Draft: efta02759952

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

CASE NO.: 502009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff,¶

vs.¶

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

Defendant,¶

MEMORANDUM IN OPPOSITION TO JEFFREY EPSTEIN'S MOTION TO CO P L D COVERY RESPONSES FROM¶

Counter-Plaintiff J. ), by and through his undersigned counsel and pursuant to Rule 1.380 of the Floridntules Of Civil Procedure, hereby moves this Court to enter an order Denying the Coun ant Jeffrey Epstein's ("Epstein") Motion to Compel Discovery Responses, and in s ereof states as follows:¶

INTRODUCTION¶

Counter- dant's recently filed motion represents nothing more than a delayed effort to obfusca inent pending issues in this case in hopes of further delaying the rapidly approac al date. As noted in Counter-Defendant's motion, this Court entered Orders relevant to the underlying discovery more than five years ago - on April 10, 2012, May 7, 2012, and August 17, 2012. Conveniently excluded from Epstein's Motion is timely compliance with the direction of the Court. In fact, on August 3, 2012, this Court held a hearing regarding outstanding discovery. On August 7, 2012—after that hearing filed his¶

Second Supplemental Response to Epstein's Request to Produce Pursuant to Court Order incorporating all responsive documents produced on May 8, 2012 in response to the Court's May 7, 2012 Order, and further asserting that "Mlle documents contained within Composite Exhibit A and those documents listed on the privilege log attached as Composite Exhibit together comprise the complete universe of responsive documents within possession, custody and control." See August 7, 2012 Motion attached hereto as Exhibit A. On August 9, 2012, communications between and agents of the federal August 7 correspondence, but had been previously pr publically accessible. informed Epstein by way of letter correspondence that the non-electronic '41-7 ent were not included in the pstein and were additionally¶

On August 17, 2012, the Court entered an 'Cc \ responsive to the August 3, 2012 hearing wherein the Court required Counter-Plaintiff to produce non-privileged responsive documents and identify privileged responsive docuinerits in a proper privilege log. By the time the Court entered this Order had already m lied with the Court's direction based upon the discussion that occurred during the August,3 hearing. Despite Epstein's deliberate intention to mislead the Court regarding the statdcof discovery conducted over five years ago, the record is clear that fully comp etwitl ithe most recent relevant Order on this issue back in 2012. See Exhibit A and Exhibit a,¶

MEMORANDUM OF LAW¶

Under Florida law "trial courts are imbued with broad discretion in discovery matters." National Convenience Stores, Inc. v. Embrey, 375 So.2d 358, 359 (Fla. 4th DCA 1979). Although Courts are to give liberal construction to the rules of discove and Courts have broad discretion in discovery matters, such discretion is limited and must erc within the permissible scope of discovery as set forth in the rules. See Nat'l Co ,.'c ?'Stores, Inc. v. Embrey, 375 So. 2d 358, 359 (Fla. 4th DCA 1979). "Parties may ob in discovery regarding any matter, not privileged, that is relevant to the subject matt e pending action" or if the information sought appears reasonably calculated the discovery of admissible evidence. Fla. R. Civ. P. 1.280(6)(1). Pursuant le .280(5), "[w]hen a party withholds information otherwise discoverable under th protection as trial preparation material e shall make the claim expressly and shall describe the nature of the documents, Gomm iicaC oons, or things not produced or disclosed in a manner that, without revealing informat ritself privileged or protected, will enable other parties to assess the applicability of the pthoiregt or protection." Furthermore, Rule 1.280 does not provide a time limit for the filing' privilege log. Allstate Indem. Co. v. Oser, 893 So.2d 675, 677 (Fla. 1st DCA 200 y claiming that it is privileged or subject to¶

Iii\this case, either already made production or objected on a timely basis to requests, and provided a detailed privilege log in accordance with the Court's August 17, 2012 Order. There can be no doubt that did not waive any privilege, but rather filed timely objections and asserted his claims of privilege in accordance with Rule 1.280. Furthermore, as noted above, all documents within possession, custody, or control were either produced¶

[REDACTED] adv. Epstein
2009CA040800XXXXMB
Memorandum in Opposition to Epstein's Motion to Compel Discovery
Responses from [REDACTED] J. [REDACTED]¶

or identified by way of his properly asserted privilege log. Consequently, contrary to Epstein's Motion, [REDACTED] has already fully responded to Epstein's requests.¶

CONCLUSION¶

Wherefore, Counter-Plaintiff respectfully requests that this Court deny Jeffrey Epstein's five-year delayed Motion to Compel Discovery Responses from [REDACTED] J. [REDACTED] as the requested relief is moot as [REDACTED] has already fulfilled his discovery obligations.¶

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 28^th day of Sept., 2017.¶

JACK SCAROLA
Florida Bar No.: 169440
Attorney E-Mail(s): jsx@searcylaw.com; and
mmccann@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
2009CA040800XXXXMB
Memorandum in Opposition to Epstein's Motion to Compel Discovery
Responses from [REDACTED] J. [REDACTED]¶

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¶

Nichole J. Segal, Esquire
njs@FLAppellateLaw.com; kbt@FLAppellateLaw.com
Burlington & Rockenbach, P.A.
444 W Railroad Avenue, Suite 350
West Palm Beach, FL 33401
Phone: (561)-721-0400
Attorneys for [REDACTED] J. Edwards¶

[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¶

adv. Epstein 2009CA040800XXXXMB Memorandum inigtion.lein's Motion to Compel Discovery Responses from J.¶

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 4414sc for Jeffrey Epstein Attorneys for Scott Rothstein IS9¶

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¶

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

CASE NO.: 502009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff,¶

vs.¶

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

Defendant,¶

A¶

SECOND SUPPLEMENTAIALESPOASE TO EPSTEIN'S REOUEST TO PRODUCE t STII#NT 14/ TO COURT ORDER¶

Defendant/Counterplaintiff, BRADLE ( . tr, RDS, by and through his undersigned attorneys, files this Second Suppleme Res S nse to EPSTEIN'S Request to Produce in compliance with this Court's Orde S as follows:¶

• I. Copies of materials revt roduced to counsel for EPSTEIN on May 8, 2012 are attached as C torite Exhibit A. Some of the produced documents contain privilege redacti s as no u tion was culled by electronic search of approximately 28,000 documents ased to by the RRA Bankruptcy Trustee. documents contained within Composite Exhibit A and those documents listed on the privilege log attached as Composite Exhibit B, together comprise the complete universe of responsive documents within possession, custody and control.

A Cos¶

¶

adv. Epstein¶

Case No.: 502009CA040800XXXXMBAG¶

Second Supplemental Response to Epstein's Request to Produce Pursuant to Court Order¶

Page 2 of 3¶

• 4. IIIME reaffirms the accuracy of IIMM Supplemental Response to Request to Produce previously filed on June 8, 2012 and attached as Exhibit C.
• 5. employment with RRA commenced in approximately A of 2009, and he has retained no electronic communications from prior to that

I HEREBY CERTIFY that a true and correct copy of the foregpM 0 en furnished by Electronic and U.S. Mail to all counsel on the attached list, this r of August, 2012.¶

JACK SC¶

Florida 40¶

Searc la Barnhart & Shipley, P.A.¶

+6s¶

Lakes Boulevard¶

ch, Florida 33409¶

) 686-6300¶

561. 383-9451

eys for Defendant/Counterplaintiff,¶

adv. Epstein¶

Case No.: 502009CA040800XXXXMBAG¶

Second Supplemental Response to Epstein's Request to Produce Pursuant to Court Order¶

Page 3 o(3¶

COUNSEL LIST¶

Esquire Jaffe, Weissing, Fistos &¶

Lehrman, FL¶

425 North Andrews Avenue, Suite 2¶

Fort Lauderdale, FL 33301¶

Phone: (954) 524-2820¶

Fax: (954) 524-2822 CO N¶

Jack A. Goldberger, Esquire¶

Phone: (561) 659-8300 "S C)¶

Atterbury, Goldberger & Weiss, P.A.¶

250 Australian Avenue South, Suite 1400¶

West Palm Beach, FL 33401¶

Fax: (561) 835-8691¶

Marc S. Nurik, Esquire¶

One E Broward Blvd., Suite 700¶

Fort Lauderdale, FL 33301¶

Phone: (954) 745-5849¶

Fax: (954) 745-3556¶

Tonja Haddad Coleman, Esqui¶

524 S Andrews Avenue, Suite 2¶

Fort Lauderdale, FL 333¶

Phone: (954) 467-1 3¶

Fax: (954) 337-3¶

Lilly Ann S Esquire¶

The L-S¶

Atto effrey Epstein¶

1441 Bric I Avenue, 15th Floor¶

Miami, FL 33131¶

Phone: (305) 503-5503¶

Fax: (305) 503-6801¶

NOTA CORRIDORED COPY¶

Docs¶

Responsive¶

~~to~~ ORDER¶

EDWARDS ADV. EPSTEIN¶

5-07-2012¶

EXHIBIT A
1 of 164¶

BRAD - PRIVILEGE LOG EMAILS DATED NOVEMBER 2009 TO AUGUST 2010¶

	DATE	TO	FROM	DESCRIPTION	OBJECTION
...Emails01	05/22/2010 9:53am	[REDACTED]	[REDACTED]	Epstein moving assets and sex trafficking	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails01	05/22/2010 9:10am	Conchita [REDACTED]	[REDACTED]	Epstein moving assets and sex trafficking	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails01-02	05/22/2010 8:47am	[REDACTED]	Conchita [REDACTED]	Epstein moving assets and sex trafficking	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails02	05/21/2010 12:44pm	[REDACTED]	Conchita Sarnoff	Epstein moving assets and sex trafficking	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails03	6/2/2010 11:50 am	[REDACTED]; Spencer Kuvin; Mike Fisten	Conchita [REDACTED]	Epstein moving assets and sex trafficking	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails03	6/2/2010 10:49 am	Conchita [REDACTED]; Spencer Kuvin; Mike Fisten	[REDACTED]	Epstein moving assets and sex trafficking	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product

BRAD PRIVILEGE LOG EMAILS DATED NOVEMBER 2009 TO AUGUST 2010¶

#	DATE	TO	FROM	DESCRIPTION	OBJECTION
					privilege
...Emails03-04	6/2/2010 10:42 am	[REDACTED]	[REDACTED] Spencer Kuvin; Mike Fisten	Epstein moving assets and sex trafficking	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails05	6/7/2010 8:01pm	Brad [REDACTED]	Conchita [REDACTED]	Investigation of other potential witnesses.	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails06	6/8/2010 11:30am	Brad [REDACTED]	Conchita [REDACTED]	Location of Witnesses	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails06	6/8/2010 10:13am	Conchita [REDACTED]	Brad Edwards	Location of Witnesses	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails06	6/8/2010 9:52am	Brad [REDACTED]	Conchita [REDACTED]	Location of Witnesses	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails06	6/8/2010 9:27am	Conchita [REDACTED]	Brad [REDACTED]	Location of Witnesses	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product

BRAD PRIVILEGE LOG EMAILS DATED NOVEMBER 2009 TO AUGUST 2010¶

	DATE	TO	FROM	DESCRIPTION	OBJECTION
					privilege
...Emails07	6/8/2010 9:27am	Brad [REDACTED]	[REDACTED]	Location of Witnesses	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails07	6/8/2010 8:55am	[REDACTED]	Brad [REDACTED]	Location of Witnesses	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails07	6/8/2010 8:40am	Brad [REDACTED]	[REDACTED]	Location of Witnesses	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails07	6/8/2010 8:26am	[REDACTED]	Brad Edwards	Location of Witnesses	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails08	6/8/2010 8:10am	Brad [REDACTED]	[REDACTED]	Location of Witnesses	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails08	6/7/2010 21:57 am	[REDACTED]	Brad [REDACTED]	Location of Witnesses	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product

BRAD — PRIVILEGE LOG EMAILS DATED NOVEMBER 2009 TO AUGUST 2010¶

DATE 12 FROM DESCRIPTION I	OBJECTION
.Emails08 6/7/2010 Brad Location of	Irrelevant	not	reasonably
8:24am Witnesses	calculated	to	lead to the
	discovery	of	admissible
	evidence	and	outside the
time	frame	of	Plaintiffs
	complai		Work product
privil	e
.Emails08 6/7/2010 Conchita Brad Location of In:	ant	of	reasonably
20:06 Witnesses	ted	to	lead to the
dEL	y	of	admissible
	ence	and	outside the
time	frame	of	Plaintiff's
	complaint	Work	product
.Emails08 -9 6/7/2010 Brad Conchita Lo 'o of	Irrelevant	not	reasonably
7:57Pm	calculated	to	lead to the
	discovery	of	admissible
	evidence	and	outside the
time	frame	or	Plaintiffs
	complaint	Work	product
.Emails010 6/15/2010 Brad Maritza Vazquez —	Irrelevant	not	reasonably
64 ;:i ‘ ) C
Witness	calculated	to	lead to the
	discovery	of	admissible
	evidence	and	outside the
time	frame	of	Plaintiff's
	complaint	Work	product
.Emails011 6/16/2010 Bra Conchita Information re:	Irrelevant	not	reasonably
1 :10po
Kuvin; Peter
child sex
	calculated	to lead	to the
	discovery	of	admissible
	evidence and		outside the
time	frame	of	Plaintiff's
	complaint	Work	product
.Emaiis012 6/17/2010 Brad Conchita Information re: Irrelevant		not	reasonably
11 :37am child sex
trafficking and
calculated		to lead	to the
discovery		of	admissible
investigation and
preparation for
evidence	and		outside the
time	frame	of	Plaintiff's
complaint		Work	product

BRAD MN PRIVILEGE LOG EMAILS DATED NOVEMBER 2009 TO AUGUST 2010¶

	DATE	TO	FROM	DESCRIPTION	OBJECTION
					privilege
...Emails012	6/17/2010 11:19am	[REDACTED]	Brad [REDACTED]	Information re: child sex trafficking and investigation and preparation for trial.	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails012	6/17/2010 11:16am	Brad [REDACTED]	[REDACTED]	Information re: child sex trafficking and investigation and preparation for trial.	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails012	6/17/2010 10:53am	Conchita [REDACTED]	Brad [REDACTED]	Information re: child sex trafficking and investigation and preparation for trial.	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails012- 013	6/17/2010 10:33am	Brad [REDACTED]	Conchita Sarnoff	Information re: child sex trafficking and investigation and preparation for trial.	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails014	6/30/2010 11:22am	Brad [REDACTED]; Mike Fisten	Conchita [REDACTED]	Location of witnesses in preparation for trial.	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails015	7/5/2010 2:27pm	Brad [REDACTED]	Conchita [REDACTED]	Location of witnesses in preparation for trial.	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product

BRAD PRIVILEGE LOG EMAILS DATED NOVEMBER 2009 TO AUGUST 2010¶

	DATE	TO	FROM	DESCRIPTION	OBJECTION
					privilege
...Emails015	7/5/2010 14:08	[REDACTED]	Brad [REDACTED]	Location of witnesses in preparation for trial.	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails015-016	7/5/2010 2:03pm	Brad [REDACTED]	Conchita [REDACTED]	Location of witnesses in preparation for trial.	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails016	7/5/2010 13:35	Conchita [REDACTED]	Brad [REDACTED]	Location of witnesses in preparation for trial.	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails016	7/5/2010 1:30pm	Brad [REDACTED]	Conchita Sarnoff	Location of witnesses in preparation for trial.	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails017	7/9/2010 3:16pm	Brad [REDACTED]	Conchita [REDACTED]	Conclusion of case.	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege
...Emails017	7/9/2010 13:44	Conchita [REDACTED]	Brad [REDACTED]	Conclusion of case.	Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product

BRAD [REDACTED] - PRIVILEGE LOG
EMAILS DATED NOVEMBER 2009 TO AUGUST 2010¶

<b>[REDACTED]</b>	<b><u>DATE</u></b>	<b><u>TO</u></b>	<b><u>FROM</u></b>	<b><u>DESCRIPTION</u></b>	<b><u>OBJECTION</u></b>
...Emails017	7/9/2010 1:36pm	Brad [REDACTED]	[REDACTED]	Conclusion of case.	privilege Irrelevant- not reasonably calculated to lead to the discovery of admissible evidence and outside the time frame of Plaintiff's complaint. Work product privilege

NOTA CERTIFIED COPY¶

WEST PALM REACH OFFICE¶

2109 PALM REACH LAKES BLVD
WEST PALM REACH FLORIDA 33409¶

PO BOX 762
WEST PALM REACH FLORIDA 33402¶

(561) 886-6300
1-800-760-8607
1-800-220-7006 Spanish¶

SEARCY
DENNEY
SCAROLA
BARNHART
& SHIPLEY, P.A.¶

ITALIAHASSEE OFFICE¶

THE TOWLE HOUSE
SIX NORTH CALHOUN STREET
TALLAHASSEE, FL 32001-0011¶

(850) 224-1600
1-868-549-7011¶

VIA EMAIL and U.S. MAIL
tonja@tonjahaddadpa.com¶

June 08, 2012¶

Tonja Haddad Coleman, Esquire
Law Offices of Tonja Haddad, P.A.
524 S Andrews Avenue, Suite 200N
Fort Lauderdale, FL 33301¶

Re: [REDACTED] adv. Epstein
Our File No.: 291874¶

Dear Ms. Coleman:¶

Attached is our Supplemental Response to Request to Produce as that request was modified by Court Order of April 10, 2012. Upon receipt and review of this attachment, please inform us whether you intend to proceed with Monday's hearing.¶

ATTORNEYS AT LAW
ROSALYN SMITH KAREN-BARNES
* GREGORY BARNHART
T HARDEE [REDACTED] H
LAURIE J BRIGGS
BRIAN R DENNEY
BRENDA S. FULNER
MARIAND [REDACTED]
JAMES W. GUSTAFSON, JR.
JACK P [REDACTED]
DAVID K. KELLEY, JR.
CAMERON M. KENNEDY
[REDACTED]
DARRYL L [REDACTED]
*WILLIAM A. NORTON
[REDACTED] E CURLAN
EDWARD V. RICCI
*JOHN SCAROLA
*CHRISTIAN D. SEARCY
*JOHN A. SHIPLEY H
[REDACTED] K. SPEED H
BRIAN P. [REDACTED] H
KAREN E. TERRY
DONALD J. [REDACTED] H
*C. CALVIN WARRINER H¶

OE COUNSEL
*EARL L. DENNEY, JR.⁵¶

SHAREHOLDERS
*BOARD CERTIFIED¶

ALSO ADVISED
*KENTUCKY
* MARIE
* MARYLAND
* MASSACHUSETTS
* MISSISSIPPI
* NEW HAMPSHIRE
* NEW JERSEY
* VIRGINIA
* WASHINGTON DC¶

FARALEGALS
OWAN AVANTEURER
HARRY M. DUFRESNE
DAVID W. GRAMME
JOHN C. HOPKINS
DEBORAH M. KHARP
WINGENT L. SEOMART, MF
JAMES PETER LIVE
ROBERT W. PATCHER
MARK P. PONCY
KATHREDA SANCH
STEVE M. SAVIN
BORNE S. STARR
WALTER A. STEIN¶

Sincerely,
JACK SCAROLA
JS/men
Esq.
Rec: [REDACTED] J. [REDACTED] Esq.¶

¶

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).¶

[REDACTED] SUPPLEMENTAL RESPONSE TO REQUEST TO PRODUCE¶

Defendant/Counterplaintiff, [REDACTED] J. Edwards, by and through his undersigned attorneys, files this supplemental response to the following request of Epstein:¶

All emails, data, correspondence, and similar documents dated April 1, 2008 through August 1, 2010 by and between [REDACTED] J. [REDACTED], Scott W. Rothstein, Marc Nurik, Cara Holmes, Mike Fisten, and any one of the following regarding or mentioning Jeffrey Epstein in any way; (a) the U.S. Attorney's Office, (b) the State Attorney's Office, (c) the Federal Bureau of Investigation, (d) Conchita Sarnoff, and (e) any other news employees or reporters.¶

Supplemental Response:¶

Except as previously delivered to Epstein's counsel or specifically identified on the previously delivered privilege log, no additional documents responsive to Epstein's request are in [REDACTED] [REDACTED] possession, custody or control.¶

Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Edwards' Supplemental Response to Request to Produce¶

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
Electronic and U.S. Mail to all Counsel on the attached list, this 8^th day of June, 2012¶

Jack Scarola¶

Florida Bar No.: 169440¶

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

2139 Palm Beach Lakes Boulevard¶

West Palm Beach, Florida 33409¶

Phone: (561) 686-6300¶

Fax: (561) 382-9451¶

Attorney for Bradley J. [REDACTED]¶

Edwards adv. Epstein
Case No.: 502009CA040806XXXXMBAG
[REDACTED] Supplemental Response to Request to Produce¶

COUNSEL LIST¶

[REDACTED] J. [REDACTED] Esquire
Farmer, Jaffe, Weissing, [REDACTED] Fistos &
425 North Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301
Phone: (954) 524-2820
Fax: (954) 524-2822¶

Jack A. Goldberger, Esquire
Atterbury, Goldberger & Weiss, P.A.
250 Australian Avenue South, Suite 1400
West Palm Beach, FL 33401
Phone: (561) 659-8300
Fax: (561) 835-8691¶

Marc S. Nurik, Esquire
Law Offices of Marc S. Nurik
One E Broward Blvd., Suite 700
Fort Lauderdale, FL 33301
Phone: (954) 745-5849
Fax: (954) 745-3556¶

Tonja Haddad Coleman, Esquire
Law Offices of Tonja Haddad, P.A.
524 S Andrews Avenue, Suite 200N
Fort Lauderdale, FL 33301
Phone: (954) 467-1223
Fax: (954) 337-3716¶

Lilly Ann Sanchez, Esquire
The L.S. Law Firm
1441 Brickell Avenue, 15th Floor
Miami, FL 33131
Phone: (305) 503-5503
Fax: (305) 503-6801¶

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

CASE NO.: 502009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff,¶

vs.¶

SCOTT ROTHSTEIN, individually,
[REDACTED] J. [REDACTED], individually, and
L.M., individually,¶

Defendant,¶

ADDENDUM TO SUPPLEMENTAL RESPONSE TO DISCOVERY ORDER¶

[REDACTED] J. [REDACTED], through counsel, files this Addendum to the previously filed Supplemental Response to this Court's Order in response to [REDACTED]' Motion for Clarification.¶

See attached letter¶

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Electronic and U.S. Mail to all counsel on the attached list, this 9th day of August, 2012.¶

JACK SCAROLA
Florida Bar No.: 169440
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
Addendum to Supplemental Response to Discovery Order
Page 2 of 2¶

COUNSEL LIST¶

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

Jack A. Goldberger, Esquire
Atterbury, Goldberger & Weiss, P.A.
250 Australian Avenue South, Suite 1400
West Palm Beach, FL 33401
Phone: (561) 659-8300
Fax: (561) 835-8691¶

Marc S. Nurik, Esquire
One E Broward Blvd., Suite 700
Fort Lauderdale, FL 33301
Phone: (954) 745-5849
Fax: (954) 745-3556¶

Tonja Haddad Coleman, Esquire
524 S Andrews Avenue, Suite 200N
Fort Lauderdale, FL 33301
Phone: (954) 467-1223
Fax: (954) 337-3716¶

Lilly Ann Sanchez, Esquire
The L-S Law Firm
Attorney For Jeffrey Epstein
1441 Brickell Avenue, 15th Floor
Miami, FL 33131
Phone: (305) 503-5503
Fax: (305) 503-6801¶

SEARCY
DENNEY
SCAROLA
BARNHART
& SHIPLEY, PA¶

Allernees
at Law¶

WEST PALM BEACH OFFICE:¶

2139 PALM BEACH LAKES BLVD
WEST PALM BEACH, FLORIDA 33409¶

P.O. BOX 3626
WEST PALM BEACH, FLORIDA 33402¶

(561) 686-6300
1-800-780-8607
1-800-220-7006 Spanish¶

TALLAHASSEE OFFICE:¶

THE TOWLE HOUSE
517 NORTH CALHOUN STREET
TALLAHASSEE, FL 32301-1231¶

(850) 224-7600
1-888-549-7011¶

VIA EMAIL and U.S. MAIL
tonja@tonjahaddadpa.com¶

August 09, 2012¶

ATTORNEYS AT LAW:¶

ROSALYN SIA BAKER-BARNES
*F. GREGORY BARNHART
T. HARDEE BASS, III
LAURIE J. BRIGGS
BRIAN R. DENNEY
BRENDA S. FULMER
MARIANO [REDACTED]
JAMES W. GUSTAFSON, JR.
JACK P. [REDACTED]
DAVID K. KELLEY, JR.
CAMERON M. KENNEDY
WILLIAM B. [REDACTED]
DARRYL L. [REDACTED]
*WILLIAM A. NORTON
[REDACTED] E. QUINLAN²
EDWARD V. RICCI
*JOHN SCAROLA
*CHRISTIAN D. SEARCY
*JOHN A. SHIPLEY III
[REDACTED] K. SPEED III
BRIAN P. [REDACTED] I⁴
KAREN E. TERRY
DONALD J. [REDACTED] III
*C. CALVIN WARRINER III¶

DE COUNSEL
*EARL L. DENNEY, JR.⁵¶

SHAREHOLDERS
*BOARD CERTIFIED¶

ALSO ADMITTED
¹KENTUCKY
²MAINE
³MARYLAND
⁴MASSACHUSETTS
⁵MESSISSIPPI
⁶NEW HAMPSHIRE
⁷NEW JERSEY
⁸VIRGINIA
⁹WASHINGTON DC¶

PARALEGALS
VIVIAN AYAN-TEJEDA
RANDY M. DUFRESNE
DAVID W. GILMORE
JOHN C. [REDACTED]
DESORAH M. KNAPP
VINCENT L. LEONARD, JR.
JAMES PETER LOVE
ROBERT W. PITCHER
MARK P. POINCY
KATHLEEN [REDACTED]
STEVE M. [REDACTED]
BONNIE S. STARK
WALTER A. [REDACTED]¶

Tonja Haddad Coleman, Esquire
Law Offices of Tonja Haddad, P.A.
524 S Andrews Avenue, Suite 200N
Fort Lauderdale, FL 33301¶

Re: [REDACTED] adv. Epstein
Our File No.: 291874¶

Dear Ms. Haddad-Coleman:¶

It has just been brought to my attention that our prior Paragraph 13 production and privilege log were limited to electronically stored email communications. Neither the production nor the privilege log included the non-electronic communications between [REDACTED] and agents of the federal government. However, those letters and pleadings have all previously been provided to Mr. Epstein and his counsel through public filings in the Crime Victims' Rights Act proceedings in federal court. In that they remain equally accessible to you now, it is not our intention to separately produce these documents.¶

Sincerely,¶

JACK SCAROLA
JS/mep¶

cc: [REDACTED] J. [REDACTED], Esquire¶

¶