner thereof.**
**RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-D4ndant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogat apropounded by the Counter-Defendant including subparts substantially exceeds the maxim r permitted without leave of Court.**
**9. Provide the following information relating to your insurance policies in force as at each of March I, 2009, October I, 2009, December I, 2009, and August I. 2012, and as now in force:**
**Policy No. Cash Surrender Value and Description Insurer Policy Amount Accumulated Dividends**
Policy Loan No.
and Description
Automatic Premium Payments
Date Made Date Made
See definition no. 5 above in preparing the response to41) is interrogatory at December I. 2009 and August 1, 2012 and as now in force, and for each su rung date provide separate tables for each distinct form of ownership described in clauses (a) (c) of definition no. 5. and for each separate table, identify the owner thereof
RESPONSE: Objection: The info lead to the discovery of admissibl the Counter-Plaintiff and all othe of Counter-Defendant's Interrogato of interrogatories propound maximum number ?psitted, is not relevant, material or reasonably calculated to . The interrogatory seeks to invade the economic privacy of passed within the extraordinarily broad scope of Definition #5 Counter-Plaintiff further objects on the grounds that the number e Counter-Defendant including subparts substantially exceeds the Mout leave of Court.
10. As at ea 0rch 1, 2009, October 1, 2009, December 1, 2009, and August 1, 2012 and as at the presen ntify each account receivable and note receivable held by you, and in connection therewith orth the name, address and telephone number of the debtor, identify the payee of each such account receivable and note receivable, and provide the amount then outstanding of each such account receivable and note receivable. See definition no. 5 above in preparing the response to this interrogatory at December I, 2009 and August I, 2012 and as at the present date.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
I I. At any time during the period in question did you own, claim an interest in, or possess, or control, whether directly or indirectly, in your own name, through ownership by entities in which you hold an interest or control, or through trusts in which you are grantors, trustees or beneficiaries, any real property? If your answer to this interrogatory is in the affirmative, state or identify:
- (a) the dates of acquisition and disposition;
- (b) the property's address;
- (c) the type of property (i.e., house, condominium, commercial building, investment property, etc.);
- (d) the cost of the property at the time purchased;
- (e) fair market value of the property as at each of March 1, 2009, October 1, 2009, December 1, 2009, and August 1, 2012, and at the present date; if the property was disposed of or acquired in different name between any two of foregoing dates, also provide the fair market value at the time of disposition or acquisition;
- (f) if not still owned, the value of all consideration received, directly or indirectly, in connection with the disposition of the property, the transferee of the property and your relationship to the transferee;
- (g) any mortgages or other encumbrances against the property and the balance, if any, of such mortgages or other encumbrances as at each of March 1, 2009, October 1, 2009, December 1, 2009, and August 1, 2012, and at the present date; provide the dates and amounts of all increases in any such mortgages or other encumbrances at any time on or after December 1, 2009; state the amounts and dates of all mortgage payments made at any time on or after December 1, 2009 by any person or entity other than the mortgagor;
- (h) how you titled the property upon its purchase or acquisition;
- (i) in the event of any changes in the titleholder on or after December 1, 2009 in connection with which you retained beneficial ownership or effective control of the property, provide the date of such change, state the amount of any consideration paid in connection with the change, identify the new titleholder and the relationship of the new titleholder to you;
- (i) identify the current titleholder and the relationship of the current titleholder to you.
- (j) specifically identify and state all transfers of the property at any time on or after December 1, 2009 as a result of which title was held (a) in the name of [REDACTED] spouse, for the benefit of [REDACTED] spouse, in a trust under which Edwards' spouse is a trustee or beneficiary, or in the name of any other person in circumstances under which Edwards' spouse has the use, enjoyment or benefit of the same or can exercise effective control over the same, or (b) in the name of a dependent child of [REDACTED], for the benefit of a dependent child of Edwards, in trust under which [REDACTED] dependent child is a beneficiary, or in the name of any other person in circumstances under which [REDACTED] dependent child has the use, enjoyment or benefit of the same, or (c) in trust under which [REDACTED] is a trustee or beneficiary, or in the name of any other person in circumstances under which [REDACTED] has the use, enjoyment or benefit of the same or can exercise effective control over the same, state the date of the transfer, identify the new title holder, describe the amount and form of all consideration exchanged in connection with the transfer, and identify the payor and the payee of all such consideration exchanged.
See definition no. 5 above in preparing the response to this interrogatory with respect to all property which at any time on or after December 1, 2009 was acquired, or disposed of, or as to which at any time on or after December 1, 2009 title was transferred to a holder described in any of clauses (a), (b) and (c) of definition no. 5.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous.
adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories
Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
- 12. If at any time during the period in question you did not own the property that was occupied by your family, whether full-time or part-time, or if you do not own the property currently occupied by your family, whether full-time or part-time, set forth the name, address, email address and telephone number ofthaPerson(s) who owned or own the property, the arrangement pursuant to which your family occupied or occupies the property (e.g., lease, sub-lease, other arrangement), how such arrangement was memorialized, the amount paid for such occupancy and the frequency of such payment, the commencement date and termination date of that arrangement, and the name, address, email address and telephone number of each of the parties to that arrangement, including, without limitation, the payor of any payment made in connection with that arrangement, whether or not the payor is an actual named party to that arrangement.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grow thatt number of interrogatories propounded by the Counter-Defendant including subparts su all exceeds the maximum number permitted without leave of Court.
- 13. As at each of March I, 2009, October 1, 2009, December 1, 2009, and August 1, 2012 and as at the present date, provide the following information with respect to each motor vehicle, boat, water craft, or aircraft owned or used by you as at such date, including, without limitation, in connection with any fractional ownership of any of the foregoing:
| Descriptions | Cost | Date Acquired | Amount of Indebtedness Date if Pledged | Pledged | Owner |
| ------------ | ---- | ------------- | -------------------------------------- | ------- | ----- |
| | | | | | |
- (A) Motor Vehicles (specify make, model, VIN, year)
- (B) Boats and watercraft (specify make, model, SN,
adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories year)
#### (C) Aircraft
(specify make, model, SN, Yew)
#### (D) Fractional
Ownership Interests (specify company, description of fractional interest, make, model, SN, year)
..-֥ C mt)sr Specifically identify and state all transfers of the foregoing. ur my at any time after December 1, 2009 as a result of which title was held (a) in the name of 'Mr spouse, for the benefit of spouse, in a trust under which s use is a trustee or bepeficiary,-OF in the name of any other person in circumstances under which spouse has the use, enjoyment or benefit of the same or can exercise effective control over the same, or (b) in the name of a dependent child of, for the benefit of a dependent child a in trust under which Edwards' de endent child is a beneficiary, or in the name of any other person in circumstances under which dependent child has the use, enjoyment or benefit of the same, or (c) in trust under which is a trustee or beneficiary, or in the name of any other person in circumstances under which has the use, enjoyment or benefit of the same or can exercise effective control over the same, state the date of the transfer, identify the new title holder, describe the amount and form of all consideration exchanged in connection with the transfer, and identify the payor and the payee of all s h consideration exchanged.
..\*Jr See definition no. 5 in preparing to this interrogatory at December I, 2009 and August I, 2012 and at the present date.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiffand all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
14. Set forth the following information regarding all stocks, bonds, options, other securities and other financial instruments (including, but not limited to, any interest in money markets and mutual funds), and commodities directly or indirectly owned by you or held on your behalf at each of March 1, 2009, October 2009, December 1, 2009, August I, 2012 and the present date:
| Record Number of Date | Indebted. | |
| ------------------------------------- | --------------- | ---------------------- |
| Description Issuer Owner Units | Acquired | Cost If Pledged |
Specifically identify and state all transfers of the foregoing property at any time on or after December 1, 2009 as a result of which record title was held (a) in the name of [REDACTED] spouse, for the benefit of [REDACTED] spouse, in a trust under which [REDACTED] spouse is a trustee or beneficiary, or in the name of any other person in circumstances under which [REDACTED] spouse has the use, enjoyment or benefit of the same or can exercise effective control over the same, or (b) in the name of a dependent child of Edwards, for the benefit of a dependent child of [REDACTED], in trust under which [REDACTED] dependent child is a beneficiary, or in the name of any other person in circumstances under which [REDACTED] dependent child has the use, enjoyment or benefit of the same, or (c) in trust under which [REDACTED] is a trustee or beneficiary, or in the name of any other person in circumstances under which [REDACTED] has the use, enjoyment or benefit of the same or can exercise effective control over the same, state the date of the transfer, identify the new record title holder, describe the amount and form of all consideration exchanged in connection with the transfer, and identify the payor and the payee of all such consideration exchanged. See definition no. 5 in preparing the response to this interrogatory
**RESPONSE:** Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
15. Identify separately for each payor the amounts and dates of all sources of income paid to or for the benefit of you, whether directly or indirectly, for each and every year from January 1, 2009 through the present date:
- (a) salaries, wages, or commissions:
- (b) honoraria
- (c) lecture fees
- (d) board membership, committee membership, advisory board membership and other management related compensation (including [REDACTED] options and [REDACTED] awards)
- (e) dividends:
- (f) interest:
- (g) income from businesses/professional activities:
- (h) partnership income:
- (i) limited liability membership income
- (j) income from other investments
- (k) capital gains:
- (l) annuities and pensions:
- (m) rents and royalties:
- (n) income from estates and trusts:
- (o) disposition of commodities
- (p) disposition of personal assets.
- (q) contracts or agreements
See definition no. 5 in preparing the response to this interrogatory, and report such items separately for each distinct form of ownership in clauses (a), (b) and (c) of definition no. 5 and for each separate report, identify the owner.
RESPONSE: Objection: The information sought is not relevant, material or reasonabl lead to the discovery of admissible evidence. The interrogatory seeks to invade the the Counter-Plaintiff and all others encompassed within the extraordinarily broa of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on th of interrogatories propounded by the Counter-Defendant including sub maximum number permitted without leave of Court. y ated to mic rivacy of f Definition #5 that the number exceeds the
16. With respect to each of the items set forth in th email address, and telephone number of the sou applicable, provide the account numbers of amounts were received by or for the benefi "S 94A) interrogatory, state the name, address, hich the income was received (and, where in the financial institutions in which such
RESPONSE: Objection: The information so t is not relevant, material or reasonably calculated to lead to the discovery of admissible idence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all othe enco d within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interroga Counter-Plaintiff further objects on the grounds that the number of interrogatories propound the Counter-Defendant including subparts substantially exceeds the maximum number permi ut leave of Court.
O
17. For e ct or indirect transfer, conveyance, or other disposition by or for the benefit of you, whether for without consideration, at any time from March 1, 2009 through the present date of any cash, assets or other items of value with a fair market value of in excess of \$5,000 provide a description of the property or asset transferred, the date of transfer, the fair market value on the date of transfer, the amount and nature of the full consideration received (if any), whether directly or indirectly, to whom the consideration was paid, and the full name, address, email address, telephone number and the relationship to you of the transferee. See definition no. 5 above in preparing your response to this interrogatory, and include in your response transfers at any time on or after December 7, 2009 by or to any of the persons listed in clauses (a), (b) and (c) of definition no. 5.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5
of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
18. At each of March 1, 2009, October 1, 2009, December 1, 2009, and August 1, 2012 and at the present date, identify each interest directly or indirectly held by you or for your benefit in any Individual Retirement Accounts, Option Plans, pension or profit sharing plans, or any other savings or retirement plans other than those listed in response to previous interrogatories, and include in the response to this interrogatory a description of the type, amount and fair market value of the assets held as at such date.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant includin 'ubp substantially exceeds the maximum number permitted without leave of Court.
"S )
19. Has a financial statement, credit appRea ,roan application, lease application, financing application or other financial affidavit or questionnaire for you been prepared at any time during the period from March I, 2009 through the present date? If so, state: (a) the name, address, email address and telephone number of the person or entity to whom the same was given; (b) the reason the same was prepared; (c) the date the same was prepared and submitted; and (d) the name, address, email address and telephone number of each person to whom the same was delivered and/or who currently has a copy of the same. See definition no. 5 above in preparing your response to this interrogatory, and include in your response financial statements, credit applications, loan applications, lease applications, financing applications or other financial affidavits or questionnaires prepared at any time on or Mier December 7, 2009 for any of the persons listed in clauses (a), (b) and (e) of definition no. 5.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
**20.** Identify every legal action (including, without limitation, alternative dispute resolution proceedings) in which you have been a participant, including, but not limited to, as a party or as legal counsel at any time during the period in question, including, but not limited to, the title of the action, the name of the court, the case or index number, the presiding judge, arbitrator or other officiant, the date the action was filed, a brief description of the nature of the action, and the result of the legal action (e.g. judgment for or against of a certain amount). If you participated as counsel in such legal action, state the amount of all remuneration you have received or which you are entitled to receive in connection with such participation, or if your remuneration is contingent on the outcome of such legal action or is subject to any similar arrangement and there has been no final disposition of such legal action, state in detail the terms of all agreements, understandings, and other arrangements relating to any remuneration you may be entitled to receive in connection with your participation in such legal action.
**RESPONSE:** Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
In addition, this Interrogatory seeks to invade the attorney-client and work product privileges.
**21.** As at each of March 1, 2009, October 1, 2009, December 1, 2009, and August 1, 2012 and at the present date, identify every loan and advance extended to and outstanding from you, and in such identification include without limitation the name, address, email address and telephone number of the lender or identify the source of the advance, provide the date of the loan or the advance, the due dates of any installment payments, the maturity date, the principal amount, the rate of interest, the collateral or
security interest given by you, your purpose in borrowing funds, and the date and amount of each repayment. If any such loan or advance was memorialized pursuant to one or more agreements, promissory notes, or other instruments, describe each of the same, all amendments, modifications, and supplements thereto, the dates of the same, and all parties thereto, and identify and state the names, addresses, email addresses, and telephone numbers of all persons in possession or control of any and all embodiments of such agreements, promissory notes, other instruments, amendments, modifications and supplements, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format). Specifically provide the dates and amounts of all increases in the outstanding principal of any such loans or advances at any time on or after December 1, 2009, and the dates and amounts of all loan and advance repayments made at any time on or after December 1, 2009 by any person or entity other than the original borrower thereunder. See definition no. 5 above in preparing your response to this interrogatory with respect to each such loan or advance, each such increase in the principal amount thereof, and each such repayment made at any time on or after December 1, 2009.
RESPONSE: Objection: The information sought is not relevant, material or [REDACTED] sonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
22. At each of March 1, 2009, October 1, 2009, December 1, 2009, and August 1, 2012 and at the present date, identify all credit, debit, and/or automatic teller ("ATM") cards used by you, or controlled by you, regardless of whether such cards are titled in your name, at any time during the period in question, and for each such card, identify, state or describe the name and address of the financial institution that issued the card (i.e. VISA, MasterCard, American Express, bank, etc.), the name of the person to whom the card was issued (i.e. the name printed on the card), the card number printed on such card, the account number assigned by the financial institution for such card, the account debtor for such card and all outstanding account balances in excess of \$5,000 as of such date. See definition no. 5 above in preparing your response to this interrogatory, and include in your response all credit, debit and ATM cards issued at any time on or after December 1, 2009 to any of the persons listed in clauses (a), (b) and (c) of definition no. 5. For each such account that is open as of any time on or after December 1, 2009, specifically provide the dates and amounts of all increases in account balances in excess of \$5,000 at any time on or after December 1, 2009, and the dates and amounts of all account repayments in excess of \$5,000 made at any time on or after December 1, 2009 by any person or entity other than [REDACTED] J. [REDACTED], his spouse or the account debtor.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Answers to Interrogatories
of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
23. State whether at any time during the period December 1, 2009 through the present date a trust was established by you, whether directly or indirectly, as grantor or settlor:
(a) for any purpose, in whole or in part, relating to or having any effect of (i) protecting the wealth, assets, income, profits, investments, or other revenue of you or your spouse from legal claims or litigation, (ii) limiting the ability to quantify the actual value of and reducing the amounts of the personal wealth, assets, income, profits, investments or other revenue of you or your spouse, (iii) diverting assets, income, profits, investments or other revenue away from you or your spouse and to any of the persons listed in clauses (a), (b) and (c) of definition no. 5, or (iv) otherwise diverting future assets, income, profits, investments and other revenue away from you or your spouse while retaining effective control and or beneficial ownership or use thereof for yourself or herself or for the benefit of your family, and state, describe or identify:
(a) all instruments governing the formation and administration of the trust, including the original trust agreement therefor, and all amendments, modifications, and supplements thereto;
(b) the situs of the trust
(c) the names, addresses, email addresses and telephone numbers of the settlors or grantors, the trustees, the trust protectors and the beneficiaries of the trust;
(d) the assets of the trust, the locations of such assets, and the fair market value of the same at the time of creation and at each of December 1, 2009, August 1, 2012 and the present date;
(e) the location and persons in possession or control all documents that support your answer to this interrogatory.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
24. Identify all federal, state, local and foreign income tax returns filed by or for you, and any businesses, corporations, partnerships, trusts, limited liability companies or other entities owned or controlled by you for any calendar or fiscal year falling within the period, include in such identification without limitation, a description of the return, the identity of the taxpayer for whom the return was filed, the date the return was filed, the government agency with which the return was filed, including the location, service center and address of the government agency with which such return was filed, the period for which the return was filed, the names, addresses, email addresses and telephone numbers of all persons to whom a copy of the return was delivered and/or who currently hold a copy of the return, and for each such return, identify each of source of all reported income in such return and the separate amounts derived from each such source.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
25. State, identify and describe with particularity all promises, contracts, agreements, understandings, and arrangements, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format) that you and/or your law firm have had with any and all attorneys, investigators, paraprofessionals, and other contractors or individuals (including witnesses) for services provided to or for the benefit of LM, EW, Jane Doe and/or [REDACTED] at any time during the period in question, including, without limitation, engagement letters, retainer letters, fee sharing arrangements, common interest or joint defense agreements. Include in your response the format in which any such promises, contracts, agreements, understandings and arrangements are embodied, the names, addresses, email addresses and telephone numbers of all persons to whom such embodiments have been delivered or transmitted, the dates of such delivery or transmission, and whether to your knowledge such embodiments are in the possession or control of such persons.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
26. State, identify, and describe with particularity all promises, contracts, agreements, understandings, and arrangements, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format) that you and/or your law firm have or at any time during the period in question had with any and all attorneys, investigators, paraprofessionals, and other
contractors or individuals (including, without limitation, witnesses) for services provided to or for the benefit of you, LM, EW, Jane Doe and/or [REDACTED] in connection with this Action, or any other matters pertaining to or involving Jeffrey Epstein. Include in your response the format in which any such promises, contracts, agreements, understandings and arrangements are embodied, the names, addresses, email addresses and telephone numbers of all persons to whom such embodiments have been delivered or transmitted, the dates of such delivery or transmission, and whether to your knowledge such embodiments are in the possession or control of such persons;
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
27. State, identify, and describe with particularity all promises, contracts, agreements, understandings, and arrangements at any time during the period in question, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format) between Jack Scarola, Searcy Denney Scarola Barnhart & Shipley PA, or Boies Schiller Flexner LLP, and/or any and all attorneys, investigators, paraprofessionals, and other contractors or individuals (including, without limitation, witnesses) for services provided to or for the benefit of you in connection with this Action or any other [REDACTED] letters pertaining to Jeffrey Epstein. Include in your response the format in which any such promises, contracts, agreements, understandings and arrangements are embodied, the names, addresses, email addresses and telephone numbers of all persons to whom such embodiments have been delivered or transmitted, the dates of such delivery or transmission, and whether to your knowledge such embodiments are in the possession or control of such persons;
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
28. State, identify, and describe with particularity all promises, contracts, agreements, understandings, and arrangements, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format) that you, =, Jaffe, Weissing, Fistos & Lehnnan PL and/or any other law firm through which you have provided legal services and/or any other law er and/or law firm have or at any time during the period in question have had with LM, EW, Jane Doe or which in any way relates to allegations by LM, EW, Jane Doe or against Jeffrey Epstein, including without limitation engagement letters, retainer letters, fee sharing arrangements, common interest or joint defense agreements, royalty agreements, publishing agreements, literary rights agreements, any other agreements relating to media rights, film rights, television rights, publishing rights, book rights, photograph rights, story rights, agency, or similar matters relating to allegations concerning Jeffrey Epstein. Include in your response the format in which any such promises, contracts, agreements, understandings and arrangements are embodied, the names, addresses, email addresses and telephone numbers of all persons to whom such embodiments have been delivered or transmitted, the dates of such delivery or transmission, and whether to your knot such embodiments are in the possession or control of such persons.
RESPONSE: Objection: The information sought is not relevant, material o'flt sonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
29. State, identify, and describe with particularity all promises, contracts, agreements, understandings, and arrangements, whether written, oral or in electronic format (includin ,. without limitation in emails, texts or other digital or electronic format) that LM, EW, Jane Doe or have or at any time during the period in question have had with publicity agents, public relations firms, book publishers, authors, literary agents, syndicators, newspaper publishers, film or television producers, news agencies, television networks entities engaged in similar business which in any way relates to allegations by LM, LW, Jane Doc or against Jeffrey Epstein, including without limitation engagement letters, retainer letters, royalty agreements, publishing agreements, literary rights agreements, agenw agreements, management agreements, any other agreements relating to media rights, film rights, television rights, publishing rights, book rights, photograph rights, story rights, agency, or similar matferetlating to allegations conceming Jeffrey Epstein. Include in your response the format in which arfrettch promises, contracts, agreements, understandings and arrangements are embodied, the names, addresses, email addresses and telephone numbers of all persons to whom such embodiments have been delivered or transmitted, the dates of such delivery or transmission, and whether to your knowledge such embodiments are in the possession or control of such persons.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
30. For each payment or distribution made by you and/or your law firm, any entity with which you are affiliated, or pursuant to a joint agreement, regarding the proceeds of settlement paid by Jeffrey Epstein in connection with the settlement of claims of LM, EW, and Jane Doe against Jeffrey Epstein, state, identify, and describe the amount of payment, the date of payment, the payee, and any promises, contracts, agreements, understandings and arrangements regarding said payment, and all amendments, modifications and supplements of the same, pursuant to which such payment was made. Include in your response the aggregate amount of such proceeds of settlement for each of LM, EW, and Jane Doe retained by you and/or your law Jinn, the amount of such retained proceeds allocated to the reimbursement of expenses, the amount of such retained proceeds retained by your law firm as its share of any contingency fee, and the amount of such retained proceeds allocated to you as distinguished from your law firm (whether or not paid to you) as your share of the fee payable.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
In addition, this Interrogatory seeks to invade the attorney-client and work product privileges.
Notwithstanding the foregoing objections, Counter-Plaintiff acknowledges that the following sums were paid by Jeffrey Epstein to voluntarily settle the claims of sexual molestation asserted against Jeffrey Epstein by each of the following:
L.M. \$ I n3illion
E.W. S-2 million
Jane Doe 5-23 million
31. State, identify, and describe with particularity any and all trust arrangements, guardian arrangements, custodial arrangements, or similar arrangements, including accounts established by and/or for the benefit of each of LM, EW, and Jane Doe regarding the receipt, administration, and/or payment or distribution of the proceeds of settlement of claims by LM, EW, or Jane Doe against Jeffrey Epstein. Include in your response a description of the agreements, contracts and instruments, and all amendments,
modifications and supplements thereto pursuant to which such arrangements were established, the dates of the same, the names, addresses, email addresses, and telephone numbers of all settlors, grantors, trustees, guardians, custodians, other fiduciaries, and beneficiaries (including, without limitation, contingent beneficiaries) of such arrangements, the names of the account holders, the names of the authorized signatories, the account numbers and the names, addresses, telephone numbers of individual contacts of the financial institutions for all accounts established to receive and hold such proceeds of settlement.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number: rted without leave of Court.
In addition, this Interrogatory seeks to invade the attorney-client and work t privileges.
/ 4.1% Notwithstanding the foregoing objections, Counter-Plaintiff acknowledge's that the following sums were paid by Jeffrey Epstein to voluntarily settle the claims of sexu In lestation asserted against Jeffrey Epstein by each of the following:
L.M. \$ 1 million
E.W. \$ 2 million
Jane Doe \$ 2.5 million
32. Pleisc\\dasoribe in detail, quantify, and explain the financial loss, including the amount that you contend torttive suffered as described in your Fourth Amended Counterclaim; to wit:
- a. injury to your reputation;
- b. mental anguish, embarrassment and anxiety;
- c. fear of physical injury to you and members of your family;
- d. the loss of the value of your time required to be diverted from your professional responsibilities;
- c. the cost of defending against Epstein's claims.
RESPONSE: Each of the listed elements of damage is presently unliquidated and will be established by the verdict of the jury empaneled to hear this case and entrusted with the responsibility to render a verdict that fully and fairly compensates for every element of damage sustained by him in the past and continues to be sustained by him in the future. As the jury will be instructed, there is no exact measure for such damages, but their verdict is required to take all evidence presented to them under consideration and to be fair, just and reasonable under the circumstances as they find them to exist.
33. Please identify with specificity the manner by which you determined that any perceird injury to your reputation, mental anguish, embarrassment and anxiety, fear of injury, and any other damage you allege to have suffered by Epstein's filing suit against you in December 2009 was attribute the lawsuit and not to being partners with Scott Rothstein/a partner at RRA.
C.)
RESPONSE: was never partners with Scott R\_ Lei partner at RRA and consequently could not have sustained any injury attributable c 1 c)cimmpistance that never existed.
\\HC c\\
34. Please describe in detail and identify wits ?Citie ity every social media outlet, website, blog, printed materials, seminar materials, or any other printed or published media on which you, your law firm, or any association with which you are affiliated has ever advertised, references, or otherwise places the name of Jeffrey Epstein, and include a detailed description and the date(s) of each and every such reference, advertisement, placement, publication, dissemination, or promotion, identify the persons or groups of persons to whom the same was made, and state the locations where made, and state whether or not the materials used in connection with such reference, advertisement, placement, publication, dissemination, or promotion am in your possession or control, or are still available on line or in print, and identify the persons or website from whom such materials may be obtained.
RESPONSE: bje Son: The information sought is not relevant, material or reasonably calculated to lead to the diK of admissible evidence. The interrogatory seeks to invade the economic privacy of the CountetsPlaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-\\ Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
In addition, this Interrogatory seeks to invade the attorney-client and work product privileges.
35. Please describe with particularity any and all evidence, circumstances and events upon which you rely in asserting that your reputation was damaged as alleged in your Counterclaim, including, without limitation, specifically describing how that damage is attributable to Epstein's lawsuit against you.
RESPONSE: The allegations of Epstein's maliciously filed Complaint are defamatory per se.
'
36. Please explain in detail the amount of time required be diverted from your professional responsibilities including, but not limited to, the time lost, each date on which the time was lost, the case/matter on which you would have otherwise spent the time, your billable hourly rate, if any, you allege to have lost, and for each case/matter identified, please provide the amount of income derived by you, your firm, or any entity acting on your behalf in that matter. Please detail all other evidence, methods and calculations on which you int o rely to quantify the damages you claim arc attributable to time diverted from your professiona 'bilities as alleged in your Counterclaim.
RESPONSE: Time diverted fro radley professional responsibilities is reflected in previously produced time records a "will be updated prior to the expiration of discovery. Counter-Plaintiff, however, objects to this interrogatory on the grounds that the number of interrogatories propounded by the Counter-Defendant, including subparts, substantially exceeds the maximum number permitted without Ire of court.
0
37. For each payment or distribution made by you, Rothstein, Rosenfeldt & Alder, =, Jaffe, Weissing, Fistos & Lehrman PL and/or any other law firm through which you have provided legal services and/or any other lawyer and/or law firm to Beth Williamson in connection with any claims asserted against Jeffrey Epstein state, identify, and describe the amount of the payment, the date of payment, the source of the payment proceeds, the reasons for the payment, and any promises, contracts, agreements, understandings and arrangements regarding said payment, and all amendments, modifications and supplements of the same, pursuant to which such payment was made.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous.
Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
In addition, this Interrogatory seeks to invade the attorney-client and work product privileges.
**38.** For each payment or distribution made by you, Rothstein, Rosenfeldt & Adler, Farner, Jaffe, Weissing, [REDACTED], Fistos & Lehrman PL and/or any other law firm through which you have provided legal services and/or any other lawyer and/or law firm to L.M., E.W., Jane Doe, any other purported victims, any investigators, paraprofessionals, other attorneys, other contractors or individuals (including, without limitation, witnesses), and any publicity agents, public relations firms, book publishers, authors, journalists, bloggers, reporters, literary agents, syndicators, newspaper publishers, film or television producers, news agencies, television networks, or entities engaged in similar business, which payment in any way relates to claims against Jeffrey Epstein, state, identify, and describe the amount of payment, the date of payment, the source of the payment proceeds, the reasons for the payment, and any promises, contracts, agreements, understandings and arrangements regarding said payment, and all amendments, modifications and supplements of the same, pursuant to which such payment was made.
**RESPONSE:** Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court.
In addition, this Interrogatory seeks to invade the attorney-client and work product privileges.
**39.** For each receivable due at any time during the relevant period to you, Rothstein, Rosenfeldt & Adler, [REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman PL and/or any other law firm through which you have provided legal services from any other lawyer and/or law firm, L.M., E.W., Jane Doe, any other purported victims, any investigators, paraprofessionals, any other contractors, and any publicity agents, public relations firms, book publishers, authors, journalists, bloggers, reporters, literary agents, syndicators, newspaper publishers, film or television producers, news agencies, television networks, or entities engaged in similar business, which receivable in any way relates to
the instant case or any other case against Jeffrey Epstein or any other claims against Jeffrey Epstein, state, identify, and describe the amount of payment, the date of payment, the source of the payment proceeds, the reasons for the payment, and any promises, contracts, agreements, understandings and arrangements regarding said payment, and all amendments, modifications and supplements of the same, pursuant to which such payment was made.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition #5 of Counter-Defendant's Interrogatories. Reference to "the period in question" is vague and ambiguous. Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without ve of Court. In addition, this Interrogatory seeks to invade the attorney-client and work product privileges. Notwithstanding the foregoing objections, Counter-Plaintiff acknowledges that the following sums were paid by Jeffrey Epstein to voluntarily settle the claims of sexual molestation asserted against Jeffrey Epstein by each of the following:
NOTA CERTIFIED
Signature of Answering Party
STATE OF )
COUNTY OF )
The foregoing instrument was acknowledged before me this 28th day of\
September, 2017 by Brad Edwards who is personally known to me or\
who has produced \_\_\_\_\_ (type of identification) as identification\
and who did/did not take an oath.
# EXHIBIT E
NOT A CERTIFIED COPY
JEFFREY EPSTEIN,
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
J, Individually, and L.M., individually.
Defendants.
IN THE CIRCUIT COURT OF THE FwItENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 502009CA040800XXXXMBAG
JUDGE: HAFELE
#### PLAINTIFF/COUNTER-DEFENDANT JEFFREY 'S REQUEST FOR PRODUCTION TO DEFENDANT/CO TER- AINTIFF
Jeffrey Epstein, by and through his undersi 1.350 of the Florida Rules of Civil Procedu produce the documents responsive to th the date of service of this Requ Interrogatories Relating to D responding hereto. cc sel and pursuant to Rule requests that requests within thirty (30) days from 'structions and definitions provided in the ed contemporaneously herewith, shall be used in
#### ITEMS TO BE PRODUCED
- 1. A copy all documents that relate to, or reference or include, any and all informat\* in, or that you referred to in any way in providing your responses to, PI • nter-Defendant Jeffrey Epstein's Interrogatories to Defendant/Counter-PI y Relating to Damages, served contemporaneously herewith.
- 2. copy of all documents that reflect, any and all promises, instruments, contracts, agreements, understandings, and arrangements, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format), and all amendments, modifications and supplements thereto, memorializing, any business arrangements between you and any and all law firms through which you rendered legal services at any time during the period in question, including, without limitation, cost sharing, fee splitting, fee percentage, profit sharing and/or profit participation terms and conditions including, but not limited to, your provision of legal services during your affiliation with Rothstein Rosenfeldt and Adler.
3. A copy of all documents reflecting, any and all instruments, agreements, contracts, understandings, and arrangements, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format), and all amendments, modifications and supplements thereto, memorializing, any and all trust arrangements, guardian arrangements, custodial arrangements or similar arrangements established by and/or for the benefit of each of LM, EW, and Jane Doe regarding the receipt, administration and/or payment or distribution of the proceeds of settlement of claims by LM, EW, or Jane Doe against Jeffrey Epstein.
1. A copy of all documents reflecting, any and all promises, contracts, dj ents, understandings, and arrangements, whether written, oral or in el c rmat (including, without limitation, in emails, texts or other digital or elec at), and all amendments, modifications and supplements thereto, memon y and all arrangements that you and/or your law firm and/or any other law aw rum have or at any time during the period in question had with LM, EW, o ane roe, which in any way relate to allegations by LM, EW, or Jane Doe agai Epstein, including without limitation engagement letters, retainer letters, f arrangements, common interest or joint defense agreements, royalty agreem ing agreements, literary rights agreements, any other agreements relating to ghts, film rights, television rights, publishing rights, book rights, photogra tory rights, agency, or similar matters relating to allegations concerning Je
1. A copy of all documents reflec y d all promises, contracts, agreements, understandings, and arrangements heth written, oral or in electronic format (including, without limitation, in is or other digital or electronic format), and all amendments, modificatio plements thereto, memorializing, any and all a ements that you, any through which you have provided legal services, , Jaffe, Weissing, and, istos & Lehrman PL and/or any other lawyer and/or law firm have or at any time ng the period in question had with any and all attorneys, investigators, other p nals, contractors and consultants and witnesses with respect . to this case or o r ase involving the claims of each of LM, EW, and Jane Doe against Jeffre including without limitation engagement letters, retainer letters, fee shari ments, common interest or joint defense agreements, royalty agreeme dishing agreements, literary rights agreements, any other agreements relatin ia rights, film rights, television rights, publishing rights, book rights, ph rights, story rights, agency, or similar matters relating to allegations conce g Jeffrey Epstein.
1. A copy of all documents reflecting, and all promises, contracts, agreements, understandings, and arrangements, whether written, oral or in electronic format (including, without limitation, in emails, texts or other digital or electronic format), and all amendments, modifications and supplements thereto, memorializing, any and all arrangements that Paul Cassell, Jack Scarola, Searcy Denney Scarola Barnhart & Shipley PA, or Boies Schiller Flexner LLP have or at any time during the period in question had with any and all attorneys (including, without limitation, you, any law firm through
which you then rendered legal services, and Jaffe, Weissing, , Fistos & Lehrman PL), investigators, other professionals, contractors and consultants and witnesses with respect to this case and any other case involving the claims of each of LM, EW, and Jane Doe against Jeffrey Epstein, including without limitation engagement letters, retainer letters, fee sharing arrangements, common interest or joint defense agreements, royalty agreements, publishing agreements, literary rights agreements, any other agreements relating to media rights, film rights, television rights, publishing rights, book rights, photograph rights, story tights, agency, or similar matters relating to allegations concerning Jeffrey Epstein.
7. A copy of all documents, including, without limitation, checks, nsfer instructions, wire transfer confirmations, bank statements, email confi iy. s, tices of Distribution and other documents, reflecting any and all payme stributions made by you, an law fi nn, through which you provided legal sery or Jaffe, Weissing, Fistos & Lehrman PL regarding the of settlement paid by Jeffrey Epstein in connection with the claims of LM, E Jane Doe against Jeffrey Epstein, including, without limitation, payments o tri ons made to or for the benefit of LM, EW or Jane Doe (including, without, to any trusts or similar arrangements or accounts of which any of LM, EW, a were then beneficiaries), payments made to Paul Cassell, payments made o y er law firm or individual lawyer, payments made to investigators, cons visors, or other professionals, payments made to other contractors and pa ad to witnesses.
1. A copy of all documents, incl hout limitation, checks, wire transfer instructions, wire transfer confirms statements, email confirmations, Notices of Distribution and other docum ting in respect of the proceeds of settlement paid by Jeffrey Epstein in con the claims of LM, EW, and Jane Doe against him any and all amounts re allocated to you, any law firm through which you then provided legal servi, Jaffe, Weissing, , Fistos & Lehrman PL as reimbursement of cos expenses or in payment for legal services rendered.
1. A copy of all ilocdments reflecting payments by you, Rothstein, Rosenfeldt & Adler, Fume ffe, Weissing, Fistos & Lehrman PL and/or any other law firm through w yo eve provided le al services and/or an other lawyer and/or law firm to LM. E. ., Jane Doe, , any investigators, pant s, other attorneys, other contractors or persons (including, without li itnesses, publicity agents, public relations firms, book publishers, authors, jouma, bloggers, reporters, literary agents, syndicators, newspaper publishers, film or television producers, news agencies, television networks, other media outlets or entities engaged in similar business), which payments in any way relate to any federal or Florida state cases against Jeffrey Epstein or any other claims against Jeffrey Epstein in which you or your clients were involved.
1. A of all documents refleSp ayments made to you, Rothstein, Rosenfeldt & Adler, , Jaffe, Weissing, Fistos & Lehrman PL and/or any other law firm through which you have provided legal services and/or any other lawyer and/or law _ mrif\_ r or made to or for the benefit of L.M. E.W., Jane Doe, by any investigators, paraprofessionals, other attorneys, other contractors or other persons (including, without limitation, publicity agents, public relations firms, book publishers, authors, journalists, bloggers, reporters, literary agents, syndicators, newspaper publishers, film or television producers, news agencies, television networks, other media outlets or entities engaged in similar business), which payments in any way relate to any federal or Florida state cases against Jeffrey Epstein or any other claims or allegations against Jeffrey Epstein in which you or your clients were involved.
/s/ Tonja Haddad Coleman
Tonja Haddad Coleman, Esq.
Fla. Bar No.: 0176737
LAW OFFICES OF TONJA H
315 SE 7th Street
Suite 301
Fort Lauderdale, Flori
954.467.1223
954.337.37 10
Tonja@t. .com
Efilin IS to, dad.com
# EXHIBIT F
NOT A CERTIFIED COPY
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502009CA040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff(s),
vs.
SCGIT ROTHSTEIN individually, J. individually, and L.M.,
Defendant®.
### )2ESPONSE TO PLAINTIFF/COUNTERID 419PENDANT JEFFREY EPSTEIN'S REQUES TS • DEFENDANT/COUNTER-PLAIN -
I. MI by and through hi tr ysi ed attorneys and pursuant to Rule 1.350, Florida Rules of Civil Procedure, here1? Z?esponiIs to Jeffrey Epstein's, Request for Production dated September 5, 2017 as folios
- 1. Objection. Attom roduct.
- 2. Objection. The reference to "the period in question" is undefined, vague and ambi o s; the' request is overly broad and seeks information that is irrelevant, rmikiterial, and not reasonably calculated to lead to the discovery of admissible evidence; information requested includes attorney work product; attorney-client Ne privileged information, and information protected by rights to financial privacy.
- 3. Objection. The request is overly broad and seeks information that is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence; information requested includes attorney work product; attorney-client privileged information, and information protected by rights to financial privacy.
- 4. Objection. The request is overly broad and seeks information that is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence; information requested includes attorney work product; attogey-client privileged information, and information protected by rights to finar"\\ ncid@i \\vac
- 5. Objection. The request is overly broad and seeks information mat 'is irrelevant, immaterial, and not reasonably calculated to lead to very of admissible evidence; information requested includes attonrrk product; attorney-client privileged information, and information protetct by lights to financial privacy.
- 6. Objection. The request is overly broac( and eelcs information that is irrelevant, immaterial, and not reasonably S\\ otilcul, "0 to lead to the discovery of admissible evidence; information requd d includYes attorney work product; attorney-client privileged informatio 9 ation protected by rights to financial privacy.
- 7. Objection. The est) Is overly broad and seeks information that is irrelevant, immaterial, 'and 'not reasonably calculated to lead to the discovery of admissible o/
- . evideAr inf rmation requested includes attorney work product; attorney-client kKiiiired information, and information protected by rights to financial privacy. Objection. The request is overly broad and seeks information that is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence; information requested includes attorney work product; attorney-client privileged information, and information protected by rights to financial privacy.
adv. Epstein 502009CA040800XXXXMBAG Response to Epstein's Request for Production served 9.5.17 17 ' 6 k) ( S 3
9. Objection. The request is overly broad and seeks information that is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence; information requested includes attorney work product; attoney-client privileged information, and information protected by rights to finan
1. Objection. The request is overly broad and seeks informat'lbp ilJt s irrelevant, immaterial, and not reasonably calculated to lead to th discbvery of admissible evidence; information requested includes alto k product; attorney-client privileged information, and information prot s to financial privacy.
I HEREBY CERTIFY that .a true anderre ,copy of the foregoing was sent via E-Serve l to all Counsel on the attached list, this Ofobu c day of, 2017.
-I
JA OLA No.: 169440 eann@searcylaw.com E-Mail(s): isx@searcvlaw.com; and rimary E-Mail: \_scarolateam@searcylaw.com Seamy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Attorneys for Fax: 561-3
[REDACTED] adv. Epstein\
Case No.: 502009CA040800XXXXMBAG\
Response to Epstein's Request for Production served 9.5.17
COUNSEL LIST
William Chester [REDACTED], Esquire\
wcblaw@aol.com; wcblawasst@gmail.com\
250 S Australian Avenue, Suite 1400\
West Palm Beach, FL 33401\
Phone: (561)-655-4777\
Fax: (561)-835-8691\
Attorneys for Jeffrey Epstein
Jack A. Goldberger, Esquire\
jgoldberger@agwpa.com;\
smahoney@agwpa.com\
Atterbury Goldberger & Weiss, P.A.\
250 Australian Avenue S, Suite 1400\
West Palm Beach, FL 33401\
Phone: (561)-659-8300\
Fax: (561)-835-8691\
Attorneys for Jeffrey Epstein
[REDACTED] J. [REDACTED], Esquire\
staff.efile@pathtojustice.com\
[REDACTED] Jaffe Weissing Edwards Fistos &\
Lehrman, P.L.\
425 N Andrews Avenue, Suite 2\
Fort Lauderdale, FL 33301\
Phone: (954)-524-2820\
Fax: (954)-524-2822
Fred Haddad, Esquire\
Dee@FredHaddadLaw.com;\
Fred@FredHaddadLaw.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
Tonja Haddad Coleman, Esquire\
tonja@tonjahaddad.com;\
efiling@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
Marc S. Nurik, Esquire\
marc@nuriklaw.com\
One E. Broward Blvd., Suite 700\
Fort Lauderdale, FL 33301\
Phone: (954)-745-5849\
Fax: (954)-745-3556\
Attorneys for Scott Rothstein
# EXHIBIT G
NOT A CERTIFIED COPY
#### IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant, JUDGE HAFELE
vs.
SCOTT ROTHSTEIN individually, individually, Defendants/Counter-Plaintiffs.
#### NOTICE OF SERVICING EX PE RI IN l'ERROG i fiSt, TO J.
Go
Jeffrey Epstein, hereby gives notice p kp t to Rule 1.340(e), Florida Rules of Civil Procedure, Expert Interrogatories numbered tugh 16 have been directed to J. this day of
I HEREBY CERTIFY that and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached Elec /Z mService it' list, this day of, 2017.
ricS'
'....)
W. CHESTER JR., P.A. Counsel for Plaintiff 250 S. Australian Avenue, Suite 1400 West Palm Beach, FL 33401 (561) 655-4777 - Phone (561) 835-8691 - Fax E-Mail: wcblaw@aol.com wcblawasst@gmail.com
By: Is/ W. Chester W. CHESTER Florida Bar No. 261858 Jr. JR.
#### Electronic Service List:
### Jack Scarola, Esq.
Searcy, Denney, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Email: mep@searcylaw.com
#### Nichole J. Segal, Esq.
Burlington & Rockenbach, P.A. Courthouse Commons/Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 E-Mail: njs@FLAppellateLaw.com kbt@FLAppellateLaw.com
J. ,Ess, Jaffe, Weissing, , et al 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 E-Mail: staffefile@pathtojustice.com
#### Marc S. Nurik, Esq.
Marc S. Nurik, P.A. 809 N. Dixie Highway, Suite 208 West Palm Beach, FL 33401 E-Mail: marc®nuriklaw.com
#### Jack A. Goldberger, Esq.
Atterbury, Goldberger & Weiss, P. 250 S. Australian Avenue, S7li 1400 West Palm Beach, FL 3401 E-Mails: jgoldberge gwpa om smahon a.com
### Fred Hadda
Haddad, PLLC 1 Financial, Suite 2612 Fort Lauderda e, FL 33394 E-Mails: dee@haddadandnavarrolaw.com
### Tonja Haddad Coleman, Esq.
Tonja Haddad, P.A. 315 S.E. 7th Street, Suite 301 Fort Lauderdale, FL 33301 E-Mails: tonja@tonjahaddad.com efiling@tonjahaddad.com
#### EXPERT INTERROGATORIES TO
- 1. State the name, address and profession of each person whom you expect to call as an expert witness at trial or on whose expert opinions others have relied in forming opinions which you will or may offer at trial. Cos
- 2. With regard to each listed above, state his/her which qualify him/her to testify as an expert i thereof, please provide a copy of each expert' , education and experience ea of expertise; and/or in lieu ent curriculum vitae.
- 3. Give e o3r title of each paper which each expert has authored in the field of his/her ex
- 4. State the name, volume and page number of the publication in which each article or paper listed above can be found.
- 5. State the substance and identify the source of the facts hicTh ch expert has relied in forming any opinion about which the expert is expec tify.
- 6. Give a comp ted I all documents, depositions, exhibits, plans, drawings, ordinances or status ich ea expert has reviewed in forming his/her opinion.
- 7. State the opinions to which the experts aforementioned are expected to testify. C A
- 8. Give a summary of the grounds of each opinion stated, iS C)
- 9. Identify where the listed above has practiced or worked in his/her tiled during the put 10 ye
10. As to each position identified above, please state:
a. Whether the expert was self-employed, employed by someone else or associated as a partner.
b. Each address where the expert practiced or was employed.
c. The dates the expert was with each employer:
d. The type of duty the expert performed with each employer.
- II. If the expert has not practiced or worked in his/her field during the last 10 years, what was his/her employment during this time?
- 12. Did the expert prepare anything or have anything prepared settin er opinions or conclusions reached from his/her examination or any test he/sh
- a. If so, state the date of preparation.
- b. The name or other mea f iddbtification of each individual and entity to the material prepared was stributed. Ca) ( S"
- c. name and address of each person who has present custody of each non-
- cal copy of the material.
- 13. Did the expert prepare or have prepared any material based upon tests, examinations or analysis of documents that he/her conducted in which he/her did not render an opinion? a, If so, state description of all material that was prepared by or for the expert.
- b. The date that the material was prepared. 6.3 SA
- c. The name or other means of idene 4/ "e person to whom all material was distributed.
- d. The name dress of the person who has present custody of each nonident' kal co the material. +0
- 14. If you will do so without a Request to Produce, attach a copy of all materials prepared by or for each expert on the basis of his/her tests, examinations or analyses to your answers to these interrogatories. ,0 0 N
- 15. Is the expert to be compensated for his/her work and effo s ' ection with this action?
- a. If so, describe in detail the basis and/or ra co pensation, the total amount paid to or on behalf of the expert, the am n tly payable to the expert for all services rendered as of the date of yt) \\ w to these interrogatories.
- b. Estimate the totalIm6unt of time reasonably expected to be spent by the expert in completin rvices to be rendered in this matter from the date of your answers to kcon th cl of the case. +O
- c. Describe all additional services expected to be rendered by the expert.
- 16. Has the expert served as an expert witness in any other litigatied case in the past 10 years?
If so, state as to each case:
- a. The style of the case, the Court in which it was filed and the names and addresses of the attorneys involved.
- O
- b. Whether the expert was retained on behalf of the Plaice or Defendant.
A
- c. The general subject m hich the expert provided services.
er sworn testimony was given in the case, and, if so, whether the expert or ou are in possession of a transcript of the testimony.
[REDACTED] J. [REDACTED]
STATE OF \_\_\_\_\_)
COUNTY OF \_\_\_\_\_)
The foregoing instrument was acknowledged before me this \_\_\_\_\_ day of \_\_\_\_\_, 2017, by \_\_\_\_\_, who is personally known to me or who has produced \_\_\_\_\_ as identification and who did/did not take an oath.
( S E A L )
\_\_\_\_\_\
*(Notary signature)*
\_\_\_\_\_\
*(Notary name - print)*
NOTARY PUBLIC, State of Florida
\_\_\_\_\_\
*(Serial number, if any)*
# EXHIBIT H
NOT A CERTIFIED COPY
#### IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant, JUDGE HAFELE
vs.
SCOTT ROTHSTEIN
individually,
individually,
Defendants/Counter-Plaintiffs.
### PLAINTIFF/COUNTER-DEFENDANT, J EPSTEIN'S RE I UEST TO PRODUCE TO DEFENDAN IL O ER-PLAINTIFF REGA Ng EXPERTS \\
COMES NOW the PlaintiffiCounter-Defe FtEY EPSTEIN, by and through undersigned counsel and pursuant to Florida Rules ofCi ocedKre 1.350, requests that Defendant/Counter-Plaintiff, J. produce of the undersigned, for inspection, and/or copying the following within thirty (30) days is nest.
- 1. Copies of any ll depositions of your expert witnesses taken in any other action that are in your possession (O' ding your attorneys).
- 2. all reports rendered by experts applicable to any and all issues in this case. correspondence between counsel for Defendant/Counter/Plaintiff and all experts in this matter, whether electronic or otherwise.
- 4. Each and every article, treatise, book, study, chapter, page, paper, letter, bill, invoice, photograph, videotape, report, records, note, survey, plat or other document or tangible evidence including electronically stored evidence in tangible form, furnished or made available to your expert in connection with this matter.
5. Each and every article, treatise, book, study, chapter, page, paper, letter bill, invoice, photograph, videotape, report, records, note, diagram, survey, plat, or other document, or tangible evidence, including electronically stored evidence in tangible form or other similar source of information considered or reviewed by your expert or upon which your expert relied in evaluating, investigating or formulating his or her opinions in connection with this matter.
1. Any other information reviewed by each expert in connection with this .
1. All documents or tangible items of any nature pertaining to the fol g:
- a. The scope of your employment of expert witnesses is case and the compensation for such service.
- b. The general litigation experience of your ex percentage of work performed for plainti r fendants.
- c. opinions or evaluations during e 1 0) years. The identity of legal actions in w I\*c s in this case, including the of your expert witnesses rendered
- d. The identity of other cases ' h)8ch of your expert witnesses in this case have testified by deposition o a al ring the last ten (10) years.
- e. An approximatio ion of the expert's involvement as an expert witness, which may be the number of hours, percentage of hours, or percentage of earned in ed from serving as an expert witness.
8. Copies of an and al Is, invoices, records, memoranda, checks, check stubs, receipts, 1099's, tax records or othe omr of financial information evidencing payment or compensation paid by s ,ff Defendant/Coun O in and counsel for services provided by your expert witnesses for the last ten (10) years.
9.A 7Your 's expert witnesses' most current curriculum vitae or resume.
10. Each and every document created by your experts in connection with this matter.
01. MI articles, books, papers, manuals, studies or similar documents both formal and informal, written by your experts or to which your experts contributed,
01. Any opinions which were revised or modified.
- 13. A fee schedule for each and every expert.
- 14. All expert reports of the same expert(s) in your possession or that of your attorneys for any other case within the last ten (10) years.
- 15. Copies of all orders pertaining to your experts including any based on motions to limit or bar their opinions or work including but not limited to those orders related to Frye or Daubert.
It is requested that aforesaid productions be made in compliance with Florida Rules of Civil .4....,L Procedure, at the law office of W. CHESTER la, JR., P.A., 250 Sout relit\]) Avenue, Suite 1400, West Palm Beach, FL 33401. Inspection will be made b Meryvation and/or copying.
If Defendant/Counter-Plaintiff's response will bethatt cop es are av ailable for inspection s at the office of Defendant/Counter-Plaintiff's counsel, requested that Plaintiff/Counter-Defendant provide the Defendant/Counter-Plaint h t e cost of those copies so that they may be obtained by Plaintiff/Counter-Defendant's
1 HEREBY CERTIFY that a tru' t copy of the foregoing was sent via E-Serve to all Counsel on the attached Electroni ern• st, this day of, 2017.
+6s
W. CHESTER JR., P.A. Counsel for Plaintiff 250 S. Australian Avenue, Suite 1400 West Palm Beach, FL 33401 (561) 655-4777 - Phone (561) 835-8691 - Fax E-Mail: wcblaw@aol.com wcblawasst@gmail.com
By: /s/ W. Chester Jr. W. CHESTER JR. Florida Bar No. 261858
#### Electronic Service List:
#### Jack Scarola, Esq.
Searcy, Denney, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Email: mcp@searcylaw.com
#### Nichole J. Segal, Esq.
Burlington & Rockenbach, P.A. Courthouse Commons/Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 E-Mail: njs®FLAppellateLaw.com kbt@FLAppellateLaw.com
Jaffe, Weissin:,s, et al 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 E-Mail: staff.efile®pathtojustice.com
### Marc S. Nurik, Esq.
Marc S. Nurik, P.A. 809 N. Dixie Highway, Suite 208 West Palm Beach, FL 33401 E-Mail: marc@nuriklaw.com
#### Jack A. Goldberger, Esq.
Atterbury, Goldberger & Weiss, P . 250 S. Australian Avenue, Suite 14 West Palm Beach, FL 3340 E-Mails: jgoldberger smahone a.com
#### Fred Hadda
Haddad & v LC 1 Financial aza, uite 2612 Fort Lauderda, FL 33394 E-Mails: dee@haddadandnavarrolaw.com
### Tonja Haddad Coleman, Esq.
Tonja Haddad, P.A. 315 S.E. 7th Street, Suite 301 Fort Lauderdale, FL 33301 E-Mails: tonja@tonjahaddad.com efiling®tonjahaddad.com