Draft: efta02760618 · The Epstein Index

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

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant,¶

SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually,¶

Defendants/Counter-Plaintiff.¶

,^ PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPS- El S MOTION TO SHORTEN TIME TO RESPOND TO EXPERT INTERROcAVALES, REOUEST TO PRODUCE REGARDING EXPERTS AND NOTICE OF INTENVTO SERVE SUBPOENAS UPON LATE-DISCL bkXPERTS¶

Plaintift'Counterclaim Defendant Je tem ("Plaintiff), moves to shorten the time for Defendant/Counterclaim Plainti ra l Edwards ("Defendant") to respond to his Request to Produce Regarding Experts xhib and Interrogatories Regarding Experts (Exhibit B) and raise objections to his No Sit ' c of arIntent to Serve Subpoenas for Documents upon Defendant's newly (and late) disclos pens xhibit C), and in support thereof, states:¶

eo mber 9, 2017, Defendant filed his Seventh Amended and Supplemental With is 1htfi, for the first time, disclosed an additional eight expert witnesses. See Amended and Suppl ental Witness List (Exhibit D). No reports were provided by any of these expert witnesses.
1. Under this Court's Trial Order, the disclosure of expert witnesses was due more than thirty days ago.

The disclosure of these expert witnesses necessitates substantial additional discovery by Plaintiff on the opinions and background of these expert witnesses. Because of the late disclosure, however, Plaintiff is unable to wait the length of time under Florida Rules of Civil Procedure 1.340 and 1.350 for a response from Defendant, or the response will be due after the discovery deadline and, even more importantly, after the trial, which is currently sche led to start on December 5, 2017.1 Similarly, under Rule 1.351, if Plaintiff was required t 10, or 15, days to allow Defendant time to object before serving subpoenas on th erts, Plaintiff would be effectively denied the right to conduct discovery, as Plainjf not have time to serve the subpoenas and allow a reasonable time for production CS xperts.
For these reasons, and so that Plaintiff h discovery on these late-disclosed expert witn , 1 i Motion for Continuance in the Trial. In the aJte laintiff requests that this Court shorten the time for Defendant to respond to t Notice of Intent to three days, so s e time to conduct additional requests that this Court grant his and for Defendant to raise objections to the 'ses and objections are made by November 16, 2017.

WHEREFORE, Plaint' along with any other relie ourt deems necessary and just. Ily requests that this Court grant the relief sought herein,¶

¹ Plaintiff filed a Motion for Continuance of Trial, which was heard by this Court on November 7, 2017. This Court took the Motion under advisement, and has not yet ruled, but this late disclosure (after that hearing) is yet another reason that a continuance is not only appropriate, but necessary in this case.¶

CERTIFICATE OF SERVICE¶

I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on November 13, 2017, through the Court's e-filing portal pursuant to Florida Rule of Judicial Administration 2.516(b)(1).¶

LINK & ROCKENBACH, P.A.
1555 Palm Beach Lakes Boulevard, Suite 301
West 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@linkrocklaw.com
Secondary: Tina@linkrocklaw.com
Secondary: Troy@linkrocklaw.com
Secondary: Tanya@linkrocklaw.com
Secondary: Eservice@linkrocklaw.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 <u>mep@searcylaw.com</u> <u>jsx@searcylaw.com</u> <u>scarolatcam@searcylaw.com</u> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> <u>J. [REDACTED]</u>	Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 <u>njs@FLAppellateLaw.com</u> <u>kbt@FLAppellateLaw.com</u> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> <u>J. [REDACTED]</u>
-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------	--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

<p>J. [REDACTED] Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 <a href="mailto:brad@epllc.com">brad@epllc.com</a> <a href="mailto:staff.efile@pathtojustice.com">staff.efile@pathtojustice.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>	<p>Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 <a href="mailto:marc@nuriklaw.com">marc@nuriklaw.com</a> <i>Counsel for Defendant Scott Rothstein</i></p>
<p>Tonja Haddad Coleman 315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, FL 33301 <a href="mailto:tonja@tonjahaddad.com">tonja@tonjahaddad.com</a> <a href="mailto:efiling@tonjahaddad.com">efiling@tonjahaddad.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Fred Haddad Haddad & Navarro, PLLC 1 Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 <a href="mailto:dee@haddadandnavarrolaw.com">dee@haddadandnavarrolaw.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>
<p>W. Chester [REDACTED], Jr. W. Chester [REDACTED], Jr. P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:wcblaw@aol.com">wcblaw@aol.com</a> <a href="mailto:wcblawasst@gmail.com">wcblawasst@gmail.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:jgoldberger@agwpa.com">jgoldberger@agwpa.com</a> <a href="mailto:smahoney@agwpa.com">smahoney@agwpa.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>

NOTA CERTIFICATE¶

EXHIBIT A¶

NOT A CERTIFIED COPY¶

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

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant,¶

v.¶

SCOTT ROTHSTEIN individually, and J. individually,¶

Defendants/Counter-Plaintiff.¶

/¶

PLAINTIFF/COUNTER-DEFENDANT J PRODUCE TO DEFENDANT/COUNTERC REGARD PSTEIN' L INTIFF RTS¶

A¶

Co's¶

Plaintiff'Counter-Defendant, Je EpsWh, pursuant to Florida Rule of Civil Procedure 1.350, requests that Defendant/C - sntiff, documents within the time pe fitted der Rule 1.350 or a shorter time as the Court may order pursuant to Plaintiffito fendant's Motion to Shorten the Time to Respond. J. M, produce the following¶

DEFINITIONS¶

niunication" or "communications" mean any oral, written or electronic utteran on or statement of any nature whatsoever, by and to whomsoever made, including, but not limited to, any documents, correspondence, letters, facsimiles, e-mails, text messages, voice recordings, video recordings, voicemail, instant messages, conversations, dialogues, discussions, interviews, conferences, meetings, consultations, agreements, and other understandings or exchanges between or among two or more people.¶

"Document' or "documents" mean all paper documents, graphic or auditory records or representations, tangible items, and electronically stored information, and shall have the broadest possible meaning accorded to it consistent with Florida Rule of Civil Procedure 1.280 (which is incorporated in this definition as if fully set forth), and includes, by way of illustration only and not by way of limitation, the following items which are in your possessi n, control, knowledge, or are known to you:

a. All written, paper or printed material of any kind, in ut not limited to: all transmittal slips, memoranda, notes, agendas, notices, books, brochures, calendars, employme les, ouncements, meeting minutes, records of meetings, rg6o conversations, newsletters, transcripts, diaries, ap studies, checks, k ')tubs, invoices, financial statements, bank statements, mmunkations, interoffice and intraoffice exchanges, conve quiries, replies, correspondence, and letters, whether in per ry in writing, or by means of any other transmittal devi es, and all originals, reproductions, copies, changes, amendments, drafts and all non-identical copies of the foregoing; Graphic or auditory records or representations of any kind, including, but not limited to: all images, photographs, charts, drawings, sketches, diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser discs, digital versatile discs, Blu-ray discs, Ultraviolet discs, cassette tapes, reel to reel tapes, recordings, sound bites, motion pictures, voice messages, telegrams, summaries, lis, ations, facsimile transmissions, ke books, agreements, contracts, reports,

and all originals, reproductions, copies, changes, amendments, drafts and all non-identical copies of the foregoing; and¶

c. Electronically stored information, electronic, mechanical and electrical records or representations of any kind including, but not limited to: all electronic communications, text messages, e-mails, instant messages, computer logs, network logs, Internet history, document f readsheet tiles, presentation files, database files, desktop publi • source code tiles, object code files, executable files, da management files, text files, portable do nt flfhat files, tabulated data tiles, virtual machine files, XML age files, image files, design tiles, GIS files, system files, 5dln tssmfiles, " disk image files, audio files, video files, backup fil and all originals, reproductions, copies, d c changes, amen (defined he defined *pt files, project, ra, and all non-identical copies of the foregoing 1"; each individual electronically stored document is an "ESI document").

For purpo e foregoing, documents may be located, stored or archived in any physical location n any lectronic storage media, including, without limitation, any computer, server, appli ce, oud-based service, web-based service, database, internal hard drive, external N hard state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the term "draft" means any earlier, preliminary, preparatory, or tentative version of all or part of a document, whether or not such draft was superseded by a later draft and whether or not the draft's terms are the same as or different from the final document's terms. Please note that "Document" and "Documents" as defined herein specifically include "Communication" and "Communications" as defined above.¶

"Native Format" means the file format of ESI in the application in which such ESI was originally created.
"Person" as used herein means any natural person or any entity, int7Rtliig, without limitation, any individual, public company, private company, firm, corpojali y 'ted liability company, joint venture, trust, proprietorship, tenancy, association, p department, governmental body, bureau, board, commission, or oth1RTorm of public or private entity. With respect to an entity, Person shall include all s m rand affiliates of the entity, as well as the present and former directors, officers, ero ttoeys, agents and anyone acting on behalf of, at the direction of, or under the "bbl o the entity or its subsidiaries or affiliates. usiness, agency,
The terms "you" or "yo mea J. and his representatives, attorneys, accountants, agents and e erson acting under his control or on his behalf.
"Relates to" Ling to" mean authorizing, concerning, constituting, comprising, containing, ting of, connected with, describing, disclosing, discussing, evidencing, expl tioning, pertaining to, proposing, reflecting, regarding, referring to, directly or in, setting forth, showing, or summarizing.

"Lawsuit" means the litigation styled Jetey Epstein v. Scott Rothstein and J.M, Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit in and for Palm Beach County, Florida.¶

"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E.W. or any other clients represented by J. against Jeffrey Epstein from January 1, 2008 to the present.
"Tagged Image File Format" or "TIFF' refer to the CCITT Group IV graphic file format for storing bit-mapped images.
"Experts" refers to all expert witnesses disclosed on your Seven ded and Supplemental Witness List dated November 9, 2017, and all other indivitals iptenndd to elicit expert testimony from at the trial of this matter including, but not limited to, cmard J. Jansen, Robert C. Josefsberg, Charles Lichtman, Spencer Kuvin, Theodore Leopold, Adam Horowitz, Isidro M. =, Earleen Cote and William Berger.
Where appropriate:
informs( your po (cri res se to this Request for Production, you are required to furnish all ments which are, or have been, in your possession, custody, or control, or in on, custody, or control.
Unless otherwise specifically stated in each Request, the relevant time period shall be the period from January 1, 2008 to the present.

a.
b.
c.
d.
e.
f. use of the singular inch ud the past tense includes the words "and" an the words "all" the word "inc use of the rith o f 1, and vice versa; e tense; tr" th conjunctive and disjunctive; can "any and all"; ans "including without limitation"; and hcludes the feminine, and vice versa.

1;Zille¶

INSTRUCTIONS¶

General Instructions¶

ESI Instructions¶

ESI Production Format. ES! shall be produced electronically, either in (1) Native Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files. For each ES! document, all metadata must remain intact and all parent/child document relationships must be maintained. All ESI shall be collected using methods that prevent the spoliation of data.
Production Media. The production of ESI as described he be made on an external hard drive, flash drive, CD or DVD ("Production Media"). c e ction Media shall include a unique identifying label specifying: (a) your identity- the te of the production of ESI; and (c) the Lawsuit name and number.
ESI of Limited Accessibility. If you i lif, at any ESI document responsive to this Request for Production is not reasonably c Atsis i " : (1) timely identify such ESI document with reasonable particularity, and (2) p ' the is for declining to produce the ESI document, including, for example, any limi o access, the likely costs that might be incurred in accessing and producing the E ent, the method used for storage of the ESI document and all locations in which the cument is kept.
TI . ES! produced as TIFF image files shall be produced as follows: (1) each pro. f IFF image files shall be accompanied by a corresponding load file ("Image Load ) each TIFF image file must contain the same information and same physical representation as the Native Format file from which the TIFF image file was created; (3) each TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be accompanied by an extracted text file containing the extracted text of the Native Format file from which the TIFF image file was created; (5) each extracted text file shall be named to match the endorsed number assigned to the first page of each corresponding TIFF image file; (6) the extracted text files shall be accompanied by a Control List File ("L87"); (7) each production of TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon ("OPT"), which shall provide the beginning and ending endorsed number of each TIFF image file and the number of pages it includes; and (8) each production of TIFF image fil must be accompanied by a data load file ("Data Load File" or "DA7") that contains bot ash value and all available metadata of the Native Format files from which the )ge files were created. Further, the following instructions apply to the production o files:

a. Processing Specifications. For each Nati o file that is converted to 77FF format: (1) all tracked Chang- 1 aintained so that all changes are visible; (2) OLE Emb SS, hall not be extracted as separate documents; (3) author all remain or be made visible; (4) hidden columns, cells, ro wor eets and other hidden data shall remain or be made visibl 5 r ter notes shall remain or be made visible; and (6) to the exte a foreign language is produced, processing of such ESI icode-compliant. ent Unitization. If a Native Format file that is converted to TIFF format is more than one page, the unitization of the file and any attachments or affixed notes must be maintained as it existed when collected. If unitization cannot be maintained, the original unitization must be documented in the Data Load File or otherwise electronically tracked.
c. Color. If a Native Format file that is converted to TIFF format contains color, the TIFF image file need not be produced in color. However, we reserve the right to make a request for a file to be produced in color.
d. Where TIFF Image File Format is Impracticable. In the event that production of a Native Format file as a TIFF image would be impracticable, you shall produce such file in Native Format with all meta tact. You shall provide a single page TIFF image placeholderle g the title of the Native Format file not being produced as a
e. Spreadsheets. All Microsoft Excel files, ' ' ar it lfIii-Microsoft spreadsheet files, and graphical compilations o ,t l)e t data, shall be produced in Native Format with all cell 'Sty, o, rows and worksheets and other information unhidden .
f. Ri t to R t ormat files. We reserve the right to demand production ormat of any file produced by you as a TIFF image file.

OUESTS FOR PRODUCTION¶

I. rrespo dence between you and the Experts relating to the subject matter of the Lawsuit, tms or defenses of the Lawsuit, or the Experts' opinions in relation to the La
- 3.
1. Lawsuits. All correspondence between you and the Experts relating to the Other Lawsuits. All correspondence between the Experts and any persons relating to the Lawsuits. All correspondence between the Experts and any persons relating to the Other

All billing records, invoices, or statements and any and all retainer agreements, engagement letters or other contracts, relating to services performed, or to be performed, by the Experts in this Lawsuit or any of the Other Lawsuits.
All versions (including draft versions, final versions, current versions and prior versions) of resumes, curriculum vitas and biographies for the Experts.
All reports, and all draft versions of those reports, that have been by the Experts or at the direction of the Experts in relation to their involvement • • wsuit. These reports include any written reports, whether typed, handwritt, maintained as electronically stored information, or audio recorded.
All documents drafted by the Experts rel Ictn it subject matter, or claims or defenses, of the Lawsuit.
Copies of any notes made by t e, or provided to the Experts in relation to that Experts' services in this Lawsuit.
All documents prove 1 bfou to the Experts in relation to the services being provided by the Experts in this
All deposi scripts, portions of deposition transcripts, or other statements or written materials vided y you to the Experts in relation to the services being provided by the Experts in th ui .

y documents prepared by the Experts, provided to the Experts, obtained by the Experts, or reviewed by the Experts, whether intended for their use or not, in connection with this Lawsuit which concern the subject matter of the case.¶

All literature and documents that the Experts considered relevant to their assignment in this case and which they considered in the development of their opinions or conclusions concerning the subject matter of the Lawsuit.
All documents prepared by the Experts to illustrate or demonstrate any fact or opinion considered relevant to this Lawsuit and/or to the Experts' assignment, investigation, or opinions.
Without limitation to the time set forth in Instruction No. 2 any articles, e c ) books, papers or other publications prepared by the Experts which facts surrounding the subject matter of this Lawsuit. cts similar to the
Any and all materials considered, consult by the Experts as a basis or predicate for their opinions and conclusions, includ' ,C cia, Al4 b "o imited to, published reports by any private or government agency, textbooks, S 4'c logs y, ta or documents provided by you, or government or industry standards or re ; ' ,.sons. ...e

trative tools upon which the Experts have or plan to rely, in the formulation and ex of their opinions and conclusions concerning the subject matter of this Lawsuit. 17. Any and all models¶

or made in t 11 n years. orts, testimony or affidavits of the Experts for any other matter given

CERTIFICATE OF SERVICE¶

LINK & ROCKENBACH, P.A. 1555 Palm Beach Lakes Boulevard, Suitk 301 West Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601
¶

By: /s/ Scott J. Link¶

Scott J. Link (FBN Kara Berard Rocker ch BN 44903) Angela M. B 80) Primary: Scatt(ibl rtkrocklaw.com Primary: araAlinkrocklaw.com Prim ucla®linIcrocklaw.com Segdh TinaAlinkrocklaw.com Trovalinkrocklaw.com : Tanya®Iinkrocklaw.com dary: Eservice®Iinkrocklaw.com¶

Accⁱ ar Trial Counsel for Plaintiff/Counter-Defendant Jeffity Epstein¶

SERVICE LIST¶

Jack Scarola Searcy, Denny, carola, Barnhart & Shipley, P.A. 2139 Palm Beach•l_akes Boulevard West Palm B-wl; FL 33409 mep@illite0aw.com jsx@sea4law.com scarolateamasearcylaw.com Co-Counseilielendant/Counter-Plaintiff J.¶

Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 njsa$LAppellateLaw.com kbt(4FLAppellateLaw.com Co-Counselciliendant/Counter-Plaintiff J.¶

<p>J. [REDACTED] Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 <a href="mailto:brad@epllc.com">brad@epllc.com</a> <a href="mailto:staff.efile@pathtojustice.com">staff.efile@pathtojustice.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>	<p>Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 <a href="mailto:marc@nuriklaw.com">marc@nuriklaw.com</a> <i>Counsel for Defendant Scott Rothstein</i></p>
<p>Tonja Haddad Coleman 315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, FL 33301 <a href="mailto:tonja@tonjahaddad.com">tonja@tonjahaddad.com</a> <a href="mailto:efiling@tonjahaddad.com">efiling@tonjahaddad.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Fred Haddad Haddad & Navarro, PLLC 1 Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 <a href="mailto:dee@haddadandnavarrolaw.com">dee@haddadandnavarrolaw.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>
<p>W. Chester [REDACTED], Jr. W. Chester [REDACTED], Jr. P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:wcblaw@aol.com">wcblaw@aol.com</a> <a href="mailto:wcblawasst@gmail.com">wcblawasst@gmail.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:jgoldberger@agwpa.com">jgoldberger@agwpa.com</a> <a href="mailto:smahoney@agwpa.com">smahoney@agwpa.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>

NOTA CERTIFICATE¶

EXHIBIT B¶

NOT A CERTIFIED COPY¶

1.340, hereby gives notice of Defendant/Counter-Plaintiff, B Plaintiff7Counter-Defendant, Je Lps ame E pursuant to Florida Rule of Civil Procedure ce of Interrogatories Regarding Experts upon on November 13, 2017.¶

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

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant,¶

v.¶

SCOTT ROTHSTEIN individually, and J. individually,¶

Defendants/Counter-Plaintiff.¶

PLAINTIFF OF INTERROGATORIES TO DEFE J. EDW TICE Cs NTERCLAIM PLAINTIFF RDING EXPERTS E¶

CERTIFICATE OF SERVICE¶

I certify that this Notice been furnished to the attorneys listed on the Service List below on November 13, 2017, through the Court's e-filing portal pursuant to Florida Rule of Judicial Administration 2.516(b)(1) and a copy of the Notice and Interrogatories have been served via e-mail.¶

LINK & ROCKENBACH, P.A.
1555 Palm Beach Lakes Boulevard, Suite 301
West 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@linkrocklaw.com
Secondary: T
Secondary: Troy@linkrocklaw.com
Secondary: Tanya@linkrocklaw.com
Secondary: Eservice@linkrocklaw.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@scarcylaw.com
jsx@scarcylaw.com
scarolateam@scarcylaw.com
Co-Counsel for Defendant/Counter-Plaintiff
J.¶

Nichole J. Segal
Burlington & Rockenbach, P.A.
Courthouse Commons, Suite 350
444 West Railroad Avenue
West Palm Beach, FL 33401
njs@FLAppellateLaw.com
kbt@FLAppellateLaw.com
Co-Counsel for Defendant/Counter-Plaintiff
J.¶

<p>J. [REDACTED] Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 <a href="mailto:brad@epllc.com">brad@epllc.com</a> <a href="mailto:staff.efile@pathtojustice.com">staff.efile@pathtojustice.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>	<p>Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 <a href="mailto:marc@nuriklaw.com">marc@nuriklaw.com</a> <i>Counsel for Defendant Scott Rothstein</i></p>
<p>Tonja Haddad Coleman 315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, FL 33301 <a href="mailto:tonja@tonjahaddad.com">tonja@tonjahaddad.com</a> <a href="mailto:efiling@tonjahaddad.com">efiling@tonjahaddad.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Fred Haddad Haddad & Navarro, PLLC 1 Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 <a href="mailto:dee@haddadandnavarrolaw.com">dee@haddadandnavarrolaw.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>
<p>W. Chester [REDACTED], Jr. W. Chester [REDACTED], Jr. P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:wcblaw@aol.com">wcblaw@aol.com</a> <a href="mailto:wcblawasst@gmail.com">wcblawasst@gmail.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:jgoldberger@agwpa.com">jgoldberger@agwpa.com</a> <a href="mailto:smahoney@agwpa.com">smahoney@agwpa.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>

NOTA CERTIFICATE¶

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

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant,¶

v.¶

SCOTT ROTHSTEIN individually, and J. individually,¶

Defendants/Counter-Plaintiff.¶

PLAINTIFF NTER-DEFENDANT EFF TO DEFENDANT/COUNTERCLAIM RTS¶

Plaintiff/Counter-Defendant, Je Epslih, pursuant to Florida Rule of Civil Procedure 1.340, hereby propounds the fol i rt Interrogatories to Defendant/Counter-Plaintiff, J. a and requ th0t e answer the Interrogatories, in writing and under oath, within the time permitte ERv ule 1.340 or a shorter time as the Court may order pursuant to PlaintiffiCounter- er sen dan s Motion to Shorten the Time to Respond.¶

0 "Communication" or "communications" mean any oral, written or electronic utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including, but not limited to, any documents, correspondence, letters, facsimiles, e-mails, text messages, voice recordings, video recordings, voicemail, instant messages, conversations, dialogues,¶

DEFINITIONS¶

discussions, interviews, conferences, meetings, consultations, agreements, and other understandings or exchanges between or among two or more people.¶

"Document' or "documents" mean all paper documents, graphic or auditory records or representations, tangible items, and electronically stored information, and shall have the broadest possible meaning accorded to it consistent with Florida Rule of Civil Procedure 1.280 (which is incorporated in this definition as if fully set forth), and includes, by w lustration only and not by way of limitation, the following items which are in yoyr.pQ ssion, control, knowledge, or are known to you:

a. All written, paper or printed material of in, cluding, but not limited to: all transmittal slips, memoran o schedules, agendas, notices, books, brochures, calendars, nt files, announcements, meeting / " minutes, records of ? s isIT records of conversations, newsletters, telegrams, sum transcripts, studies, , ts, compilations, facsimile transmissions, pointment books, agreements, contracts, reports, check stubs, invoices, financial statements, bank sta t, receipts, communications, interoffice and intraoffice exchanges, cony nations, inquiries, replies, correspondence, and letters, whether in person, by telephone, in writing, or by means of any other transmittal devices, and all originals, reproductions, copies, changes, amendments, drafts and all non-identical copies of the foregoing;
b. Graphic or auditory records or representations of any kind, including, but not limited to: all images, photographs, charts, drawings, sketches, diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser

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files, virtual machine ?f c , , files, GIS files, s fil, compressed files, disk image files, audio files, video files, , metadata and all originals, reproductions, copies, changes, ents, drafts, and all non-identical copies of the foregoing (de erein as "ESI"; each individual electronically stored document is de fin-' herein as an "ES! document"). 'files, spreadsheet
c. Electronically stored information, electronic, mechanical an electrical records or representations of any kind including, but no to: all electronic communications, text messages, e-majieett messages, computer logs, network logs, Internet history, files, presentation files, database files, d Ac o ptl5tfshing files, source code files, object code files, executabl es, ,a files, script files, project management files, text files, 8 43" cument format files, tabulated data files, webpage files, image files, design

? urposes of the foregoing, documents may be located, stored or archived in any physi n or on any electronic storage media, including, without limitation, any computer, server, appliance, cloud-based service, web-based service, database, internal hard drive, external hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the¶

discs, digital versatile discs, Blu-ray discs, UltraViolet discs, cassette tapes, reel to reel tapes, recordings, sound bites, motion pictures, voice messages, and all originals, reproductions, copies, changes, amendments, drafts and all non-identical copies of the foregoing; and¶

term "draft" means any earlier, preliminary, preparatory, or tentative version of all or part of a document, whether or not such draft was superseded by a later draft and whether or not the draft's terms are the same as or different from the final document's terms. Please note that "Document' and "Documents" as defined herein specifically include "Communication" and "Communications" as defined above.¶

"Native Format" means the file format of ES! in the application in ' such ES! was originally created. ACt
"Person" as used herein means any natural person or ncluding, without limitation, any individual, public company, private company, co ration, limited liability company, joint venture, trust, proprietorship, tenancy, ci ti artnership, business, agency, department, governmental body, bureau, board, co i \s, any other form of public or private entity. With respect to an entity, Person shall S' illseth a ,}subsidiaries and affiliates of the entity, as well as the present and former directors cers, ployees, attorneys, agents and anyone acting on behalf of, at the direction of, or d ontrol of, the entity or its subsidiaries or affiliates.
The terms `5,o or ur" mean J. and his representatives, attorneys, accountants, a d any other person acting under his control or on his behalf.
comprising evide to or "relating to" mean authorizing, concerning, constituting, rig, consisting of, connected with, describing, disclosing, discussing, laining, mentioning, pertaining to, proposing, reflecting, regarding, referring to, directly or indirectly, setting forth, showing, or summarizing.

J. 7. "Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit in and for Palm Beach County, Florida.¶

"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E.W. or any other clients represented by present. J. against Jeffrey Epstein from January 1, 2008 to the
"Tagged Image File Format' or "TIFF' refer to the CCITT Group IV graphic file format for storing bit-mapped images.
"Experts" refers to all expert witnesses disclosed on your Seven 4 Supplemental Witness List dated November 9, 2017, and all other individris expert testimony from at the trial of this matter including, but not limited to, cmard J. Jansen, Robert C. Josefsberg, Charles Lichtman, Spencer Kuvin, Theodore Leopold, Adam Horowitz, Isidro M. =, Earleen Cote and William Berger. ded and tend to elicit
Where appropriate:

a.
b.
c.
d.
e.
f. use of the singular inch the past tense includes the words "and" an the words "all" the word "inc use of the gri thilIo tense; 1, and vice versa; tr" e th conjunctive and disjunctive; can "any and all"; ans "including without limitation"; and eludes the feminine, and vice versa.

Interrozatory N¶

For each Ex that the E a su ase state the subject matter on which the Expert is expected to testify, the date retained, the facts and opinions which the Expert is expected to testify to, and e grounds on which each of the opinions are based.¶

TEFtROGATORIES¶

Inierroliaton. No. 2:¶

For each Expert, please identify any documents, reports, publications, or other written opinions prepared by the Expert relating to the Expert's opinions in this matter.¶

Interroaatory No. 3:¶

For each Expert, please provide:¶

(a) the names of all professio, or a member of, stating his or her education (b)
(c) his or her w associated, add and g tions or societies with which he or she is related 'status with each and inclusive dates of such status; und; and tory, including name of employer, organization with which ss of employer or organization, dates of employment or association ption of work performed in the last twenty-five years.

Inierroliaton. No. 4:¶

For each Expert, please state whether he or she has ever been retained, deposed or testified as an expert witness in any other lawsuit and, if so, for each such lawsuit, give the style of the case, the kind of suit involved, the name of the court, the approximate date of the testimony; and the name and address of the parties and attorneys for whom he or she testified, and the area or field in which he or she was qualified as an expert.¶

A¶

Goes¶

Interrozaton No. 5:¶

For each Expert, please state t er entage of the Expert's earned income derived from serving as an expert witness. Izotir¶

Interrooatory No. 6:¶

For each Expert, please state whether the Expert has ever been retained in the past by you or any of your attorneys as an expert witness, and, if so, the style of the case in which the Expert was retained, and the amount paid or consideration received for the service rendered by the Expert.¶

Interrooaton No. 7:¶

For each Expert, please state w of your attorneys as an attome and the amount paid or conside xpert has ever been retained in the past by you or any so, the style of the case in which the Expert was retained, received for the service rendered by the Expert.¶

Interrogatory No. 8:¶

For each Expert, please provide a complete list of all materials reviewed, consulted, or relied upon in forming his or her opinion, including all depositions, documents, publications, exhibits, plans, drawings, ordinances, statutes, etc.¶

By: _____
Bradley J. Edwards¶

STATE OF FLORIDA )¶

COUNTY OF PALM BEACH )¶

The foregoing instrument was acknowledged before me this ___ day of _____, 2017, by [REDACTED] J. [REDACTED], who is ___ personally known to me or ___ produced _____ as identification who, after being duly sworn, on penalty of perjury, deposes and states that the foregoing Answers to Interrogatories are true to the best of his/her knowledge, information and belief.¶

_____
Notary Public, State of Florida¶

My Commission expires:¶

EXHIBIT C¶

NOT A CERTIFIED COPY¶

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

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant,¶

v.¶

SCOTT ROTHSTEIN individually, and J. individually,¶

Atht i ARPSTEIN'S NOTICE OF PLAINTIFF/COUNTER-DEFENDANT J PRODUCTION FR\ ic¶

Defendants/Counter-Plaintiff.¶

/¶

YOU ARE NOTIFIED that after 10 fro the date of service of this notice, if service is by delivery, or 15 days from the ice, if service is by mail, and if no objection is received from any party, the e, on behalf of Plaintiff/Counter-Defendant Jeffrey Epstein, will issue the attach poenas directed to the following, who are non-parties, to produce the items li ed at e ime and place specified in the Subpoenas:¶

I. Joefsberg urst Orseck, PA ± S.E. Third Avenue, Suite 2700 iami, FL 33131
- 1. Charles Lichtman Berger Singerman 300 East Las Olas Boulevard, Suite 1000 Ft. Lauderdale, FL 33301
- 1. Spencer Kuvin 1800 S. Australian Avenue, Suite 400 West Palm Beach, FL 33409
1. Theodore Leopold Milstein 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410
1. Adam Horowitz 425 N. Andrews Ave., Suite 2 Ft. Lauderdale, FL 33301
1. AH M. Law Firm, P.A. 224 Datum Street, Suite 900 West Palm Beach, FL 33401
1. Earleen Cote Kubicki Draper One East Broward Boulevard, Fort Lauderdale, FL 33301 Suite 1600 c
1. William Berger Weiss, Handler, Comwell, P.A. 2255 Glades Road, Suite 218A ? s, Boca Raton, FL 33431

is)¶

CERTIFICATE OF SERVICE¶

LINK & ROCKENBACH, P.A. 1555 Palm Beach Lakes Boulevard, Suitk 301 West Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601
¶

By: /s/ Scott J. Link¶

Accⁱ ar Trial Counsel for Plaintiff/Counter-Defendant Jeffity Epstein¶

SERVICE LIST¶

<p>J. [REDACTED] Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 <a href="mailto:brad@epllc.com">brad@epllc.com</a> <a href="mailto:staff.efile@pathtojustice.com">staff.efile@pathtojustice.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>	<p>Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 <a href="mailto:marc@nuriklaw.com">marc@nuriklaw.com</a> <i>Counsel for Defendant Scott Rothstein</i></p>
<p>Tonja Haddad Coleman 315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, FL 33301 <a href="mailto:tonja@tonjahaddad.com">tonja@tonjahaddad.com</a> <a href="mailto:efiling@tonjahaddad.com">efiling@tonjahaddad.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Fred Haddad Haddad & Navarro, PLLC 1 Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 <a href="mailto:dee@haddadandnavarrolaw.com">dee@haddadandnavarrolaw.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>
<p>W. Chester [REDACTED], Jr. W. Chester [REDACTED], Jr. P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:wcblaw@aol.com">wcblaw@aol.com</a> <a href="mailto:wcblawasst@gmail.com">wcblawasst@gmail.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:jgoldberger@agwpa.com">jgoldberger@agwpa.com</a> <a href="mailto:smahoney@agwpa.com">smahoney@agwpa.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>

NOTA CERTIFICATE¶

TAB 1¶

NOT A CERTIFIED COPY¶

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

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

PlaintiffiCounter-Defendant,¶

^v .¶

SCOTT ROTHSTEIN individually, and J. individually,¶

Defendants/Counter-Plaintiff.¶

SUBPOENA DUCES TECUM WI EPOSITION¶

(Mail in Sub¶

THE STATE OF FLORIDA TO:¶

TO: Robert C. Josefsberg Podhurst Orseck, P.A. One S.E. Third Avenue, S Miami, FL 33131¶

YOU ARE COMMANCD) to appear at Link & Rockenbach, P.A., 1555 Palm Beach Lakes Boulevard, S •te 3 est Palm Beach, Florida, on 2017, at 9:00 a.m. and to have with you e and place the following:¶

SEE EXHIBIT A¶

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

If you fail to: A¶

4D IIIII \ -¶

(1) appear as specified; or
(2) furnish the records instead of appearing as provided abov C or O %
(3) object to this Subpoena,

you may be in contempt of court. You are subpoenaed p the following attorneys, and unless excused from this Subpoena by the attornp th Court, you shall respond to this Subpoena as directed.¶

Dated: November 20 1 7.¶

+6s¶

*INK & ROCKENBACH, P.A. 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601 [fax]¶

By: Scott J. Link (FBN 602991) Kara Berard Rockenbach (FBN 44903) Angela M. Many (FBN 26680) Primary: Scott@linlcrocklaw.com Primary: Kara@linkrocklaw.com Primary: AngelaWinkrocklaw.com Secondary: Tina@linkrocklaw.com Secondary: Troy@linkrocklaw.com Secondary: Tanya(alinkrocklaw.com Secondary: Eserviceelinlcrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein
¶

[DRAFT]¶

Copies provided to:¶

SERVICE LIST¶

<p>Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 <a href="mailto:mep@searcylaw.com">mep@searcylaw.com</a> <a href="mailto:jsx@searcylaw.com">jsx@searcylaw.com</a> <a href="mailto:scarolateam@searcylaw.com">scarolateam@searcylaw.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> <b>J. [REDACTED]</b></p>	<p>Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 <a href="mailto:njs@FLAppellateLaw.com">njs@FLAppellateLaw.com</a> <a href="mailto:kbt@FLAppellateLaw.com">kbt@FLAppellateLaw.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> <b>J. [REDACTED]</b></p>
<p><b>J. [REDACTED]</b> Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 <a href="mailto:brad@epllc.com">brad@epllc.com</a> <a href="mailto:staff.efile@pathtojustice.com">staff.efile@pathtojustice.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> <b>J. [REDACTED]</b></p>	<p>Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 <a href="mailto:marc@nuriklaw.com">marc@nuriklaw.com</a> <i>Counsel for Defendant Scott Rothstein</i> <b>J. [REDACTED]</b></p>
<p>Tonja Haddad Coleman 315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, FL 33301 <a href="mailto:tonja@tonjahaddad.com">tonja@tonjahaddad.com</a> <a href="mailto:efiling@tonjahaddad.com">efiling@tonjahaddad.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Fred Haddad Haddad & Navarro, PLLC 1 Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 <a href="mailto:dee@haddadandnavarrolaw.com">dee@haddadandnavarrolaw.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>
<p>W. Chester Brewer, Jr. W. Chester Brewer, Jr. P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:wcblaw@aol.com">wcblaw@aol.com</a> <a href="mailto:wcblawasst@gmail.com">wcblawasst@gmail.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:jgoldberger@agwpa.com">jgoldberger@agwpa.com</a> <a href="mailto:smahoney@agwpa.com">smahoney@agwpa.com</a> <i>C</i></p>

If you are a person with a disability who needs any accommodation in order to respond to this Subpoena, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Link & Rockenbach, 1555 Palm Beach Lakes Boulevard, Suite 301, West Palm Beach, Florida 33401 (561) 727-3600, at least seven days before your scheduled appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than seven days; if you are hearing or voice impaired, call 711.¶

NOT A CERTIFIED COPY¶

EXHIBIT A¶

DEFINITIONS¶

I. "Communication" or "communications" mean any oral, written or electronic utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including, but not limited to, any documents, correspondence, letters, facsimiles, e-mails, tex messages, voice recordings, video recordings, voicemail, instant messages, conversatiAlAtidialogues, discussions, interviews, conferences, meetings, consultations, agree and other understandings or exchanges between or among two or more people.¶

"Document" or "documents" mean all paper do hic or auditory records or representations, tangible items, and electronically s Ac?I, ation, and shall have the broadest possible meaning accorded to it consisten "Stip it da Rule of Civil Procedure 1.280 (which is incorporated in this definition as if I t rth), and includes, by way of illustration only and not by way of limitation, the items which are in your possession, control, knowledge, or are known to you:

a. All writs or printed material of any kind, including, but not limited : rtsmittal slips, memoranda, notes, schedules, agendas, notices, brochures, calendars, employment files, announcements, meeting minutes, records of meetings, records of conversations, newsletters, telegrams, summaries, lists, compilations, facsimile transmissions, transcripts, diaries, appointment books, agreements, contracts, reports, studies, checks, check stubs, invoices, financial statements, bank statements, receipts, communications, interoffice and intraoffice exchanges, conversations, inquiries, replies, correspondence, and letters, whether in person, by telephone, in writing, or by means of any other transmittal

+0¶

devices, and all originals, reproductions, copies, changes, amendments, drafts and all non-identical copies of the foregoing;¶

b. Graphic or auditory records or representations of any kind, including, but not limited to: all images, photographs, charts, drawings, sketches, diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser discs, digital versatile discs, Blu-ray discs, UltraViolet dis c, tte tapes, reel to reel tapes, recordings, sound bites, motion pi e messages, and all originals, reproductions, copies, chan ents, drafts and all non-identical copies of the foregoing;
c. Electronically stored information, mechanical and electrical records or representations o including, but not limited to: all electronic communicat messages, e-mails, instant messages, computer logs, ne rk lo, Internet history, document files, spreadsheet files, presen *o, database files, desktop publishing files, source code ct....., files, ob t e files, executable files, data files, script files, project tic, nt files, text files, portable document format files, tabulated data files, virtual machine files, XML files, webpage files, image files, design 0 video files, backup files, metadata and all originals, reproductions, copies, files, GIS files, system files, compressed files, disk image files, audio files, changes, amendments, drafts, and all non-identical copies of the foregoing (defined herein as "ESP'; each individual electronically stored document is defined herein as an "ESI document").

For purposes of the foregoing, documents may be located, stored or archived in any physical location or on any electronic storage media, including, without limitation, any computer, server, appliance, cloud-based service, web-based service, database, internal hard drive, external hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the term "draft" means any earlier, preliminary, preparatory, or tentative version of all r part of a document, whether or not such draft was superseded by a later draft and whether o e draft's terms are the same as or different from the final document's terms. Pleas D t "Document" and "Documents" as defined herein specifically include "Communicat' n ommunications" as defined above.¶

"Native Format" means the file format of Yjnn application in which such ESI was originally created.
"Person" as used herein m I person or any entity, including, without limitation, any individual, public comp priv company, firm, corporation, limited liability company, joint venture, trust, pro, tenancy, association, partnership, business, agency, department, governmental bod board, commission, or any other form of public or private entity. With respect to an r• )erson shall include all subsidiaries and affiliates of the entity, as well as the prese d fo er directors, officers, employees, attorneys, agents and anyone acting on behalf of, • trection of, or under the control of, the entity or its subsidiaries or affiliates.

+he terms "you" or "your" mean Robert C. Josefsberg and include all employees, staff, representatives, attorneys, accountants, agents and any other person acting under his control or on his behalf.¶

"Relates to" or "relating to" mean authorizing, concerning, constituting, comprising, containing, consisting of, connected with, describing, disclosing, discussing,

evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to, directly or indirectly, setting forth, showing, or summarizing.¶

"Lawsuit" means the litigation styled Jeffity Epstein v. Scott Rothstein and Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit in and for Palm Beach County, Florida.
"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E.,, ...., any other clients represented by J. against Jeffrey Epstein from 1 2008 to the present.
"Tagged Image File Format' or "TIFF' refer toC Group 1V graphic file for storing bit-mapped images. tiw
Where appropriate:
informs( your po e to this Subpoena Duces Tecum, you are required to furnish all ments which are, or have been, in your possession, custody, or control, or in on, custody, or control.

a.
b.
c.
d.
e.
f. use of the singular inch the past tense includes the words "and" an the words "all" the word "inc use of the silec,t al, and vice versa; e tense; tr" th conjunctive and disjunctive; can "any and all"; ans "including without limitation"; and ncludes the feminine, and vice versa.

INSTRUCTIONS¶

General Instructions¶

Unless otherwise specifically stated in each request, the relevant time period shall be the period from January 1, 2008 to the present.

ESI Instructions¶

ESI Production Format. ES! shall be produced electronically, either in (1) Native Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files. For each ES! document, all metadata must remain intact and all parent/child document relationships must be maintained. All ESI shall be collected using methods that prevent the spoliation of data.
Production Media. The production of ESI as described he be made on an external hard drive, flash drive, CD or DVD ("Production Media"). c e ction Media shall include a unique identifying label specifying: (a) your identity- the te of the production of ESI; and (c) the Lawsuit name and number.
ESI of Limited Accessibility. If you ltkiig" at any ESI document responsive to this Subpoena is not reasonably accessible: (1 r ntify such ES! document with reasonable particularity; and (2) provide the basis ' .....e eel' g to produce the ES! document, including, for example, any limitations on acc ely costs that might be incurred in accessing and producing the ESI document, which the ESI document i used for storage of the ESI document and all locations in
TI . ES! produced as TIFF image files shall be produced as follows: (1) each pro f IFF image files shall be accompanied by a corresponding load file ("Image Load ) each TIFF image file must contain the same information and same physical representation as the Native Format file from which the TIFF image file was created; (3) each TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be accompanied by an extracted text file containing the extracted text of the Native Format file from which the TIFF image file was created; (5) each extracted text file shall be named to match the endorsed number assigned to the first page of each corresponding TIFF image file; (6) the extracted text files shall be accompanied by a Control List File ("LS7"); (7) each production of TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon ropn, which shall provide the beginning and ending endorsed number of each TIFF image file and the number of pages it includes; and (8) each production of TIFF image files must be accompanied by a data load file ("Data Load File' or "DAT') that contains both the hash value and all available metadata of the Native Format files from which the TIFF i les were created. Further, the following instructions apply to the production of TIFF •

a. Processing Specifications. For each Native Fo a at is converted to TIFF format: (1) all tracked changes shwa med so that all changes are visible; (2) OLE Embedded of be extracted as separate documents; (3) author comme Sic main or be made visible; (4) hidden columns, cells, rows, w nd other hidden data shall remain or be made visible; (5) to otes shall remain or be made visible; and (6) to the extent ign language is produced, processing of such ESI shall be compliant.
b. D nitizati n. If a Native Format file that is converted to TIFF t is more than one page, the unitization of the file and any attachments O unitization cannot be maintained, the original unitization must be or affixed notes must be maintained as it existed when collected. If documented in the Data Load File or otherwise electronically tracked.
- c. Color. If a Native Format file that is converted to TIFF format contains color, the TIFF image file need not be produced in color. However, we reserve the right to make a request for a file to be produced in color.
d. Where TIFF Image File Format is Impracticable. In the event that production of a Native Format file as a TIFF image would be impracticable, you shall produce such file in Native Format with all metadata intact. You shall provide a single page TIFF image placeholder referencing the title of the Native Format file not being produced as a TIFF image.
e. Spreadsheets. All Microsoft Excel files, similar non-Micro readshect files, and graphical compilations of spreadsheet datp i produced in Native Format with all cells, columns, row information unhidden and expanded.
f. Right to Request Native Format 'reserve the right to demand production in Native Format< lc"NSfi, produced by you as a TIFF image file. hects and other

REQUESTED DOCUMENTS¶

1. Your current curriculum vitae. )r
1. My reports prepared b ou r at your direction, relating to your services or participation in this Lawsuit and your is of the Other Lawsuits.
1. Copies of a no ade by you, or provided to you, relating to your opinions or conclusiop9 i this Lawsuit and your analysis of the Other Lawsuits, whether you relied on those
1. Cd1hQi icdtions between you and any person relating to your analysis, opinions or ons in this Lawsuit, as well as your analysis of the Other Lawsuits.
1. My photographs or videos taken by you, or provided to you, that you have observed and reviewed in relation to this Lawsuit.
1. My deposition or hearing transcripts provided to you, or parts of deposition transcripts or any other statements or written materials provided to you, which you have examined or will examine in relation to this Lawsuit.
1. Any diagrams or drawings made by you or provided to you, which you have examined in relation to this Lawsuit.
1. My statements or affidavits taken by you, at your direction, or provided to you for your review concerning any of the facts which are involved in this Lawsuit.
1. Any memoranda or written notice made by you, or provided to you, concerning the subject matter of this Lawsuit.
1. My documents prepared by you, provided to you, or obtained by you or reviewed by you, whether intended for your use or not, and regardless of whether or not ypu actually reviewed or relied on those documents, in connection with this Lawsuit.
1. All literature and/or documents that you considered relevant to yo dht in this Lawsuit and which you considered in the development of your o 0 ' • conclusions concerning the subject matter of the lawsuit.
1. All documents prepared by you to illustrate or demonstrate a fact r opinion considered relevant to this Lawsuit and/or to your assignment, inv tio, r opinions.
1. Copies of any articles, books, papers or other publ ed by you which relate to facts similar to the facts surrounding the subjec this Lawsuit.
1. My and all materials considered, consu by you as a basis or predicate for your opinions and conclusions in tit' u including, but not limited to, published reports by any private or govern age y, textbooks, articles, data or documents furnished by the party engagin ices, or government or industry standards or regulations.
1. My and all models or formulation and exp of this Lawsuit. ve tools upon which you have or plan to rely, in the ur opinions and conclusions concerning the subject matter
1. A conv of auv ret ef agreement or otherianent between you and James guns I for James that sets forth the terms of your is matter, including, but not limited to, the fees for your services in this
1. of all statements, bills, invoices, check stubs or any other document that reflects pa ent or compensation, or a request for payment or compensation, for your services in this Lawsuit or any of the Other Lawsuits.
1. All marketing materials that market or advertise your expert witness services.
1. A list of all other expatizitiaess set-total -formed for James M, or any clients represented by James in the last ten years.
1. A list of other depositions or trials in which you have testified from January 1, 2008 to the present.
1. All expert reports, testimony, videos and affidavits in which you have testified as an expert on any issue in the last ten years.
1. Copies of all publications, expert reports, depositions or other documents in which you have discussed, analyzed or otherwise referenced the subject of the scope of discovery in litigation.
1. Your file regarding your opinions, possible opinions, expert testimony, and/or consultation relating directly or indirectly to the issues in this Lawsuit.
1. All complaints filed against you with the Florida Bar, as well as all co icati ns to you by the Florida Bar and all documents relating to any discip ceedings or investigations conducted by the Florida Bar, or any committee of Bar.

TAB 2¶

NOT A CERTIFIED COPY¶

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

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

PlaintiffiCounter-Defendant,¶

^v .¶

SCOTT ROTHSTEIN individually, and J. individually,¶

Defendants/Counter-Plaintiff.¶

SUBPOENA DUCES TECUM WI EPOSITION¶

(Mail in Sub¶

THE STATE OF FLORIDA TO:¶

TO: Charles Lichtman Berger Singennan 300 East Las Olas Blvd., S Ft. Lauderdale, FL 333¶

YOU ARE COMMANCBI) to appear at Link & Rockenbach, P.A., 1555 Palm Beach Lakes Boulevard, S 'te 30t. est Palm Beach, Florida, on 2017, at 9:30 a.m. and to have with you e and place the following:¶

SEE EXHIBIT A¶

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

If you fail to:¶

10.448k¶

(1) appear as specified; or
(2) furnish the records instead of appearing as provided abov e or s)O .1
(3) object to this Subpoena,

you may be in contempt of court. You are subpoenaed ref the following attorneys, and unless excused from this Subpoena by the attom S, S t Court, you shall respond to this Subpoena as directed.¶

Dated: November 2017.¶

& ROCKENBACH, P.A. 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601 [fax]¶

By: Scott J. Link (FBN 602991) Kara Berard Rockenbach (FBN 44903) Angela M. Many (FBN 26680) Primary: Scott@linlcrocklaw.com Primary: Kara@linkrocklaw.com Primary: AngelaWinIcrocklaw.com Secondary: Tina@linkrocklaw.com Secondary: Troy@linkrocklaw.com Secondary: Tanya(alinkrocklaw.com Secondary: Eserviceelitticrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein¶

[DRAFT]¶

Copies provided to:¶

SERVICE LIST¶

<p>Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 <u>mep@searcylaw.com</u> <u>jsx@searcylaw.com</u> <u>scarolateam@searcylaw.com</u> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>	<p>Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 <u>njs@FLAppellateLaw.com</u> <u>kbt@FLAppellateLaw.com</u> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>
<p>[REDACTED] J. [REDACTED] Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 <u>brad@epllc.com</u> <u>staff.efile@pathtojustice.com</u> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>	<p>Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 <u>marc@nuriklaw.com</u> <i>Counsel for Defendant Scott Rothstein</i> [REDACTED]</p>
<p>Tonja Haddad Coleman 315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, FL 33301 <u>tonja@tonjahaddad.com</u> <u>efiling@tonjahaddad.com</u> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Fred Haddad Haddad & Navarro, PLLC 1 Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 <u>dee@haddadandnavarrolaw.com</u> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>
<p>W. Chester Brewer, Jr. W. Chester Brewer, Jr. P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <u>wcblaw@aol.com</u> <u>wcblawasst@gmail.com</u> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <u>jgoldberger@agwpa.com</u> </p>

NOT A CERTIFIED COPY¶

EXHIBIT A¶

DEFINITIONS¶

"Communication" or "communications" mean any oral, written or electronic utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including, but not limited to, any documents, correspondence, letters, facsimiles, e-mails, tex messages, voice recordings, video recordings, voicemail, instant messages, conversatiAlAlidialogues, discussions, interviews, conferences, meetings, and other understandings or exchanges between or among two or more people. consultations, art
"Document" or "documents" mean all paper do or representations, tangible items, and electronically s ation, and shall have the broadest possible meaning accorded to it consisten li Ida c Rule of Civil Procedure 1.280 (which is incorporated in this definition as if 1 t rth), and includes, by way of illustration only and not by way of limitation, the ow' items which arc in your possession, control, knowledge, or are known to you: hic or auditory records

a. All writt or printed material of any kind, including, but not limited : nsmittal slips, memoranda, notes, schedules, agendas, notices, brochures, calendars, employment files, announcements, meeting minutes, records of meetings, records of conversations, newsletters, telegrams, summaries, lists, compilations, facsimile transmissions, transcripts, diaries, appointment books, agreements, contracts, reports, studies, checks, check stubs, invoices, financial statements, bank statements, receipts, communications, interoffice and intraoffice exchanges, conversations, inquiries, replies, correspondence, and letters, whether in person, by telephone, in writing, or by means of any other transmittal

+0¶

devices, and all originals, reproductions, copies, changes, amendments, drafts and all non-identical copies of the foregoing;¶

b. Graphic or auditory records or representations of any kind, including, but not limited to: all images, photographs, charts, drawings, sketches, diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser discs, digital versatile discs, Blu-ray discs, UltraViolet dis c, tte tapes, reel to reel tapes, recordings, sound bites, motion pi e messages, and all originals, reproductions, copies, than ents, drafts and all non-identical copies of the foregoing;
c. Electronically stored information, mechanical and electrical records or representations o including, but not limited to: all electronic communicat messages, e-mails, instant messages, computer logs, ne rk lo, Internet history, document files, spreadsheet files, presen o, database files, desktop publishing files, source code files, ob e files, executable files, data files, script files, project nt files, text files, portable document format files, tabulated data files, virtual machine files, XML files, webpage files, image files, design 0 video files, backup files, metadata and all originals, reproductions, copies, files, GIS files, system files, compressed files, disk image files, audio files, changes, amendments, drafts, and all non-identical copies of the foregoing (defined herein as "ESP'; each individual electronically stored document is defined herein as an "ESI document").

For purposes of the foregoing, documents may be located, stored or archived in any physical location or on any electronic storage media, including, without limitation, any computer, server, appliance, cloud-based service, web-based service, database, internal hard drive, external hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the term "draft" means any earlier, preliminary, preparatory, or tentative version of all pr part of a document, whether or not such draft was superseded by a later draft and whether e draft's terms are the same as or different from the final document's terms. Pleas "Document" and "Documents" as defined herein specifically include "Communicat' Cn .) ommunications" as defined above.¶

"Native Format" means the file format of 'n p pplication in which such ESI was originally created.
"Person" as used herein m ial person or any entity, including, without limitation, any individual, public comp priv company, firm, corporation, limited liability company, joint venture, trust, pro 1 , tenancy, association, partnership, business, agency, department, governmental body board, commission, or any other form of public or private entity. With respect to an r• Person shall include all subsidiaries and affiliates of the entity, as well as the prese d fo er directors, officers, employees, attorneys, agents and anyone acting on behalf of, erection of, or under the control of, the entity or its subsidiaries or affiliates.

+he terms "you" or "your" mean Charles Lichtman and include all employees, staff, representatives, attorneys, accountants, agents and any other person acting under his control or on his behalf.¶

"Relates to" or "relating to" mean authorizing, concerning, constituting, comprising, containing, consisting of, connected with, describing, disclosing, discussing,

evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to, directly or indirectly, setting forth, showing, or summarizing.¶

"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit in and for Palm Beach County, Florida.
"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E. ,,,...k, . any other clients represented by J. against Jeffrey Epstein from 1, 2008 to the present.
"Tagged Image File Format' or "TIFF' refer toC Group 1V graphic file for storing bit-mapped images. tiw
Where appropriate:
informs( your po e to this Subpoena Duces Tecum, you are required to furnish all ments which are, or have been, in your possession, custody, or control, or in on, custody, or control.

a.
b.
c.
d.
e.
f. use of the singular inch the past tense includes the words "and" an the words "all" the word "inc use of the s e siS,al, and vice versa; ese tense; tr" th conjunctive and disjunctive; can "any and all"; ans "including without limitation"; and ncludes the feminine, and vice versa.

INSTRUCTIONS¶

General Instructions¶

Unless otherwise specifically stated in each request, the relevant time period shall be the period from January 1, 2008 to the present.

ESI Instructions¶

ESI Production Format. ES! shall be produced electronically, either in (1) Native Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files. For each ES! document, all metadata must remain intact and all parent/child document relationships must be maintained. All ES! shall be collected using methods that prevent the spoliation of data.
Production Media. The production of ESI as described he be made on an external hard drive, flash drive, CD or DVD ("Production Media"). c e ction Media shall include a unique identifying label specifying: (a) your identity- the te of the production of ESI; and (c) the Lawsuit name and number.
ESI of Limited Accessibility. If you at any ESI document responsive to this Subpoena is not reasonably accessible: (1 i ntify such ES! document with reasonable particularity; and (2) provide the basis ' .....e eel' g to produce the ES! document, including, for example, any limitations on acc ely costs that might be incurred in accessing and producing the ESI document, which the ESI document used for storage of the ESI document and all locations in
TI . ES! produced as TIFF image files shall be produced as follows: (1) each pro. f IFF image files shall be accompanied by a corresponding load file ("Image Load ) each TIFF image file must contain the same information and same physical representation as the Native Format file from which the TIFF image file was created; (3) each TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be accompanied by an extracted text file containing the extracted text of the Native Format file from which the TIFF image file was created; (5) each extracted text file shall be named to match the endorsed number assigned to the first page of each corresponding TIFF image file; (6) the extracted text files shall be accompanied by a Control List File ("LS7"); (7) each production of TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon ropn, which shall provide the beginning and ending endorsed number of each TIFF image file and the number of pages it includes; and (8) each production of TIFF image files must be accompanied by a data load file ("Data Load File' or "DAT') that contains both the hash value and all available metadata of the Native Format files from which the TIFF i les were created. Further, the following instructions apply to the production of TIFF • :

a. Processing Specifications. For each Native Fo at is converted to TIFF format: (1) all tracked changes sha a med so that all changes are visible; (2) OLE Embedded fit s ) of be extracted as separate
- (3) author comme s I main or be made visible; (4) hidden columns, cells, rows, w nd other hidden data shall remain or be made visible; (5) to otes shall remain or be made visible; and (6) to the extent E3 jl.a, eign language is produced, processing of such ESI shall be
b. D compliant. nitizati n. If a Native Format file that is converted to TIFF t is more than one page, the unitization of the file and any attachments O unitization cannot be maintained, the original unitization must be or affixed notes must be maintained as it existed when collected. If documented in the Data Load File or otherwise electronically tracked.
- c. Color. If a Native Format file that is converted to TIFF format contains color, the TIFF image file need not be produced in color. However, we reserve the right to make a request for a file to be produced in color.
d. Where TIFF Image File Format is Impracticable. In the event that production of a Native Format file as a TIFF image would be impracticable, you shall produce such file in Native Format with all metadata intact. You shall provide a single page TIFF image placeholder referencing the title of the Native Format file not being produced as a TIFF image.
e. Spreadsheets. All Microsoft Excel files, similar non-Micro readshect files, and graphical compilations of spreadsheet datp i produced in Native Format with all cells, columns, row information unhidden and expanded.
f. Right to Request Native Format 'reserve the right to demand production in Native Format< lc"NSfi, produced by you as a TIFF image file. hects and other

REQUESTED DOCUMENTS¶

1. Your current curriculum vitae. )e
1. My reports prepared b u r at your direction, relating to your services or participation in this Lawsuit and your is of the Other Lawsuits.
1. Copies of a no aide by you, or provided to you, relating to your opinions or conclusiopA i this Lawsuit and your analysis of the Other Lawsuits, whether you relied on those
1. tions between you and any person relating to your analysis, opinions or ons in this Lawsuit, as well as your analysis of the Other Lawsuits.
1. My photographs or videos taken by you, or provided to you, that you have observed and reviewed in relation to this Lawsuit.
1. My deposition or hearing transcripts provided to you, or parts of deposition transcripts or any other statements or written materials provided to you, which you have examined or will examine in relation to this Lawsuit.
1. Any diagrams or drawings made by you or provided to you, which you have examined in relation to this Lawsuit.
1. My statements or affidavits taken by you, at your direction, or provided to you for your review concerning any of the facts which are involved in this Lawsuit.
1. Any memoranda or written notice made by you, or provided to you, concerning the subject matter of this Lawsuit.
1. My documents prepared by you, provided to you, or obtained by you or reviewed by you, whether intended for your use or not, and regardless of whether or not ypu actually reviewed or relied on those documents, in connection with this Lawsuit.
1. All literature and/or documents that you considered relevant to yo t in this Lawsuit and which you considered in the development of your o 0 ' • conclusions concerning the subject matter of the lawsuit.
1. All documents prepared by you to illustrate or demonstrate a fact r opinion considered relevant to this Lawsuit and/or to your assignment, inv r opinions.
1. Copies of any articles, books, papers or other publ by you which relate to facts similar to the facts surrounding the subjec this Lawsuit.
1. My and all materials considered, consu by you as a basis or predicate for your opinions and conclusions in fir' u including, but not limited to, published reports by any private or govern age y, textbooks, articles, data or documents furnished by the party engagin ices, or government or industry standards or regulations.
1. My and all models or formulation and exp of this Lawsuit. ve tools upon which you have or plan to rely, in the ur opinions and conclusions concerning the subject matter
1. A conv of auv re eef agreement or otheriment between you and James guns I for James that sets forth the terms of your is matter, including, but not limited to, the fees for your services in this
1. of all statements, bills, invoices, check stubs or any other document that reflects pa ent or compensation, or a request for payment or compensation, for your services in this Lawsuit or any of the Other Lawsuits.
1. All marketing materials that market or advertise your expert witness services.
1. A list of all other expirtSess servlasjaformed for James M, or any clients represented by James in the last ten years.
1. A list of other depositions or trials in which you have testified from January 1, 2008 to the present.
1. All expert reports, testimony, videos and affidavits in which you have testified as an expert on any issue in the last ten years.
1. Copies of all publications, expert reports, depositions or other documents in which you have discussed, analyzed or otherwise referenced the subject of the scope of discovery in litigation.
1. Your file regarding your opinions, possible opinions, expert testimony, and/or consultation relating directly or indirectly to the issues in this Lawsuit.
1. All complaints filed against you with the Florida Bar, as well as all co icati ns to you by the Florida Bar and all documents relating to any discip it • troceedings or investigations conducted by the Florida Bar, or any committee of .! " Bar.

C¶

iS 4/) 9¶

?S'¶

r¶

C¶

—¶

r ic S II PIIIr¶

'....)¶

TAB3¶

NOT A CERTIFIED COPY¶

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

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant,¶

^v .¶

SCOTT ROTHSTEIN individually, and J. individually,¶

Defendants/Counter-Plaintiff.¶

/¶

A Cos¶

SUBPOENA DUCES TECUM WI EPOSITION¶

(Mail in Sub¶

THE STATE OF FLORIDA TO:¶

TO: Spencer Kuvin 1800 S. Australian Ave., Suit 44L r West Palm Beach, FL 334 L c )¶

YOU ARE CO EDj appear at Link & Rockenbach, P.A., 1555 Palm Beach Lakes Boulevard, Suite 3 esstt Palm Beach, Florida, on 2017, at 10:00 a.m. and to have with you at kh time v afid place the following:¶

0 ms will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this Subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this Subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the conics to the attorney whose name appears on this Subpoena and thereby eliminate your appearance at the¶

SEE EXHIBIT A¶

time and place specified above. You have the right to object to the production pursuant to this Subpoena at any time before production by giving written notice to the attorney whose name appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.¶

If you fail to:¶

(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this Subpoena,

you may be in contempt of court. You are subpoenaed to apt • ollowing attorneys, and unless excused from this Subpoena by the attorneys o Subpoena as directed. you shall respond to this¶

Dated: November_, 2017.¶

Copies provided to:¶

/4 \¶

( LS€ & ROCKENBACH, P.A. 5 Palm Beach Lakes Boulevard, Suite 301 est Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601 [fax]¶

By. Scott J. Link (FBN 602991) Kara Berard Rockenbach (FBN 44903) Angela M. Many (FBN 26680) Primary: Scott®Iinkrocklaw.com Primary: Kara(Minkrocklaw.com Primary: Angela@linkrocklaw.com Secondary: Tina®Iinkrocklaw.com Secondary: Trov(alinkrocklaw.com Secondary: Tanya@linkrocklaw.com Secondary: Eservice@linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein¶

[DRAFT]¶

SERVICE LIST¶

<p>Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 <a href="mailto:mep@searcylaw.com">mep@searcylaw.com</a> <a href="mailto:jsx@searcylaw.com">jsx@searcylaw.com</a> <a href="mailto:scarolateam@searcylaw.com">scarolateam@searcylaw.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> <span style="background-color: black; color: black;">[REDACTED]</span> J. [REDACTED]</p>	<p>Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 <a href="mailto:njs@FLAppellateLaw.com">njs@FLAppellateLaw.com</a> <a href="mailto:kbt@FLAppellateLaw.com">kbt@FLAppellateLaw.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> <span style="background-color: black; color: black;">[REDACTED]</span> J. [REDACTED]</p>
<p><span style="background-color: black; color: black;">[REDACTED]</span> J. [REDACTED] Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 <a href="mailto:brad@epllc.com">brad@epllc.com</a> <a href="mailto:staff.efile@pathtojustice.com">staff.efile@pathtojustice.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> <span style="background-color: black; color: black;">[REDACTED]</span> J. [REDACTED]</p>	<p>Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 <a href="mailto:marc@nuriklaw.com">marc@nuriklaw.com</a> <i>Counsel for Defendant Scott Rothstein</i> <span style="background-color: black; color: black;">[REDACTED]</span></p>
<p>Tonja Haddad Coleman 315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, FL 33301 <a href="mailto:tonja@tonjahaddad.com">tonja@tonjahaddad.com</a> <a href="mailto:efiling@tonjahaddad.com">efiling@tonjahaddad.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Fred Haddad Haddad & Navarro, PLLC 1 Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 <a href="mailto:dec@haddadandnavarrolaw.com">dec@haddadandnavarrolaw.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>
<p>W. Chester [REDACTED], Jr. W. Chester [REDACTED], Jr. P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:wcblaw@aol.com">wcblaw@aol.com</a> <a href="mailto:wcblawasst@gmail.com">wcblawasst@gmail.com</a> <i>Co-Counsel for Plaintiff/Cou</i></p>

4s)¶

EXHIBIT A¶

DEFINITIONS¶

I. "Communication" or "communications" mean any oral, written or electronic utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including, but not limited to, any documents, correspondence, letters, facsimiles, e-mails, tex messages, voice recordings, video recordings, voicemail, instant messages, conversatiAlAlidialogues, discussions, interviews, conferences, meetings, consultations, a and other understandings or exchanges between or among two or more people.¶

"Document" or "documents" mean all paper do ts, phic or auditory records broadest possible meaning accorded to it consisten or representations, tangible items, and electronically s Ac? i nation, and shall have the lIda Rule of Civil Procedure 1.280 (which is incorporated in this definition as if IN t rth), and includes, by way of illustration only and not by way of limitation, the ow' items which arc in your possession, control, knowledge, or are known to you:

a. All writt or printed material of any kind, including, but not limited : nsmittal slips, memoranda, notes, schedules, agendas, notices, brochures, calendars, employment files, announcements, meeting minutes, records of meetings, records of conversations, newsletters, telegrams, summaries, lists, compilations, facsimile transmissions, transcripts, diaries, appointment books, agreements, contracts, reports, studies, checks, check stubs, invoices, financial statements, bank statements, receipts, communications, interoffice and intraoffice exchanges, conversations, inquiries, replies, correspondence, and letters, whether in person, by telephone, in writing, or by means of any other transmittal

+0¶

devices, and all originals, reproductions, copies, changes, amendments, drafts and all non-identical copies of the foregoing;¶

b. Graphic or auditory records or representations of any kind, including, but not limited to: all images, photographs, charts, drawings, sketches, diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser discs, digital versatile discs, Blu-ray discs, UltraViolet discs tte tapes, reel to reel tapes, recordings, sound bites, motion pi e messages, and all originals, reproductions, copies, chan ents, drafts and all non-identical copies of the foregoing;
c. Electronically stored information, mechanical and electrical records or representations o including, but not limited to: all electronic communicat messages, e-mails, instant messages, computer logs, ne rk lo, Internet history, document files, spreadsheet files, presen o, database files, desktop publishing files, source code files, ob e files, executable files, data files, script files, project nt files, text files, portable document format files, tabulated data files, virtual machine files, XML files, webpage files, image files, design 0 video files, backup files, metadata and all originals, reproductions, copies, files, GIS files, system files, compressed files, disk image files, audio files, changes, amendments, drafts, and all non-identical copies of the foregoing (defined herein as "ESP'; each individual electronically stored document is defined herein as an "ESI document").

For purposes of the foregoing, documents may be located, stored or archived in any physical location or on any electronic storage media, including, without limitation, any computer, server, appliance, cloud-based service, web-based service, database, internal hard drive, external hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the term "draft" means any earlier, preliminary, preparatory, or tentative version of all pr part of a document, whether or not such draft was superseded by a later draft and whether o> e draft's terms are the same as or different from the final document's terms. Pleas "Document" and "Documents" as defined herein specifically include "Comm unicat C' n .)communications' as defined above.¶

"Native Format" means the file format of 'n p pplication in which such ESI was originally created.
"Person" as used herein m ial person or any entity, including, without limitation, any individual, public comp priv company, firm, corporation, limited liability company, joint venture, trust, pro 1 , tenancy, association, partnership, business, agency, department, governmental body board, commission, or any other form of public or private entity. With respect to an rP• erson shall include all subsidiaries and affiliates of the entity, as well as the preser d fo er directors, officers, employees, attorneys, agents and anyone acting on behalf of, •trection of, or under the control of, the entity or its subsidiaries or affiliates.

+he terms "you" or `your" mean Spencer Kuvin and include all employees, staff, representatives, attorneys, accountants, agents and any other person acting under his control or on his behalf.¶

"Relates to" or "relating to" mean authorizing, concerning, constituting, comprising, containing, consisting of, connected with, describing, disclosing, discussing,

evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to, directly or indirectly, setting forth, showing, or summarizing.¶

"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit in and for Palm Beach County, Florida.
"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E. ,,....., . any other clients represented by J. against Jeffrey Epstein from 7l1, 2008 to the present.
"Tagged Image File Forma(' or "TIFF' refer toC Group IV graphic file for storing bit-mapped images. tiw
Where appropriate:
informs( your po e to this Subpoena Duces Tecum, you are required to furnish all ments which are, or have been, in your possession, custody, or control, or in on, custody, or control.

a.
b.
c.
d.
e.
f. use of the singular inch the past tense includes the words "and" an the words "all" the word "inc use of the o rsic ,t a1, and vice versa; e tense; tr" th conjunctive and disjunctive; can "any and all"; ans "including without limitation"; and ncludes the feminine, and vice versa.

INSTRUCTIONS¶

General Instructions¶

Unless otherwise specifically stated in each request, the relevant time period shall be the period from January 1, 2008 to the present.

ESI Instructions¶

ESI Production Format. ES! shall be produced electronically, either in (1) Native Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files. For each ES! document, all metadata must remain intact and all parent/child document relationships must be maintained. All ES! shall be collected using methods that prevent the spoliation of data.
Production Media. The production of ESI as described he be made on an external hard drive, flash drive, CD or DVD ("Production Media"). c e ction Media shall include a unique identifying label specifying: (a) your identity- the te of the production of ESI; and (c) the Lawsuit name and number.
ESI of Limited Accessibility. If you at any ESI document responsive to this Subpoena is not reasonably accessible: (1 i ntify such ES! document with reasonable particularity; and (2) provide the basis ' .....e eel' g to produce the ESI document, including, for example, any limitations on acc ely costs that might be incurred in accessing and producing the ESI document, which the ESI document i used for storage of the ESI document and all locations in
TI . ES! produced as TIFF image files shall be produced as follows: (1) each pro f IFF image files shall be accompanied by a corresponding load file ("Image Load ) each TIFF image file must contain the same information and same physical representation as the Native Format file from which the TIFF image file was created; (3) each TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be accompanied by an extracted text file containing the extracted text of the Native Format file from which the TIFF image file was created; (5) each extracted text file shall be named to match the endorsed number assigned to the first page of each corresponding TIFF image file; (6) the extracted text files shall be accompanied by a Control List File ("LS7"); (7) each production of TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon ("OPT' , which shall provide the beginning and ending endorsed number of each TIFF image file and the number of pages it includes; and (8) each production of TIFF image files must be accompanied by a data load file ("Data Load File" or "DA7") that contains both the hash value and all available metadata of the Native Format files from which the TIFF i les were created. Further, the following instructions apply to the production of TIFF • les:

a. Processing Specifications. For each Native Fo at is converted to TIFF format: (1) all tracked changes sha a med so that all changes are visible; (2) OLE Embedded fit s ) of be extracted as separate
- (3) author comme s I main or be made visible; (4) hidden columns, cells, rows, w nd other hidden data shall remain or be made visible; (5) to otes shall remain or be made visible; and (6) to the extent i a eign language is produced, processing of such ESI shall be compliant.
b. D nitizati n. If a Native Format file that is converted to TIFF t is more than one page, the unitization of the file and any attachments 0 unitization cannot be maintained, the original unitization must be or affixed notes must be maintained as it existed when collected. If documented in the Data Load File or otherwise electronically tracked.
- c. Color. If a Native Format file that is converted to TIFF format contains color, the TIFF image file need not be produced in color. However, we reserve the right to make a request for a file to be produced in color.
d. Where TIFF Image File Format is Impracticable. In the event that production of a Native Format file as a TIFF image would be impracticable, you shall produce such file in Native Format with all metadata intact. You shall provide a single page TIFF image placeholder referencing the title of the Native Format file not being produced as a TIFF image.
e. Spreadsheets. All Microsoft Excel files, similar non-Micro readsheet files, and graphical compilations of spreadsheet datp i produced in Native Format with all cells, columns, row information unhidden and expanded.
f. Right to Request Native Format eserve the right to demand production in Native Format< lc"NSfi, produced by you as a TIFF image file. hects and other

REQUESTED DOCUMENTS¶

1. Your current curriculum vitae. )r
1. My reports prepared b u r at your direction, relating to your services or participation in this Lawsuit and your is of the Other Lawsuits.
1. Copies of a no a& by you, or provided to you, relating to your opinions or conclusiopA i this Lawsuit and your analysis of the Other Lawsuits, whether you relied on those
1. tions between you and any person relating to your analysis, opinions or ons in this Lawsuit, as well as your analysis of the Other Lawsuits.
1. My photographs or videos taken by you, or provided to you, that you have observed and reviewed in relation to this Lawsuit.
1. My deposition or hearing transcripts provided to you, or parts of deposition transcripts or any other statements or written materials provided to you, which you have examined or will examine in relation to this Lawsuit.
1. Any diagrams or drawings made by you or provided to you, which you have examined in relation to this Lawsuit.
1. My statements or affidavits taken by you, at your direction, or provided to you for your review concerning any of the facts which are involved in this Lawsuit.
1. Any memoranda or written notice made by you, or provided to you, concerning the subject matter of this Lawsuit.
1. My documents prepared by you, provided to you, or obtained by you or reviewed by you, whether intended for your use or not, and regardless of whether or not ypu actually reviewed or relied on those documents, in connection with this Lawsuit.
1. All literature and/or documents that you considered relevant to you mdht in this Lawsuit and which you considered in the development of your o 0 • • conclusions concerning the subject matter of the lawsuit.
1. All documents prepared by you to illustrate or demonstrate a fact r opinion considered relevant to this Lawsuit and/or to your assignment, inv tio r opinions.
1. Copies of any articles, books, papers or other publ by you which relate to facts similar to the facts surrounding the subjec this Lawsuit.
1. My and all materials considered, consu by you as a basis or predicate for your opinions and conclusions in th' u including, but not limited to, published reports by any private or govern age y, textbooks, articles, data or documents finished by the party engagin ices, or government or industry standards or regulations.
1. My and all models or formulation and exp of this Lawsuit. ve tools upon which you have or plan to rely, in the ur opinions and conclusions concerning the subject matter
1. A co of apy rem e agreement or otheriment between you and James I for James that sets forth the terms of your is matter, including, but not limited to, the fees for your services in this
1. of all statements, bills, invoices, check stubs or any other document that reflects pa ent or compensation, or a request for payment or compensation, for your services in this Lawsuit or any of the Other Lawsuits.
1. All marketing materials that market or advertise your expert witness services.
1. A list of all other expirSess serviiasjaformed for James M, or any clients represented by James in the last ten years.
1. A list of other depositions or trials in which you have testified from January 1, 2008 to the present.
1. All expert reports, testimony, videos and affidavits in which you have testified as an expert on any issue in the last ten years.
1. Copies of all publications, expert reports, depositions or other documents in which you have discussed, analyzed or otherwise referenced the subject of the scope of discovery in litigation.
1. Your file regarding your opinions, possible opinions, expert testimony, and/or consultation relating directly or indirectly to the issues in this Lawsuit.
1. All complaints filed against you with the Florida Bar, as well as all co icati ns to you by the Florida Bar and all documents relating to any discip ceedings or investigations conducted by the Florida Bar, or any committee of a Fl Bar.

TAB 4¶

NOT A CERTIFIED COPY¶

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

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant,¶

^v .¶

SCOTT ROTHSTEIN individually, and J. individually,¶

Defendants/Counter-Plaintiff.¶

SUBPOENA DUCES TECUM WI EPOSITION¶

(Mail in Sub¶

THE STATE OF FLORIDA TO:¶

TO: Theodore Leopold Milstein 2925 PGA Boulevard, Sui Palm Beach Gardens, F¶

YOU ARE COMM to appear at Link & Rockenbach, P.A., 1555 Palm Beach Lakes Boulevard, S le 30 est Palm Beach, Florida, on 2017, at 10:30 a.m. and to have with youju t e and place the following:¶

SEE EXHIBIT A¶

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

If you fail to:¶

10.448k¶

(1) appear as specified; or
(2) furnish the records instead of appearing as provided abov e or s)O .1
(3) object to this Subpoena,

you may be in contempt of court. You are subpoenaed ref the following attorneys, and unless excused from this Subpoena by the attom S, S t Court, you shall respond to this Subpoena as directed.¶

Dated: November 2017.¶

& ROCKENBACH, P.A. 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601 [fax]¶

[DRAFT]¶

Copies provided to:¶

SERVICE LIST¶

<p>Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 <u>mep@searcylaw.com</u> <u>jsx@searcylaw.com</u> <u>scarolateam@searcylaw.com</u> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>	<p>Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 <u>njs@FLAppellateLaw.com</u> <u>kbt@FLAppellateLaw.com</u> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>
<p>[REDACTED] J. [REDACTED] Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 <u>brad@epllc.com</u> <u>staff.efile@pathtojustice.com</u> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>	<p>Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 <u>marc@nuriklaw.com</u> <i>Counsel for Defendant Scott Rothstein</i> [REDACTED]</p>
<p>Tonja Haddad Coleman 315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, FL 33301 <u>tonja@tonjahaddad.com</u> <u>efiling@tonjahaddad.com</u> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Fred Haddad Haddad & Navarro, PLLC 1 Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 <u>dee@haddadandnavarrolaw.com</u> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>
<p>W. Chester Brewer, Jr. W. Chester Brewer, Jr. P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <u>wcblaw@aol.com</u> <u>wcblawasst@gmail.com</u> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <u>jgoldberger@agwpa.com</u> </p>

NOT A CERTIFIED COPY¶

EXHIBIT A¶

DEFINITIONS¶

I. "Communication" or "communications" mean any oral, written or electronic utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including, but not limited to, any documents, correspondence, letters, facsimiles, e-mails, tex messages, voice recordings, video recordings, voicemail, instant messages, conversatiAlAlidialogues, discussions, interviews, conferences, meetings, consultations, a and other understandings or exchanges between or among two or more people.¶

"Document" or "documents" mean all paper do ts, phic or auditory records broadest possible meaning accorded to it consisten or representations, tangible items, and electronically s Ac? i nation, and shall have the lIda Rule of Civil Procedure 1.280 (which is incorporated in this definition as if IN t rth), and includes, by way of illustration only and not by way of limitation, the ow' items which arc in your possession, control, knowledge, or are known to you:

a. All writt or printed material of any kind, including, but not limited : nsmittal slips, memoranda, notes, schedules, agendas, notices, brochures, calendars, employment files, announcements, meeting minutes, records of meetings, records of conversations, newsletters, telegrams, summaries, lists, compilations, facsimile transmissions, transcripts, diaries, appointment books, agreements, contracts, reports, studies, checks, check stubs, invoices, financial statements, bank statements, receipts, communications, interoffice and intraoffice exchanges, conversations, inquiries, replies, correspondence, and letters, whether in person, by telephone, in writing, or by means of any other transmittal

+0¶

devices, and all originals, reproductions, copies, changes, amendments, drafts and all non-identical copies of the foregoing;¶

b. Graphic or auditory records or representations of any kind, including, but not limited to: all images, photographs, charts, drawings, sketches, diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser discs, digital versatile discs, Blu-ray discs, UltraViolet discs tte tapes, reel to reel tapes, recordings, sound bites, motion pi e messages, and all originals, reproductions, copies, chan ents, drafts and all non-identical copies of the foregoing;
c. Electronically stored information, mechanical and electrical records or representations o including, but not limited to: all electronic communicat messages, e-mails, instant messages, computer logs, ne rk lo, Internet history, document files, spreadsheet files, presen o, database files, desktop publishing files, source code files, ob e files, executable files, data files, script files, project nt files, text files, portable document format files, tabulated data files, virtual machine files, XML files, webpage files, image files, design 0 video files, backup files, metadata and all originals, reproductions, copies, files, GIS files, system files, compressed files, disk image files, audio files, changes, amendments, drafts, and all non-identical copies of the foregoing (defined herein as "ESP'; each individual electronically stored document is defined herein as an "ESI document").

For purposes of the foregoing, documents may be located, stored or archived in any physical location or on any electronic storage media, including, without limitation, any computer, server, appliance, cloud-based service, web-based service, database, internal hard drive, external hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the term "draft" means any earlier, preliminary, preparatory, or tentative version of all pr part of a document, whether or not such draft was superseded by a later draft and whether o> e draft's terms are the same as or different from the final document's terms. Pleas "Document" and "Documents" as defined herein specifically include "Comm unicat C' n .) ommunications" as defined above.¶

"Native Format" means the file format of 'n p pplication in which such ESI was originally created.
"Person" as used herein m ial person or any entity, including, without limitation, any individual, public comp priv company, firm, corporation, limited liability company, joint venture, trust, pro, tenancy, association, partnership, business, agency, department, governmental body board, commission, or any other form of public or private entity. With respect to an rP• erson shall include all subsidiaries and affiliates of the entity, as well as the preser d fo er directors, officers, employees, attorneys, agents and anyone acting on behalf of, •trection of, or under the control of, the entity or its subsidiaries or affiliates.

A\a\The terms `you" or "your" mean Theodore Leopold and include all employees, staff, representatives, attorneys, accountants, agents and any other person acting under his control or on his behalf.¶

"Relates to" or "relating to" mean authorizing, concerning, constituting, comprising, containing, consisting of, connected with, describing, disclosing, discussing,

evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to, directly or indirectly, setting forth, showing, or summarizing.¶

"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit in and for Palm Beach County, Florida.
"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E. ,,....., . any other clients represented by J. against Jeffrey Epstein from 7l1, 2008 to the present.
"Tagged Image File Forma(' or "TIFF' refer toC Group IV graphic file for storing bit-mapped images. tiw
Where appropriate:
informs( your po e to this Subpoena Duces Tecum, you are required to furnish all ments which are, or have been, in your possession, custody, or control, or in on, custody, or control.

a.
b.
c.
d.
e.
f. use of the singular inch the past tense includes the words "and" an the words "all" the word "inc use of the o rsic ,t a1, and vice versa; e tense; tr" th conjunctive and disjunctive; can "any and all"; ans "including without limitation"; and ncludes the feminine, and vice versa.

INSTRUCTIONS¶

General Instructions¶

Unless otherwise specifically stated in each request, the relevant time period shall be the period from January 1, 2008 to the present.

ESI Instructions¶

ESI Production Format. ES! shall be produced electronically, either in (1) Native Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files. For each ES! document, all metadata must remain intact and all parent/child document relationships must be maintained. All ES! shall be collected using methods that prevent the spoliation of data.
Production Media. The production of ESI as described he be made on an external hard drive, flash drive, CD or DVD ("Production Media"). c e ction Media shall include a unique identifying label specifying: (a) your identity- the te of the production of ESI; and (c) the Lawsuit name and number.
ESI of Limited Accessibility. If you at any ESI document responsive to this Subpoena is not reasonably accessible: (1 i ntify such ES! document with reasonable particularity; and (2) provide the basis ' .....e eel' g to produce the ESI document, including, for example, any limitations on acc ely costs that might be incurred in accessing and producing the ESI document, which the ESI document i used for storage of the ESI document and all locations in
TI . ES! produced as TIFF image files shall be produced as follows: (1) each pro f IFF image files shall be accompanied by a corresponding load file ("Image Load ) each TIFF image file must contain the same information and same physical representation as the Native Format file from which the TIFF image file was created; (3) each TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be accompanied by an extracted text file containing the extracted text of the Native Format file from which the TIFF image file was created; (5) each extracted text file shall be named to match the endorsed number assigned to the first page of each corresponding TIFF image file; (6) the extracted text files shall be accompanied by a Control List File ("LS7"); (7) each production of TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon ("OPT' , which shall provide the beginning and ending endorsed number of each TIFF image file and the number of pages it includes; and (8) each production of TIFF image files must be accompanied by a data load file ("Data Load File" or "DA7") that contains both the hash value and all available metadata of the Native Format files from which the TIFF i les were created. Further, the following instructions apply to the production of TIFF • les:

a. Processing Specifications. For each Native Fo at is converted to TIFF format: (1) all tracked changes sha a med so that all changes are visible; (2) OLE Embedded fit s ) of be extracted as separate
- (3) author comme s I main or be made visible; (4) hidden columns, cells, rows, w nd other hidden data shall remain or be made visible; (5) to otes shall remain or be made visible; and (6) to the extent i a eign language is produced, processing of such ESI shall be compliant.
b. D nitizati n. If a Native Format file that is converted to TIFF t is more than one page, the unitization of the file and any attachments 0 unitization cannot be maintained, the original unitization must be or affixed notes must be maintained as it existed when collected. If documented in the Data Load File or otherwise electronically tracked.
- c. Color. If a Native Format file that is converted to TIFF format contains color, the TIFF image file need not be produced in color. However, we reserve the right to make a request for a file to be produced in color.
d. Where TIFF Image File Format is Impracticable. In the event that production of a Native Format file as a TIFF image would be impracticable, you shall produce such file in Native Format with all metadata intact. You shall provide a single page TIFF image placeholder referencing the title of the Native Format file not being produced as a TIFF image.
e. Spreadsheets. All Microsoft Excel files, similar non-Micro readsheet files, and graphical compilations of spreadsheet datp i produced in Native Format with all cells, columns, row information unhidden and expanded.
f. Right to Request Native Format eserve the right to demand production in Native Format< lc"NSfi, produced by you as a TIFF image file. hects and other

REQUESTED DOCUMENTS¶

1. Your current curriculum vitae. )r
1. My reports prepared b u r at your direction, relating to your services or participation in this Lawsuit and your is of the Other Lawsuits.
1. Copies of a no a& by you, or provided to you, relating to your opinions or conclusiopA i this Lawsuit and your analysis of the Other Lawsuits, whether you relied on those
1. tions between you and any person relating to your analysis, opinions or ons in this Lawsuit, as well as your analysis of the Other Lawsuits.
1. My photographs or videos taken by you, or provided to you, that you have observed and reviewed in relation to this Lawsuit.
1. My deposition or hearing transcripts provided to you, or parts of deposition transcripts or any other statements or written materials provided to you, which you have examined or will examine in relation to this Lawsuit.
1. Any diagrams or drawings made by you or provided to you, which you have examined in relation to this Lawsuit.
1. My statements or affidavits taken by you, at your direction, or provided to you for your review concerning any of the facts which are involved in this Lawsuit.
1. Any memoranda or written notice made by you, or provided to you, concerning the subject matter of this Lawsuit.
1. My documents prepared by you, provided to you, or obtained by you or reviewed by you, whether intended for your use or not, and regardless of whether or not ypu actually reviewed or relied on those documents, in connection with this Lawsuit.
1. All literature and/or documents that you considered relevant to you mdht in this Lawsuit and which you considered in the development of your o 0 • • conclusions concerning the subject matter of the lawsuit.
1. All documents prepared by you to illustrate or demonstrate a fact r opinion considered relevant to this Lawsuit and/or to your assignment, inv tio r opinions.
1. Copies of any articles, books, papers or other publ by you which relate to facts similar to the facts surrounding the subjec this Lawsuit.
1. My and all materials considered, consu by you as a basis or predicate for your opinions and conclusions in th' u including, but not limited to, published reports by any private or govern age y, textbooks, articles, data or documents finished by the party engagin ices, or government or industry standards or regulations.
1. My and all models or formulation and exp of this Lawsuit. ve tools upon which you have or plan to rely, in the ur opinions and conclusions concerning the subject matter
1. A co of apy rem e agreement or otheriment between you and James I for James that sets forth the terms of your is matter, including, but not limited to, the fees for your services in this
1. of all statements, bills, invoices, check stubs or any other document that reflects pa ent or compensation, or a request for payment or compensation, for your services in this Lawsuit or any of the Other Lawsuits.
1. All marketing materials that market or advertise your expert witness services.
1. A list of all other expirSess serviiasjaformed for James M, or any clients represented by James in the last ten years.
1. A list of other depositions or trials in which you have testified from January 1, 2008 to the present.
1. All expert reports, testimony, videos and affidavits in which you have testified as an expert on any issue in the last ten years.
1. Copies of all publications, expert reports, depositions or other documents in which you have discussed, analyzed or otherwise referenced the subject of the scope of discovery in litigation.
1. Your file regarding your opinions, possible opinions, expert testimony, and/or consultation relating directly or indirectly to the issues in this Lawsuit.
1. All complaints filed against you with the Florida Bar, as well as all co icati ns to you by the Florida Bar and all documents relating to any discip ceedings or investigations conducted by the Florida Bar, or any committee of a Fl Bar.

TAB5¶

NOT A CERTIFIED COPY¶

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

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

PlaintiffiCounter-Defendant,¶

^v .¶

SCOTT ROTHSTEIN individually, and J. individually,¶

Defendants/Counter-Plaintiff.¶

SUBPOENA DUCES TECUM WI EPOSITION¶

(Mail in Sub¶

THE STATE OF FLORIDA TO:¶

TO: Adam Horowitz 425 N. Andrews Ave., Suite SLINK Ft. Lauderdale, FL 33301¶

YOU ARE CO EDj appear at Link & Rockenbach, P.A., 1555 Palm Beach Lakes Boulevard, Suite 3 esstt Palm Beach, Florida, on 2017, at 11:00 a.m. and to have with you at kit time / abd place the following:¶

SEE EXHIBIT A¶

If you fail to:¶

(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this Subpoena,

you may be in contempt of court. You are subpoenaed to ap ollowing attorneys, and unless excused from this Subpoena by the attorneys o Subpoena as directed. you shall respond to this¶

Dated: November_, 2017.¶

/4 \¶

( LS€ & ROCKENBACH, P.A. 5 Palm Beach Lakes Boulevard, Suite 301 est Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601 [fax]¶

By. Scott J. Link (FBN 602991) Kara Berard Rockenbach (FBN 44903) Angela M. Many (FBN 26680) Primary: Scott®Iinkrocklaw.com Primary: Kara(Minkrocklaw.com Primary: Angela@linkrocklaw.com Secondary: Tina@linkrocklaw.com Secondary: Trovalinkrocklaw.com Secondary: Tanya@linkrocklaw.com Secondary: Eservice@linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein¶

[DRAFT]¶

Copies provided to:¶

SERVICE LIST¶

<p>Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 <u>mep@searcylaw.com</u> <u>jsx@searcylaw.com</u> <u>scarolateam@searcylaw.com</u> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>	<p>Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 <u>njs@FLAppellateLaw.com</u> <u>kbt@FLAppellateLaw.com</u> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>
<p>[REDACTED] J. [REDACTED] Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 <u>brad@epllc.com</u> <u>staff.efile@pathtojustice.com</u> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>	<p>Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 <u>marc@nuriklaw.com</u> <i>Counsel for Defendant Scott Rothstein</i> [REDACTED]</p>
<p>Tonja Haddad Coleman 315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, FL 33301 <u>tonja@tonjahaddad.com</u> <u>efiling@tonjahaddad.com</u> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Fred Haddad Haddad & Navarro, PLLC 1 Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 <u>dee@haddadandnavarrolaw.com</u> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>
<p>W. Chester Brewer, Jr. W. Chester Brewer, Jr. P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <u>wcblaw@aol.com</u> <u>wcblawasst@gmail.com</u> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <u>jgoldberger@agwpa.com</u> </p>

NOT A CERTIFIED COPY¶

EXHIBIT A¶

DEFINITIONS¶

I. "Communication" or "communications" mean any oral, written or electronic utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including, but not limited to, any documents, correspondence, letters, facsimiles, e-mails, tex messages, voice recordings, video recordings, voicemail, instant messages, conversatiAlAlidialogues, discussions, interviews, conferences, meetings, consultations, a and other understandings or exchanges between or among two or more people.¶

"Document" or "documents" mean all paper do ts, phic or auditory records broadest possible meaning accorded to it consisten or representations, tangible items, and electronically s Ac? i nation, and shall have the lIda Rule of Civil Procedure 1.280 (which is incorporated in this definition as if IN t rth), and includes, by way of illustration only and not by way of limitation, the ow' items which arc in your possession, control, knowledge, or are known to you:

a. All writt or printed material of any kind, including, but not limited : nsmittal slips, memoranda, notes, schedules, agendas, notices, brochures, calendars, employment files, announcements, meeting minutes, records of meetings, records of conversations, newsletters, telegrams, summaries, lists, compilations, facsimile transmissions, transcripts, diaries, appointment books, agreements, contracts, reports, studies, checks, check stubs, invoices, financial statements, bank statements, receipts, communications, interoffice and intraoffice exchanges, conversations, inquiries, replies, correspondence, and letters, whether in person, by telephone, in writing, or by means of any other transmittal

+0¶

devices, and all originals, reproductions, copies, changes, amendments, drafts and all non-identical copies of the foregoing;¶

b. Graphic or auditory records or representations of any kind, including, but not limited to: all images, photographs, charts, drawings, sketches, diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser discs, digital versatile discs, Blu-ray discs, UltraViolet discs tte tapes, reel to reel tapes, recordings, sound bites, motion pi e messages, and all originals, reproductions, copies, chan ents, drafts and all non-identical copies of the foregoing;
c. Electronically stored information, mechanical and electrical records or representations o including, but not limited to: all electronic communicat messages, e-mails, instant messages, computer logs, ne rk lo, Internet history, document files, spreadsheet files, presen o, database files, desktop publishing files, source code files, ob e files, executable files, data files, script files, project nt files, text files, portable document format files, tabulated data files, virtual machine files, XML files, webpage files, image files, design 0 video files, backup files, metadata and all originals, reproductions, copies, files, GIS files, system files, compressed files, disk image files, audio files, changes, amendments, drafts, and all non-identical copies of the foregoing (defined herein as "ESP'; each individual electronically stored document is defined herein as an "ESI document").

For purposes of the foregoing, documents may be located, stored or archived in any physical location or on any electronic storage media, including, without limitation, any computer, server, appliance, cloud-based service, web-based service, database, internal hard drive, external hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the term "draft" means any earlier, preliminary, preparatory, or tentative version of all pr part of a document, whether or not such draft was superseded by a later draft and whether o> e draft's terms are the same as or different from the final document's terms. Pleas "Document" and "Documents" as defined herein specifically include "Comm unicat C' n .) ommunications" as defined above.¶

"Native Format" means the file format of 'n p pplication in which such ESI was originally created.
"Person" as used herein m ial person or any entity, including, without limitation, any individual, public comp priv company, firm, corporation, limited liability company, joint venture, trust, pro 1 , tenancy, association, partnership, business, agency, department, governmental body board, commission, or any other form of public or private entity. With respect to an r• Person shall include all subsidiaries and affiliates of the entity, as well as the prese d fo er directors, officers, employees, attorneys, agents and anyone acting on behalf of, • trection of, or under the control of, the entity or its subsidiaries or affiliates.

+he terms 51ou" or 5,our" mean Adam Horowitz and include all employees, staff, representatives, attorneys, accountants, agents and any other person acting under his control or on his behalf.¶

"Relates to" or "relating to" mean authorizing, concerning, constituting, comprising, containing, consisting of, connected with, describing, disclosing, discussing,

evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to, directly or indirectly, setting forth, showing, or summarizing.¶

"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit in and for Palm Beach County, Florida.
"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E. ,,....., . any other clients represented by J. against Jeffrey Epstein from 7l1, 2008 to the present.
"Tagged Image File Forma(' or "TIFF' refer toC Group IV graphic file for storing bit-mapped images. tiw
Where appropriate:
informs( your po e to this Subpoena Duces Tecum, you are required to furnish all ments which are, or have been, in your possession, custody, or control, or in on, custody, or control.

a.
b.
c.
d.
e.
f. use of the singular inch the past tense includes the words "and" an the words "all" the word "inc use of the o rsic ,t a1, and vice versa; e tense; tr" th conjunctive and disjunctive; can "any and all"; ans "including without limitation"; and ncludes the feminine, and vice versa.

INSTRUCTIONS¶

General Instructions¶

Unless otherwise specifically stated in each request, the relevant time period shall be the period from January 1, 2008 to the present.

ESI Instructions¶

ESI Production Format. ES! shall be produced electronically, either in (1) Native Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files. For each ES! document, all metadata must remain intact and all parent/child document relationships must be maintained. All ES! shall be collected using methods that prevent the spoliation of data.
Production Media. The production of ESI as described he be made on an external hard drive, flash drive, CD or DVD ("Production Media"). c e ction Media shall include a unique identifying label specifying: (a) your identity- the te of the production of ESI; and (c) the Lawsuit name and number.
ESI of Limited Accessibility. If you at any ESI document responsive to this Subpoena is not reasonably accessible: (1 i ntify such ES! document with reasonable particularity; and (2) provide the basis ' .....e eel' g to produce the ESI document, including, for example, any limitations on acc ely costs that might be incurred in accessing and producing the ESI document, which the ESI document i used for storage of the ESI document and all locations in
TI . ES! produced as TIFF image files shall be produced as follows: (1) each pro f IFF image files shall be accompanied by a corresponding load file ("Image Load ) each TIFF image file must contain the same information and same physical representation as the Native Format file from which the TIFF image file was created; (3) each TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be accompanied by an extracted text file containing the extracted text of the Native Format file from which the TIFF image file was created; (5) each extracted text file shall be named to match the endorsed number assigned to the first page of each corresponding TIFF image file; (6) the extracted text files shall be accompanied by a Control List File ("LS7"); (7) each production of TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon ("OPT' , which shall provide the beginning and ending endorsed number of each TIFF image file and the number of pages it includes; and (8) each production of TIFF image files must be accompanied by a data load file ("Data Load File" or "DA7") that contains both the hash value and all available metadata of the Native Format files from which the TIFF i les were created. Further, the following instructions apply to the production of TIFF • les:

a. Processing Specifications. For each Native Fo at is converted to TIFF format: (1) all tracked changes sha a med so that all changes are visible; (2) OLE Embedded fit s ) of be extracted as separate
- (3) author comme s I main or be made visible; (4) hidden columns, cells, rows, w nd other hidden data shall remain or be made visible; (5) to otes shall remain or be made visible; and (6) to the extent i a eign language is produced, processing of such ESI shall be compliant.
b. D nitizati n. If a Native Format file that is converted to TIFF t is more than one page, the unitization of the file and any attachments 0 unitization cannot be maintained, the original unitization must be or affixed notes must be maintained as it existed when collected. If documented in the Data Load File or otherwise electronically tracked.
- c. Color. If a Native Format file that is converted to TIFF format contains color, the TIFF image file need not be produced in color. However, we reserve the right to make a request for a file to be produced in color.
d. Where TIFF Image File Format is Impracticable. In the event that production of a Native Format file as a TIFF image would be impracticable, you shall produce such file in Native Format with all metadata intact. You shall provide a single page TIFF image placeholder referencing the title of the Native Format file not being produced as a TIFF image.
e. Spreadsheets. All Microsoft Excel files, similar non-Micro readsheet files, and graphical compilations of spreadsheet datp i produced in Native Format with all cells, columns, row information unhidden and expanded.
f. Right to Request Native Format eserve the right to demand production in Native Format< lc"NSfi, produced by you as a TIFF image file. hects and other

REQUESTED DOCUMENTS¶

1. Your current curriculum vitae. )r
1. My reports prepared b u r at your direction, relating to your services or participation in this Lawsuit and your is of the Other Lawsuits.
1. Copies of a no a& by you, or provided to you, relating to your opinions or conclusiopA i this Lawsuit and your analysis of the Other Lawsuits, whether you relied on those
1. tions between you and any person relating to your analysis, opinions or ons in this Lawsuit, as well as your analysis of the Other Lawsuits.
1. My photographs or videos taken by you, or provided to you, that you have observed and reviewed in relation to this Lawsuit.
1. My deposition or hearing transcripts provided to you, or parts of deposition transcripts or any other statements or written materials provided to you, which you have examined or will examine in relation to this Lawsuit.
1. Any diagrams or drawings made by you or provided to you, which you have examined in relation to this Lawsuit.
1. My statements or affidavits taken by you, at your direction, or provided to you for your review concerning any of the facts which are involved in this Lawsuit.
1. Any memoranda or written notice made by you, or provided to you, concerning the subject matter of this Lawsuit.
1. My documents prepared by you, provided to you, or obtained by you or reviewed by you, whether intended for your use or not, and regardless of whether or not ypu actually reviewed or relied on those documents, in connection with this Lawsuit.
1. All literature and/or documents that you considered relevant to you mdht in this Lawsuit and which you considered in the development of your o 0 • • conclusions concerning the subject matter of the lawsuit.
1. All documents prepared by you to illustrate or demonstrate a fact r opinion considered relevant to this Lawsuit and/or to your assignment, inv tio r opinions.
1. Copies of any articles, books, papers or other publ by you which relate to facts similar to the facts surrounding the subjec this Lawsuit.
1. My and all materials considered, consu by you as a basis or predicate for your opinions and conclusions in th' u including, but not limited to, published reports by any private or govern age y, textbooks, articles, data or documents finished by the party engagin ices, or government or industry standards or regulations.
1. My and all models or formulation and exp of this Lawsuit. ve tools upon which you have or plan to rely, in the ur opinions and conclusions concerning the subject matter
1. A co of apy rem e agreement or otheriment between you and James I for James that sets forth the terms of your is matter, including, but not limited to, the fees for your services in this
1. of all statements, bills, invoices, check stubs or any other document that reflects pa ent or compensation, or a request for payment or compensation, for your services in this Lawsuit or any of the Other Lawsuits.
1. All marketing materials that market or advertise your expert witness services.
1. A list of all other expirSess serviiasjaformed for James M, or any clients represented by James in the last ten years.
1. A list of other depositions or trials in which you have testified from January 1, 2008 to the present.
1. All expert reports, testimony, videos and affidavits in which you have testified as an expert on any issue in the last ten years.
1. Copies of all publications, expert reports, depositions or other documents in which you have discussed, analyzed or otherwise referenced the subject of the scope of discovery in litigation.
1. Your file regarding your opinions, possible opinions, expert testimony, and/or consultation relating directly or indirectly to the issues in this Lawsuit.
1. All complaints filed against you with the Florida Bar, as well as all co icati ns to you by the Florida Bar and all documents relating to any discip ceedings or investigations conducted by the Florida Bar, or any committee of a Fl Bar.

TAB 6¶

NOT A CERTIFIED COPY¶

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

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant, J. individually, Defendants/Counter-Plaintiff. (Mail in Sub THE STATE OF FLORIDA TO: Law Firm, P.A. ° 224 Datura Street, Suite 9 West Palm Beach, FL 3* have with you e and place the following:¶

^v .¶

SCOTT ROTHSTEIN individually, and¶

SUBPOENA DUCES TECUM WI EPOSITION¶

TO: Isidro M.¶

YOU ARE COMM to appear at Link & Rockenbach, P.A., 1555 Palm Beach Lakes Boulevard, S le 30 1 est Palm Beach, Florida, on, 2017, at 11:30 a.m. and to¶

SEE EXHIBIT A¶

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

If you fail to:¶

10.448k¶

(1) appear as specified; or
(2) furnish the records instead of appearing as provided abov e or s)O .1
(3) object to this Subpoena,

you may be in contempt of court. You are subpoenaed ref the following attorneys, and unless excused from this Subpoena by the attom S, S t Court, you shall respond to this Subpoena as directed.¶

Dated: November 2017.¶

& ROCKENBACH, P.A. 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601 [fax]¶

[DRAFT]¶

Copies provided to:¶

SERVICE LIST¶

<p>Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 <a href="mailto:mep@searcylaw.com">mep@searcylaw.com</a> <a href="mailto:jsx@searcylaw.com">jsx@searcylaw.com</a> <a href="mailto:scarolateam@searcylaw.com">scarolateam@searcylaw.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>	<p>Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 <a href="mailto:njs@FLAppellateLaw.com">njs@FLAppellateLaw.com</a> <a href="mailto:kbt@FLAppellateLaw.com">kbt@FLAppellateLaw.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>
<p>[REDACTED] J. [REDACTED] [REDACTED] Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 <a href="mailto:brad@epllc.com">brad@epllc.com</a> <a href="mailto:staff.efile@pathtojustice.com">staff.efile@pathtojustice.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>	<p>Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 <a href="mailto:marc@nuriklaw.com">marc@nuriklaw.com</a> <i>Counsel for Defendant Scott Rothstein</i></p>
<p>Tonja Haddad Coleman 315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, FL 33301 <a href="mailto:tonja@tonjahaddad.com">tonja@tonjahaddad.com</a> <a href="mailto:efiling@tonjahaddad.com">efiling@tonjahaddad.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Fred Haddad Haddad & Navarro, PLLC 1 Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 <a href="mailto:dee@haddadandnavarrolaw.com">dee@haddadandnavarrolaw.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>
<p>W. Chester Brewer, Jr. W. Chester Brewer, Jr. P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:wcblaw@aol.com">wcblaw@aol.com</a> <a href="mailto:wcblawasst@gmail.com">wcblawasst@gmail.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:jgoldberger@agwpa.com">jgoldberger@agwpa.com</a> <a href="mailto:smahoney@agwpa.com">smahoney@agwpa.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>

cos¶

EXHIBIT A¶

DEFINITIONS¶

I. "Communication" or "communications" mean any oral, written or electronic utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including, but not limited to, any documents, correspondence, letters, facsimiles, e-mails, tex messages, voice recordings, video recordings, voicemail, instant messages, conversatiAlAlidialogues, discussions, interviews, conferences, meetings, consultations, a and other understandings or exchanges between or among two or more people.¶

"Document" or "documents" mean all paper do ts, phic or auditory records broadest possible meaning accorded to it consisten or representations, tangible items, and electronically s Ac? i nation, and shall have the lIda Rule of Civil Procedure 1.280 (which is incorporated in this definition as if IN t rth), and includes, by way of illustration only and not by way of limitation, the ow' items which arc in your possession, control, knowledge, or are known to you:

a. All writt or printed material of any kind, including, but not limited : nsmittal slips, memoranda, notes, schedules, agendas, notices, brochures, calendars, employment files, announcements, meeting minutes, records of meetings, records of conversations, newsletters, telegrams, summaries, lists, compilations, facsimile transmissions, transcripts, diaries, appointment books, agreements, contracts, reports, studies, checks, check stubs, invoices, financial statements, bank statements, receipts, communications, interoffice and intraoffice exchanges, conversations, inquiries, replies, correspondence, and letters, whether in person, by telephone, in writing, or by means of any other transmittal

+0¶

devices, and all originals, reproductions, copies, changes, amendments, drafts and all non-identical copies of the foregoing;¶

b. Graphic or auditory records or representations of any kind, including, but not limited to: all images, photographs, charts, drawings, sketches, diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser discs, digital versatile discs, Blu-ray discs, UltraViolet di reel to reel tapes, recordings, sound bites, motion pi s col, tte tapes, e messages, and all originals, reproductions, copies, chan a ndments, drafts and all non-identical copies of the foregoing;
c. Electronically stored information, mechanical and electrical records or representations of n including, but not limited to: all messages, e-mails, instant messages, computer logs, ne rk lo, Internet history, document files, spreadsheet files, presen o, database files, desktop publishing files, source code files, ob e files, executable files, data files, script files, project nt files, text files, portable document format files, tabulated data files, virtual machine files, XML files, webpage files, image files, design 0 video files, backup files, metadata and all originals, reproductions, copies, files, GIS files, system files, compressed files, disk image files, audio files, changes, amendments, drafts, and all non-identical copies of the foregoing (defined herein as "ESP'; each individual electronically stored document is defined herein as an "ESI document"). electronic communicat

For purposes of the foregoing, documents may be located, stored or archived in any physical location or on any electronic storage media, including, without limitation, any computer, server, appliance, cloud-based service, web-based service, database, internal hard drive, external hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the term "draft" means any earlier, preliminary, preparatory, or tentative version of all pr part of a document, whether or not such draft was superseded by a later draft and whether of e draft's terms are the same as or different from the final document's terms. Pleas "Document" and "Documents" as defined herein specifically include "Comm unicat C• n .) ommunications" as defined above.¶

"Native Format" means the file format of 'n p pplication in which such ESI was originally created.
"Person" as used herein m i a I person or any entity, including, without limitation, any individual, public comp ,c)..., priv company, firm, corporation, limited liability company, joint venture, trust, pro 1 , tenancy, association, partnership, business, agency, department, governmental bod board, commission, or any other form of public or private entity. With respect to an r• P erson shall include all subsidiaries and affiliates of the entity, as well as the prese d fo er directors, officers, employees, attorneys, agents and anyone acting on behalf of, • Erection of, or under the control of, the entity or its subsidiaries or affiliates.

+he terms "you" or "your" mean Isidro M. and include all employees, staff, representatives, attorneys, accountants, agents and any other person acting under his control or on his behalf.¶

"Relates to" or "relating to" mean authorizing, concerning, constituting, comprising, containing, consisting of, connected with, describing, disclosing, discussing,

evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to, directly or indirectly, setting forth, showing, or summarizing.¶

"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and J. Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit in and for Palm Beach County, Florida.
"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E. ,,....., . any other clients represented by J. against Jeffrey Epstein from 1, 2008 to the present.
"Tagged Image File Forma(' or "TIFF' refer toC Group IV graphic file for storing bit-mapped images. tiw
Where appropriate:
informs( your po e to this Subpoena Duces Tecum, you are required to furnish all ments which are, or have been, in your possession, custody, or control, or in on, custody, or control.

a.
b.
c.
d.
e.
f. use of the singular inch the past tense includes the words "and" an the words "all" the word "inc use of the tet, tal, and vice versa; e tense; th conjunctive and disjunctive; can "any and all"; ans "including without limitation"; and hcludes the feminine, and vice versa.

INSTRUCTIONS¶

General Instructions¶

Unless otherwise specifically stated in each request, the relevant time period shall be the period from January 1, 2008 to the present.

ESI Instructions¶

ESI Production Format. ES! shall be produced electronically, either in (1) Native Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files. For each ES! document, all metadata must remain intact and all parent/child document relationships must be maintained. All ESI shall be collected using methods that prevent the spoliation of data.
Production Media. The production of ESI as described he be made on an external hard drive, flash drive, CD or DVD ("Production Media"). c e ction Media shall include a unique identifying label specifying: (a) your identity- the te of the production of ESI; and (c) the Lawsuit name and number.
ESI of Limited Accessibility. If you iliiig" at any ESI document responsive to this Subpoena is not reasonably accessible: (1 r ntify such ES! document with reasonable particularity; and (2) provide the basis ' .....e eel' g to produce the ES! document, including, for example, any limitations on acc ely costs that might be incurred in accessing and producing the ESI document, which the ESI document used for storage of the ESI document and all locations in
TI . ES! produced as TIFF image files shall be produced as follows: (1) each pro f IFF image files shall be accompanied by a corresponding load file ("Image Load ) each TIFF image file must contain the same information and same physical representation as the Native Format file from which the TIFF image file was created; (3) each TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be accompanied by an extracted text file containing the extracted text of the Native Format file from which the TIFF image file was created; (5) each extracted text file shall be named to match the endorsed number assigned to the first page of each corresponding TIFF image file; (6) the extracted text files shall be accompanied by a Control List File ("LS7"); (7) each production of TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon ("OPT' , which shall provide the beginning and ending endorsed number of each TIFF image file and the number of pages it includes; and (8) each production of TIFF image files must be accompanied by a data load file ("Data Load File" or "DA7") that contains both the hash value and all available metadata of the Native Format files from which the TIFF irrl>l Iles were created. Further, the following instructions apply to the production of TIFF • les:

a. Processing Specifications. For each Native Fo at is converted to TIFF format: (1) all tracked changes sha a med so that all changes are visible; (2) OLE Embedded fit s ) of be extracted as separate documents; (3) author comme 8Ss I ., main or be made visible; (4) hidden columns, cells, rows, w nd other hidden data shall remain or be made visible; (5) to otes shall remain or be made visible; and (6) to the extent i a eign language is produced, processing of such ESI shall be compliant.
b. D nitizati n. If a Native Format file that is converted to TIFF t is more than one page, the unitization of the file and any attachments 0 unitization cannot be maintained, the original unitization must be or affixed notes must be maintained as it existed when collected. If documented in the Data Load File or otherwise electronically tracked.
- c. Color. If a Native Format file that is converted to TIFF format contains color, the TIFF image file need not be produced in color. However, we reserve the right to make a request for a file to be produced in color.
d. Where TIFF Image File Format is Impracticable. In the event that production of a Native Format file as a TIFF image would be impracticable, you shall produce such file in Native Format with all metadata intact. You shall provide a single page TIFF image placeholder referencing the title of the Native Format file not being produced as a TIFF image.
e. Spreadsheets. All Microsoft Excel files, similar non-Micro readsheet files, and graphical compilations of spreadsheet datp i produced in Native Format with all cells, columns, row information unhidden and expanded.
f. Right to Request Native Format eserve the right to demand production in Native Format< lcatl~fi \ produced by you as a TIFF image file. hects and other

REQUESTED DOCUMENTS¶

1. Your current curriculum vitae. )e
1. My reports prepared b u r at your direction, relating to your services or participation in this Lawsuit and your is of the Other Lawsuits.
1. Copies of a no ade by you, or provided to you, relating to your opinions or conclusiop9 i this Lawsuit and your analysis of the Other Lawsuits, whether you relied on those
1. tions between you and any person relating to your analysis, opinions or ons in this Lawsuit, as well as your analysis of the Other Lawsuits.
1. My photographs or videos taken by you, or provided to you, that you have observed and reviewed in relation to this Lawsuit.
1. My deposition or hearing transcripts provided to you, or parts of deposition transcripts or any other statements or written materials provided to you, which you have examined or will examine in relation to this Lawsuit.
1. Any diagrams or drawings made by you or provided to you, which you have examined in relation to this Lawsuit.
1. My statements or affidavits taken by you, at your direction, or provided to you for your review concerning any of the facts which are involved in this Lawsuit.
1. Any memoranda or written notice made by you, or provided to you, concerning the subject matter of this Lawsuit.
1. My documents prepared by you, provided to you, or obtained by you or reviewed by you, whether intended for your use or not, and regardless of whether or not ypu actually reviewed or relied on those documents, in connection with this Lawsuit.
1. All literature and/or documents that you considered relevant to yo in this Lawsuit and which you considered in the development of your o 0 • • conclusions concerning the subject matter of the lawsuit.
1. All documents prepared by you to illustrate or demonstrate a fact r opinion considered relevant to this Lawsuit and/or to your assignment, inv ti0 , r opinions.
1. Copies of any articles, books, papers or other publ red by you which relate to facts similar to the facts surrounding the subjec this Lawsuit.
1. My and all materials considered, consu by you as a basis or predicate for your opinions and conclusions in tit' u including, but not limited to, published reports by any private or govern age y, textbooks, articles, data or documents furnished by the party engagin ices, or government or industry standards or regulations.
1. My and all models or formulation and exp of this Lawsuit. ve tools upon which you have or plan to rely, in the ur opinions and conclusions concerning the subject matter
1. A conv of auv retAfnef agreement or otheriment between you and James I for James that sets forth the terms of your is matter, including, but not limited to, the fees for your services in this
1. of all statements, bills, invoices, check stubs or any other document that reflects pa ent or compensation, or a request for payment or compensation, for your services in this Lawsuit or any of the Other Lawsuits.
1. All marketing materials that market or advertise your expert witness services.
1. A list of all other expErSess serviiasjaformed for James M, or any clients represented by James in the last ten years.
1. A list of other depositions or trials in which you have testified from January 1, 2008 to the present.
1. All expert reports, testimony, videos and affidavits in which you have testified as an expert on any issue in the last ten years.
1. Copies of all publications, expert reports, depositions or other documents in which you have discussed, analyzed or otherwise referenced the subject of the scope of discovery in litigation.
1. Your file regarding your opinions, possible opinions, expert testimony, and/or consultation relating directly or indirectly to the issues in this Lawsuit.
1. All complaints filed against you with the Florida Bar, as well as all co icati ns to you by the Florida Bar and all documents relating to any discip ceedings or investigations conducted by the Florida Bar, or any committee of a FI t Bar.

TAB 7¶

NOT A CERTIFIED COPY¶

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

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

PlaintiffiCounter-Defendant,¶

^v .¶

SCOTT ROTHSTEIN individually, and J. individually,¶

Defendants/Counter-Plaintiff.¶

SUBPOENA DUCES TECUM WI EPOSITION¶

(Mail in Sub¶

THE STATE OF FLORIDA TO:¶

TO: Earleen Cote Kubicki Draper One East Broward Blvd., S Ft. Lauderdale, FL 333¶

YOU ARE COMM to appear at Link & Rockenbach, P.A., 1555 Palm Beach Lakes Boulevard, S to 30t,West Palm Beach, Florida, on, 2017, at 12:00 p.m. and to have with youjk t e and place the following:¶

SEE EXHIBIT A¶

If you fail to:¶

10.448k¶

(1) appear as specified; or
(2) furnish the records instead of appearing as provided abov e or s)O .1
(3) object to this Subpoena,

you may be in contempt of court. You are subpoenaed ref the following attorneys, and unless excused from this Subpoena by the attom S, S t Court, you shall respond to this Subpoena as directed.¶

Dated: November 2017.¶

& ROCKENBACH, P.A. 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601 [fax]¶

[DRAFT]¶

Copies provided to:¶

SERVICE LIST¶

<p>Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 <a href="mailto:mep@searcylaw.com">mep@searcylaw.com</a> <a href="mailto:jsx@searcylaw.com">jsx@searcylaw.com</a> <a href="mailto:scarolateam@searcylaw.com">scarolateam@searcylaw.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> <b>J. [REDACTED]</b></p>	<p>Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 <a href="mailto:njs@FLAppellateLaw.com">njs@FLAppellateLaw.com</a> <a href="mailto:kbt@FLAppellateLaw.com">kbt@FLAppellateLaw.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> <b>J. [REDACTED]</b></p>
<p><b>J. [REDACTED]</b> Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 <a href="mailto:brad@epllc.com">brad@epllc.com</a> <a href="mailto:staff.efile@pathtojustice.com">staff.efile@pathtojustice.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> <b>J. [REDACTED]</b></p>	<p>Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 <a href="mailto:marc@nuriklaw.com">marc@nuriklaw.com</a> <i>Counsel for Defendant Scott Rothstein</i></p>
<p>Tonja Haddad Coleman 315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, FL 33301 <a href="mailto:tonja@tonjahaddad.com">tonja@tonjahaddad.com</a> <a href="mailto:efiling@tonjahaddad.com">efiling@tonjahaddad.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Fred Haddad Haddad & Navarro, PLLC 1 Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 <a href="mailto:dee@haddadandnavarrolaw.com">dee@haddadandnavarrolaw.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>
<p>W. Chester Brewer, Jr. W. Chester Brewer, Jr. P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:wcblaw@aol.com">wcblaw@aol.com</a> <a href="mailto:wcblawasst@gmail.com">wcblawasst@gmail.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:jgoldberger@agwpa.com">jgoldberger@agwpa.com</a> <a href="mailto:smahoney@agwpa.com">smahoney@agwpa.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>

cos¶

EXHIBIT A¶

DEFINITIONS¶

I. "Communication" or "communications" mean any oral, written or electronic utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including, but not limited to, any documents, correspondence, letters, facsimiles, e-mails, tex messages, voice recordings, video recordings, voicemail, instant messages, conversatiAlAlidialogues, discussions, interviews, conferences, meetings, consultations, a and other understandings or exchanges between or among two or more people.¶

"Document" or "documents" mean all paper do ts, phic or auditory records broadest possible meaning accorded to it consisten or representations, tangible items, and electronically s Ac? i nation, and shall have the lIda Rule of Civil Procedure 1.280 (which is incorporated in this definition as if IN t rth), and includes, by way of illustration only and not by way of limitation, the ow' items which arc in your possession, control, knowledge, or are known to you:

a. All writt or printed material of any kind, including, but not limited : nsmittal slips, memoranda, notes, schedules, agendas, notices, brochures, calendars, employment files, announcements, meeting minutes, records of meetings, records of conversations, newsletters, telegrams, summaries, lists, compilations, facsimile transmissions, transcripts, diaries, appointment books, agreements, contracts, reports, studies, checks, check stubs, invoices, financial statements, bank statements, receipts, communications, interoffice and intraoffice exchanges, conversations, inquiries, replies, correspondence, and letters, whether in person, by telephone, in writing, or by means of any other transmittal

+0¶

devices, and all originals, reproductions, copies, changes, amendments, drafts and all non-identical copies of the foregoing;¶

b. Graphic or auditory records or representations of any kind, including, but not limited to: all images, photographs, charts, drawings, sketches, diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser discs, digital versatile discs, Blu-ray discs, UltraViolet di reel to reel tapes, recordings, sound bites, motion pi s col, tte tapes, e messages, and all originals, reproductions, copies, chan a ndments, drafts and all non-identical copies of the foregoing;
c. Electronically stored information, mechanical and electrical records or representations o including, but not limited to: all electronic communicat messages, e-mails, instant messages, computer logs, ne rk lo, Internet history, document files, spreadsheet files, presen o, database files, desktop publishing files, source code files, ob e files, executable files, data files, script files, project nt files, text files, portable document format files, tabulated data files, virtual machine files, XML files, webpage files, image files, design 0 video files, backup files, metadata and all originals, reproductions, copies, files, GIS files, system files, compressed files, disk image files, audio files, changes, amendments, drafts, and all non-identical copies of the foregoing (defined herein as "ESP'; each individual electronically stored document is defined herein as an "ESI document").

For purposes of the foregoing, documents may be located, stored or archived in any physical location or on any electronic storage media, including, without limitation, any computer, server, appliance, cloud-based service, web-based service, database, internal hard drive, external hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the term "draft" means any earlier, preliminary, preparatory, or tentative version of all pr part of a document, whether or not such draft was superseded by a later draft and whether o e draft's terms are the same as or different from the final document's terms. Pleas "Document" and "Documents" as defined herein specifically include "Comm unicat* C n .) ommunications" as defined above.¶

"Native Format" means the file format of 'n p pplication in which such ESI was originally created.
"Person" as used herein m ial person or any entity, including, without limitation, any individual, public comp priv company, firm, corporation, limited liability company, joint venture, trust, pro, tenancy, association, partnership, business, agency, department, governmental body board, commission, or any other form of public or private entity. With respect to an r• Person shall include all subsidiaries and affiliates of the entity, as well as the prese d fo er directors, officers, employees, attorneys, agents and anyone acting on behalf of, •trection of, or under the control of, the entity or its subsidiaries or affiliates.

+he terms 5,ou" or 5,our" mean Earleen Cote and include all employees, staff, representatives, attorneys, accountants, agents and any other person acting under her control or on her behalf.¶

"Relates to" or "relating to" mean authorizing, concerning, constituting, comprising, containing, consisting of, connected with, describing, disclosing, discussing,

evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to, directly or indirectly, setting forth, showing, or summarizing.¶

"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit in and for Palm Beach County, Florida.
"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E. . any other clients represented by J. against Jeffrey Epstein from 1, 2008 to the present.
"Tagged Image File Format' or "TIFF' refer toC Group IV graphic file for storing bit-mapped images. tiw
Where appropriate:
informs( your po e to this Subpoena Duces Tecum, you are required to furnish all ments which are, or have been, in your possession, custody, or control, or in on, custody, or control.

a.
b.
c.
d.
e.
f. use of the singular inch the past tense includes the words "and" an the words "all" the word "inc use of the silec,al, t and vice versa; e tense; th conjunctive and disjunctive; can "any and all"; ans "including without limitation"; and hcludes the feminine, and vice versa.

INSTRUCTIONS¶

General Instructions¶

Unless otherwise specifically stated in each request, the relevant time period shall be the period from January 1, 2008 to the present.

ESI Instructions¶

ESI Production Format. ES! shall be produced electronically, either in (1) Native Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files. For each ES! document, all metadata must remain intact and all parent/child document relationships must be maintained. All ESI shall be collected using methods that prevent the spoliation of data.
Production Media. The production of ESI as described he be made on an external hard drive, flash drive, CD or DVD ("Production Media"). c e ction Media shall include a unique identifying label specifying: (a) your identity- the te of the production of ESI; and (c) the Lawsuit name and number.
ESI of Limited Accessibility. If you tAgl, at any ESI document responsive to this Subpoena is not reasonably accessible: (1 r ntify such ES! document with reasonable particularity; and (2) provide the basis ' .....e eel' g to produce the ES! document, including, for example, any limitations on acc ely costs that might be incurred in accessing and producing the ESI document, which the ESI document i used for storage of the ESI document and all locations in
TI . ES! produced as TIFF image files shall be produced as follows: (1) each pro f IFF image files shall be accompanied by a corresponding load file ("Image Load ) each TIFF image file must contain the same information and same physical representation as the Native Format file from which the TIFF image file was created; (3) each TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be accompanied by an extracted text file containing the extracted text of the Native Format file from which the TIFF image file was created; (5) each extracted text file shall be named to match the endorsed number assigned to the first page of each corresponding TIFF image file; (6) the extracted text files shall be accompanied by a Control List File ("LS7"); (7) each production of TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon ropn, which shall provide the beginning and ending endorsed number of each TIFF image file and the number of pages it includes; and (8) each production of TIFF image files must be accompanied by a data load file ("Data Load File" or "DAT) that contains both the hash value and all available metadata of the Native Format files from which the TIFF miles were created. Further, the following instructions apply to the production of TIFF •

a. Processing Specifications. For each Native Fo a at is converted to TIFF format: (1) all tracked changes shwa med so that all changes are visible; (2) OLE Embedded of be extracted as separate documents; (3) author comme Sc main or be made visible; (4) hidden columns, cells, rows, w nd other hidden data shall remain or be made visible; (5) to otes shall remain or be made visible; and (6) to the extent eign language is produced, processing of such ESI shall be compliant.
b. D nitizati n. If a Native Format file that is converted to TIFF t is more than one page, the unitization of the file and any attachments O unitization cannot be maintained, the original unitization must be or affixed notes must be maintained as it existed when collected. If documented in the Data Load File or otherwise electronically tracked.
- c. Color. If a Native Format file that is converted to TIFF format contains color, the TIFF image file need not be produced in color. However, we reserve the right to make a request for a file to be produced in color.
d. Where TIFF Image File Format is Impracticable. In the event that production of a Native Format file as a TIFF image would be impracticable, you shall produce such file in Native Format with all metadata intact. You shall provide a single page TIFF image placeholder referencing the title of the Native Format file not being produced as a TIFF image.
e. Spreadsheets. All Microsoft Excel files, similar non-Micro readsheet files, and graphical compilations of spreadsheet datp i produced in Native Format with all cells, columns, row information unhidden and expanded.
f. Right to Request Native Format eserve the right to demand production in Native Formatt lc"NSfi., produced by you as a TIFF image file. hects and other

REQUESTED DOCUMENTS¶

1. Your current curriculum vitae. )e
1. My reports prepared b u r at your direction, relating to your services or participation in this Lawsuit and your is of the Other Lawsuits.
1. Copies of a no a& by you, or provided to you, relating to your opinions or conclusiopA i this Lawsuit and your analysis of the Other Lawsuits, whether you relied on those
1. tions between you and any person relating to your analysis, opinions or ons in this Lawsuit, as well as your analysis of the Other Lawsuits.
1. My photographs or videos taken by you, or provided to you, that you have observed and reviewed in relation to this Lawsuit.
1. My deposition or hearing transcripts provided to you, or parts of deposition transcripts or any other statements or written materials provided to you, which you have examined or will examine in relation to this Lawsuit.
1. Any diagrams or drawings made by you or provided to you, which you have examined in relation to this Lawsuit.
1. My statements or affidavits taken by you, at your direction, or provided to you for your review concerning any of the facts which are involved in this Lawsuit.
1. Any memoranda or written notice made by you, or provided to you, concerning the subject matter of this Lawsuit.
1. My documents prepared by you, provided to you, or obtained by you or reviewed by you, whether intended for your use or not, and regardless of whether or not ypu actually reviewed or relied on those documents, in connection with this Lawsuit.
1. All literature and/or documents that you considered relevant to yo in this Lawsuit and which you considered in the development of your o 0 ' • conclusions concerning the subject matter of the lawsuit.
1. All documents prepared by you to illustrate or demonstrate fact r opinion considered relevant to this Lawsuit and/or to your assignment, inv do r opinions.
1. Copies of any articles, books, papers or other publ by you which relate to facts similar to the facts surrounding the subjec this Lawsuit.
1. My and all materials considered, consul ed by you as a basis or predicate for your opinions and conclusions in th• u including, but not limited to, published reports by any private or govern age y, textbooks, articles, data or documents furnished by the party engagin ices, or government or industry standards or regulations.
1. My and all models or formulation and exp of this Lawsuit. ve tools upon which you have or plan to rely, in the ur opinions and conclusions concerning the subject matter
1. A conv of auv re eef agreement or otheriment between you and James guns I for James that sets forth the terms of your is matter, including, but not limited to, the fees for your services in this
1. of all statements, bills, invoices, check stubs or any other document that reflects pa ent or compensation, or a request for payment or compensation, for your services in this Lawsuit or any of the Other Lawsuits.
1. All marketing materials that market or advertise your expert witness services.
1. A list of all other expattzitstess services performed for James M, or any clients represented by James in the last ten years.
1. A list of other depositions or trials in which you have testified from January 1, 2008 to the present.
1. All expert reports, testimony, videos and affidavits in which you have testified as an expert on any issue in the last ten years.
1. Copies of all publications, expert reports, depositions or other documents in which you have discussed, analyzed or otherwise referenced the subject of the scope of discovery in litigation.
1. Your file regarding your opinions, possible opinions, expert testimony, and/or consultation relating directly or indirectly to the issues in this Lawsuit.
1. All complaints filed against you with the Florida Bar, as well as all co by the Florida Bar and all documents relating to any disci investigations conducted by the Florida Bar, or any committee of icati ns to you roceedings or Bar.

iS 4/) 9¶

?S'¶

r¶

C¶

—¶

r ic S II PIIIr¶

'....)¶

TAB 8¶

NOT A CERTIFIED COPY¶

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

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

PlaintiffiCounter-Defendant,¶

^v .¶

SCOTT ROTHSTEIN individually, and J. individually,¶

Defendants/Counter-Plaintiff.¶

SUBPOENA DUCES TECUM WI EPOSITION¶

(Mail in Sub¶

THE STATE OF FLORIDA TO:¶

TO: William Berger Weiss, Handler, Comwell, P 2255 Glades Road, Suite 2 Boca Raton, FL 33431¶

YOU ARE COMM to appear at Link & Rockenbach, P.A., 1555 Palm Beach Lakes Boulevard, S to 30tWest Palm Beach, Florida, on, 2017, at 12:30 p.m. and to have with youjk t e and place the following:¶

SEE EXHIBIT A¶

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

If you fail to:¶

10.448k¶

(1) appear as specified; or
(2) furnish the records instead of appearing as provided abov e or s)O .1
(3) object to this Subpoena,

you may be in contempt of court. You are subpoenaed ref the following attorneys, and unless excused from this Subpoena by the attom S, S t Court, you shall respond to this Subpoena as directed.¶

Dated: November 2017.¶

& ROCKENBACH, P.A. 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601 [fax]¶

[DRAFT]¶

Copies provided to:¶

SERVICE LIST¶

<p>Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 <a href="mailto:mep@searcylaw.com">mep@searcylaw.com</a> <a href="mailto:jsx@searcylaw.com">jsx@searcylaw.com</a> <a href="mailto:scarolateam@searcylaw.com">scarolateam@searcylaw.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>	<p>Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 <a href="mailto:njs@FLAppellateLaw.com">njs@FLAppellateLaw.com</a> <a href="mailto:kbt@FLAppellateLaw.com">kbt@FLAppellateLaw.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>
<p>[REDACTED] J. [REDACTED] [REDACTED] Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 <a href="mailto:brad@epllc.com">brad@epllc.com</a> <a href="mailto:staff.efile@pathtojustice.com">staff.efile@pathtojustice.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> [REDACTED] J. [REDACTED]</p>	<p>Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 <a href="mailto:marc@nuriklaw.com">marc@nuriklaw.com</a> <i>Counsel for Defendant Scott Rothstein</i></p>
<p>Tonja Haddad Coleman 315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, FL 33301 <a href="mailto:tonja@tonjahaddad.com">tonja@tonjahaddad.com</a> <a href="mailto:efiling@tonjahaddad.com">efiling@tonjahaddad.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Fred Haddad Haddad & Navarro, PLLC 1 Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 <a href="mailto:dee@haddadandnavarrolaw.com">dee@haddadandnavarrolaw.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>
<p>W. Chester Brewer, Jr. W. Chester Brewer, Jr. P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:wcblaw@aol.com">wcblaw@aol.com</a> <a href="mailto:wcblawasst@gmail.com">wcblawasst@gmail.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p>Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:jgoldberger@agwpa.com">jgoldberger@agwpa.com</a> <a href="mailto:smahoney@agwpa.com">smahoney@agwpa.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>

cos¶

EXHIBIT A¶

DEFINITIONS¶

I. "Communication" or "communications" mean any oral, written or electronic utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including, but not limited to, any documents, correspondence, letters, facsimiles, e-mails, tex messages, voice recordings, video recordings, voicemail, instant messages, conversatiAlAlidialogues, discussions, interviews, conferences, meetings, consultations, a and other understandings or exchanges between or among two or more people.¶

"Document" or "documents" mean all paper do ts, phic or auditory records broadest possible meaning accorded to it consisten or representations, tangible items, and electronically s Ac? i nation, and shall have the lIda Rule of Civil Procedure 1.280 (which is incorporated in this definition as if IN t rth), and includes, by way of illustration only and not by way of limitation, the ow' items which arc in your possession, control, knowledge, or are known to you:

a. All writt or printed material of any kind, including, but not limited : nsmittal slips, memoranda, notes, schedules, agendas, notices, brochures, calendars, employment files, announcements, meeting minutes, records of meetings, records of conversations, newsletters, telegrams, summaries, lists, compilations, facsimile transmissions, transcripts, diaries, appointment books, agreements, contracts, reports, studies, checks, check stubs, invoices, financial statements, bank statements, receipts, communications, interoffice and intraoffice exchanges, conversations, inquiries, replies, correspondence, and letters, whether in person, by telephone, in writing, or by means of any other transmittal

+0¶

devices, and all originals, reproductions, copies, changes, amendments, drafts and all non-identical copies of the foregoing;¶

b. Graphic or auditory records or representations of any kind, including, but not limited to: all images, photographs, charts, drawings, sketches, diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser discs, digital versatile discs, Blu-ray discs, UltraViolet di reel to reel tapes, recordings, sound bites, motion pi s col, tte tapes, e messages, and all originals, reproductions, copies, chan a ndments, drafts and all non-identical copies of the foregoing;
c. Electronically stored information, mechanical and electrical records or representations o including, but not limited to: all electronic communicat messages, e-mails, instant messages, computer logs, ne rk lo, Internet history, document files, spreadsheet files, presen o, database files, desktop publishing files, source code files, ob e files, executable files, data files, script files, project nt files, text files, portable document format files, tabulated data files, virtual machine files, XML files, webpage files, image files, design 0 video files, backup files, metadata and all originals, reproductions, copies, files, GIS files, system files, compressed files, disk image files, audio files, changes, amendments, drafts, and all non-identical copies of the foregoing (defined herein as "ESP'; each individual electronically stored document is defined herein as an "ESI document").

For purposes of the foregoing, documents may be located, stored or archived in any physical location or on any electronic storage media, including, without limitation, any computer, server, appliance, cloud-based service, web-based service, database, internal hard drive, external hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the term "draft" means any earlier, preliminary, preparatory, or tentative version of all pr part of a document, whether or not such draft was superseded by a later draft and whether o e draft's terms are the same as or different from the final document's terms. Pleas "Document" and "Documents" as defined herein specifically include "Comm unicat* C n .) ommunications" as defined above.¶

"Native Format" means the file format of 'n p pplication in which such ESI was originally created.
"Person" as used herein m ial person or any entity, including, without limitation, any individual, public comp priv company, firm, corporation, limited liability company, joint venture, trust, pro, tenancy, association, partnership, business, agency, department, governmental body board, commission, or any other form of public or private entity. With respect to an rP• erson shall include all subsidiaries and affiliates of the entity, as well as the prese d fo er directors, officers, employees, attorneys, agents and anyone acting on behalf of, •trection of, or under the control of, the entity or its subsidiaries or affiliates.

+he terms "you" or "your" mean William Berger and include all employees, staff, representatives, attorneys, accountants, agents and any other person acting under his control or on his behalf.¶

"Relates to" or "relating to" mean authorizing, concerning, constituting, comprising, containing, consisting of, connected with, describing, disclosing, discussing,

evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to, directly or indirectly, setting forth, showing, or summarizing.¶

"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit in and for Palm Beach County, Florida.
"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E. . any other clients represented by J. against Jeffrey Epstein from 1, 2008 to the present.
"Tagged Image File Format' or "TIFF' refer toC Group IV graphic file for storing bit-mapped images. tiw
Where appropriate:
informs( your po e to this Subpoena Duces Tecum, you are required to furnish all ments which are, or have been, in your possession, custody, or control, or in on, custody, or control.

a.
b.
c.
d.
e.
f. use of the singular inch the past tense includes the words "and" an the words "all" the word "inc use of the silec,al, t and vice versa; e tense; th conjunctive and disjunctive; can "any and all"; ans "including without limitation"; and hcludes the feminine, and vice versa.

INSTRUCTIONS¶

General Instructions¶

Unless otherwise specifically stated in each request, the relevant time period shall be the period from January 1, 2008 to the present.

ESI Instructions¶

ESI Production Format. ES! shall be produced electronically, either in (1) Native Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files. For each ES! document, all metadata must remain intact and all parent/child document relationships must be maintained. All ESI shall be collected using methods that prevent the spoliation of data.
Production Media. The production of ESI as described he be made on an external hard drive, flash drive, CD or DVD ("Production Media"). c e ction Media shall include a unique identifying label specifying: (a) your identity- the te of the production of ESI; and (c) the Lawsuit name and number.
ESI of Limited Accessibility. If you tAgl, at any ESI document responsive to this Subpoena is not reasonably accessible: (1 r ntify such ES! document with reasonable particularity; and (2) provide the basis ' .....e eel' g to produce the ES! document, including, for example, any limitations on acc ely costs that might be incurred in accessing and producing the ESI document, which the ESI document i used for storage of the ESI document and all locations in
TI . ES! produced as TIFF image files shall be produced as follows: (1) each pro f IFF image files shall be accompanied by a corresponding load file ("Image Load ) each TIFF image file must contain the same information and same physical representation as the Native Format file from which the TIFF image file was created; (3) each TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be accompanied by an extracted text file containing the extracted text of the Native Format file from which the TIFF image file was created; (5) each extracted text file shall be named to match the endorsed number assigned to the first page of each corresponding TIFF image file; (6) the extracted text files shall be accompanied by a Control List File ("LS7"); (7) each production of TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon ropn, which shall provide the beginning and ending endorsed number of each TIFF image file and the number of pages it includes; and (8) each production of TIFF image files must be accompanied by a data load file ("Data Load File" or "DAT) that contains both the hash value and all available metadata of the Native Format files from which the TIFF miles were created. Further, the following instructions apply to the production of TIFF •

a. Processing Specifications. For each Native Fo a at is converted to TIFF format: (1) all tracked changes shwa med so that all changes are visible; (2) OLE Embedded of be extracted as separate documents; (3) author comme Sc main or be made visible; (4) hidden columns, cells, rows, w nd other hidden data shall remain or be made visible; (5) to otes shall remain or be made visible; and (6) to the extent eign language is produced, processing of such ESI shall be compliant.
b. D nitizati n. If a Native Format file that is converted to TIFF t is more than one page, the unitization of the file and any attachments O unitization cannot be maintained, the original unitization must be or affixed notes must be maintained as it existed when collected. If documented in the Data Load File or otherwise electronically tracked.
- c. Color. If a Native Format file that is converted to TIFF format contains color, the TIFF image file need not be produced in color. However, we reserve the right to make a request for a file to be produced in color.
d. Where TIFF Image File Format is Impracticable. In the event that production of a Native Format file as a TIFF image would be impracticable, you shall produce such file in Native Format with all metadata intact. You shall provide a single page TIFF image placeholder referencing the title of the Native Format file not being produced as a TIFF image.
e. Spreadsheets. All Microsoft Excel files, similar non-Micro readsheet files, and graphical compilations of spreadsheet datp i produced in Native Format with all cells, columns, row information unhidden and expanded.
f. Right to Request Native Format eserve the right to demand production in Native Formatt lc"NSfi., produced by you as a TIFF image file. hects and other

REQUESTED DOCUMENTS¶

1. Your current curriculum vitae. )e
1. My reports prepared b u r at your direction, relating to your services or participation in this Lawsuit and your is of the Other Lawsuits.
1. Copies of a no a& by you, or provided to you, relating to your opinions or conclusiopA i this Lawsuit and your analysis of the Other Lawsuits, whether you relied on those
1. tions between you and any person relating to your analysis, opinions or ons in this Lawsuit, as well as your analysis of the Other Lawsuits.
1. My photographs or videos taken by you, or provided to you, that you have observed and reviewed in relation to this Lawsuit.
1. My deposition or hearing transcripts provided to you, or parts of deposition transcripts or any other statements or written materials provided to you, which you have examined or will examine in relation to this Lawsuit.
1. Any diagrams or drawings made by you or provided to you, which you have examined in relation to this Lawsuit.
1. My statements or affidavits taken by you, at your direction, or provided to you for your review concerning any of the facts which are involved in this Lawsuit.
1. Any memoranda or written notice made by you, or provided to you, concerning the subject matter of this Lawsuit.
1. My documents prepared by you, provided to you, or obtained by you or reviewed by you, whether intended for your use or not, and regardless of whether or not ypu actually reviewed or relied on those documents, in connection with this Lawsuit.
1. All literature and/or documents that you considered relevant to yo in this Lawsuit and which you considered in the development of your o 0 ' • conclusions concerning the subject matter of the lawsuit.
1. All documents prepared by you to illustrate or demonstrate fact r opinion considered relevant to this Lawsuit and/or to your assignment, inv do r opinions.
1. Copies of any articles, books, papers or other publ by you which relate to facts similar to the facts surrounding the subjec this Lawsuit.
1. My and all materials considered, consul ed by you as a basis or predicate for your opinions and conclusions in th• u including, but not limited to, published reports by any private or govern age y, textbooks, articles, data or documents furnished by the party engagin ices, or government or industry standards or regulations.
1. My and all models or formulation and exp of this Lawsuit. ve tools upon which you have or plan to rely, in the ur opinions and conclusions concerning the subject matter
1. A conv of auv re eef agreement or otheriment between you and James guns I for James that sets forth the terms of your is matter, including, but not limited to, the fees for your services in this
1. of all statements, bills, invoices, check stubs or any other document that reflects pa ent or compensation, or a request for payment or compensation, for your services in this Lawsuit or any of the Other Lawsuits.
1. All marketing materials that market or advertise your expert witness services.
1. A list of all other expattzitstess services performed for James M, or any clients represented by James in the last ten years.
1. A list of other depositions or trials in which you have testified from January 1, 2008 to the present.
1. All expert reports, testimony, videos and affidavits in which you have testified as an expert on any issue in the last ten years.
1. Copies of all publications, expert reports, depositions or other documents in which you have discussed, analyzed or otherwise referenced the subject of the scope of discovery in litigation.
1. Your file regarding your opinions, possible opinions, expert testimony, and/or consultation relating directly or indirectly to the issues in this Lawsuit.
1. All complaints filed against you with the Florida Bar, as well as all co by the Florida Bar and all documents relating to any disci investigations conducted by the Florida Bar, or any committee of icati ns to you roceedings or Bar.

iS 4/) 9¶

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EXHIBIT D¶

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, vs.¶

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

Defendant,¶

SEVENTH AMENDED AND SUPPLEMENTAL WITNESS L1ST OF COUNTER-PLAINTIFF BRADLEY J.¶

Counter-Plaintiff, J. EDWARDS, by and through his undersigned attorneys,¶

hereby supplements his list of witnesses for trial as follows:¶

WITNESSES EXPECTED TO BE PRESENTED¶

1. _J.- 2.. Jeffrey Epstein
1. do Jo n Stephenson 1201 W. Peachtree Street Atlanta, Georgia 30339 c/o Erica Dubno 767 Third Avenue, Suite 3600 New York, New York 10017
1. Guiffre do Stan Pottinger 49 Twin Lakes Road, Suite 100 South Salem NY 10590

ADV. EPSTEIN¶

Case No.: 502009CA040800X.X.)0CMBAG¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff J.¶

Page 2 of 22¶

1. do Peter Guirguis, Esq. Mintz & Gold LLP 600 Third Avenue, 25'h Floor, New York 10016 do Pe ~ Peter Guirguis, Esq. Mintz & Gold LLP 600 Third Avenue, 25'h Floor, New York, 10016 Sherman Oaks, CA 91423-2449
1. 13701 Riverside Drive, Suite 800 9
1. do Robert C. Josefsberg, Podhurst Orseck, PA One S.E. 3rd Avenue, Sty Miami, FL 33131
1. Robert C. Jose Podhurst Orsec One S.E. rd Avenu Suite 2700 Miami, FL
1. Recarey ch Police Department outh County Road Beach, FL 33480 +12. Chief Michael Reiter Palm Beach Police Department 345 South County Road Palm Beach, FL 33480
1. do & Schuster 1230 6th Avenue New York, New York 10020

C¶

O SA¶

"S 4A)¶

ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff J. Page 3 of 22¶

1. Charles Lichtman, Esquire Berger Singerman 300 East Las Olas Boulevard, Suite 1000 Fort Lauderdale, FL 33301
1. do Adam Horowitz. Horowitz Law 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301
1. Antonio Figueroa (Tony) Palm Coast, Florida
1. Records Custodian of Palm Beach Poli 345 South County Road Palm Beach, FL 33480
1. Records Custodian of Unit for the Southern District S? 4V:rimy's Office
1. Records Custodi eral Bureau of Investigations
1. Spencer Kuvin, 1800 S. A tmlian venue, #400 West Palm Florida 33409 +22. Rinaldo Rizzo do Robert 228 East 45th Street 1 17th Floor New York, NY 10017
1. re Leopold, Esquire Istein PGA Boulevard, Suite 200 Beach Gardens, Florida 33410
1. Adam Horowitz, Esquire 425 N. Andrews Ave., Suite 2 Ft. Lauderdale, FL 33301

lgrt009CA040800XXXXMBAG¶

DV. EPSTEIN¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff M. IM¶

Page 4 of 22¶

1. Isidro M. ME Esquire =Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL, 33401
1. Earleen Cote, Esquire Kubicki Draper One East Broward Boulevard, Suite 1600 4. 41mc Fort Lauderdale, FL 33301 O
1. Bernard J. Jansen, Ph.D. do Jack Scarola West Palm Beach, FL 33409 W s Searcy Denney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Blvd. /% 27. William Berger, Esquire Weiss, Handler, Comwell, P.A. 'Cl\I 2255 Glades Road, Suite 218 Boca Raton, FL 33431

C '¶

1C)¶

WITNESSES WHI CALLED IF THE NEED ARISES¶

1. Adrian Mucins 1040 South Sho Miami Beach, FL 33 141
1. Land6h Thotyias York Times th Avenue York, NY 10018 ren Kramer do Boston Provident, L.P. 717 5th Avenue #12A New York, NY 10022
1. LaVecchio !!!Unite !!tes Attorney's Office, Southern District of Florida Broward Financial Center Fort Lauderdale, Florida

Case No.: 502009CA040800XXXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff [REDACTED] J. [REDACTED]
Page 5 of 22¶

[REDACTED]
c/o Adam Horowitz.
Horowitz Law
425 North Andrews Avenue, Suite 2
Fort Lauderdale FL 33301
Evgenia Ignatieva
1650 Broadway, #910
New York, NY 10019
[REDACTED]
[REDACTED]
c/o Adam Horowitz.
Horowitz Law
425 North Andrews Avenue, Suite 2
Fort Lauderdale FL 33301
[REDACTED]
c/o Jack Scarola
Searcy Denney Scarola Barnhart & Shipley
2139 Palm Beach Lakes Blvd.
West Palm Beach, FL 33409
[REDACTED]
c/o Robert C. Josefsberg, Esq.
Podhurst Orseck, PA
One S.E. 3^rd Avenue, Suite 2700
Miami, FL 33131
Brandy Brenson
c/o Spencer Kuvin
1800 South Australian Ave #400
West Palm Beach, Florida, 33409
[REDACTED]
c/o Robert C. Josefsberg, Esq.
Podhurst Orseck, PA
One S.E. 3^rd Avenue, Suite 2700
Miami, FL 33131

ADV. EPSTEIN¶

Case No.: 502009CA040800XXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff¶

Page 6 of 22¶

do Spencer Kuvin 1800 South Australian Ave #400 West Palm Beach, Florida, 33409
William Scherer, Esquire 633 S Federal Hwy #800 4ohlk Fort Lauderdale, FL 33301 O
Paul Cassell, Esq. 383 S. University Street Salt Lake City Utah, UT 84112
do Adam Horowitz. Horowitz Law GC Fort Lauderdale FL 33301 ? S e 425 North Andrews Avenue, Suitt
1212 N. Clark Street West Hollywood,
ght do Robe C Jose rg, Esq. Podhurst PA One 3 venue, Suite 2700 M* FL 3131
b'kobert C. Josefsberg, Esq. odhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131
lck,:,, esberg, li Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131

Case No.: 502009CA040800XXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff¶

Page 7 of 22¶

Prince Andrew Albert Christian Edwards
Duke of York, Buckingham Palace Road
London SW1A 1AA
Frederic Fekkai
Address Currently Unknown
[REDACTED]
c/o Robert C. Josefsberg, Esq.
Podhurst Orseck, PA
One S.E. 3^rd Avenue, Suite 2700
Miami, FL 33131
Lesley Groff
c/o Mike Miller
1114 Avenue of the Americas
New York, NY 10036
Dave Rogers
c/o Bruce Reinhart
505 S. Flagler Drive, Ste 300
West Palm Beach, FL 33401
[REDACTED]
c/o Adam Horowitz.
Horowitz Law
425 North Andrews Avenue, Suite 2
Fort Lauderdale FL 33301
[REDACTED]
c/o Robert C. Josefsberg, Esq.
Podhurst Orseck, PA
One S.E. 3^rd Avenue, Suite 2700
Miami, FL 33131
Meagan Dorshel
c/o Robert C. Josefsberg, Esq.
Podhurst Orseck, PA
One S.E. 3^rd Avenue, Suite 2700
Miami, FL 33131

ADV. EPSTEIN¶

Case No.: 502009CA040800XXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff¶

Page 8 of 22¶

do Adam Horowitz. Horowitz Law 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301¶

do Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3"I Avenue, Suite 2700 Miami, FL 33131¶

Tod Meister 101 Seminole Avenue Palm Beach, FL 38480

do Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2 Miami, FL 33131¶

do Robert C. Jo Podhurst Orsec One S.E. 3r Aven ,'Suite 2700 Miami, FL¶

pe Kuvin South Australian Ave #400 t Palm Beach, Florida, 33409¶

do Marshall Dore Louis 40 NW third Street, Suite 200 Miami, FL 33128¶

Jason Richards Federal Bureau of Investigation 16320 NW r d AVE., Miami, FL 33169

Case No.: 502009CA040800XXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff¶

Page 9 of 22¶

[REDACTED], Esq.
[REDACTED] Pottinger LLC
425 North Andrews Avenue, Suite 2
Fort Lauderdale FL 33301¶

[REDACTED]
c/o Adam Horowitz.
Horowitz Law
425 North Andrews Avenue, Suite 2
Fort Lauderdale FL 33301¶

Nezbitt Kurkendall
Federal Bureau of Investigation
16320 NW 2^nd Ave.
Miami, FL 33169¶

[REDACTED]
c/o Isidro M. [REDACTED]
[REDACTED] Law Firm, P.A.
224 Datura Street, Suite 900
West Palm Beach, FL, 33401¶

ADV. EPSTEIN¶

Case No.: 502009CA040800XXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff J.¶

Page IO of 22¶

Igor Zinoview Address Currently Unknown
Address Currently Unknown
Seth Lehrman 425 North Andrews Ave., Suite 2 Fort Lauderdale, FL 33301
Matt Weissing 425 North Andrews Ave., Suite 2 Fort Lauderdale, FL 33301
Maria Villafana 500 S. Australian Avenue, West Palm Beach, FL 3
Any additional indj Office and who supplied as it re entified as victims by the United States Attorney's were conveyed to Jeffrey Epstein as part of a list the NPA.
Leslie W imit Parkway C4t1 kus, Ohio 43206

Cos¶

79 dent Donald J. Trump Alan Garten, Esq. 5 Fifth Avenue New York, NY 10022¶

Larry Visoski 1131 Pine Point Road Riviera Beach, FL 33401
Mari tza Vasquez 1293 SW 215` Terrace Miami, FL 33145

Case No.: 502009CA040800XXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff [REDACTED] J. [REDACTED]
Page 11 of 22¶

Maximilia Cordero
c/o William Unroch, Esquire
140 West End, Apt. 30-BW
New York, NY 10023
[REDACTED]
c/o Spencer Kuvin
1800 S. Australian Avenue, #400
West Palm Beach, Florida 33409
[REDACTED]
[REDACTED]
[REDACTED]
c/o Robert C. Josefsberg, Esq.
Podhurst Orseck, PA
One S.E. 3^rd Avenue, Suite 2700
Miami, FL 33131
David Copperfield (David Seth Kokin)
11675 Glowing Sunset Lane
Las Vegas, NV 89135
[REDACTED]
Michael Fisten
Weston, FL
Russell Adler
Delray Beach, FL
Marie Alessi
6791 Fairway Lakes Dr.
Boynton Beach, FL 33472
Janusz Banasiak
358 El Brillo Way
Palm Beach, FL, 33480

ADV. EPSTEIN¶

Case No.: 502009CA040800XXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff¶

Page 12 of 22¶

Beata Banasiak 358 El Brillo Way Palm Beach, FL, 33480
Juan Alessi 6791 Fairway Lakes Dr. Boynton Beach, FL 33472
Michael 53320 Avenida Madero La Quinta, CA 92253
Jerry Goldsmith 13285 Silver Fox Lane West Palm Beach, FL 33418-7942
?s,
Valdson Cotrin Address Currently
, outh Africa

nn Dubin 040 5th Ave. Unit 15A New York, NY 10028-0137¶

Abigail Wexner Three Limited Parkway Columbus, Ohio 43206
Officer Munyan Palm Beach Police Department 345 South County Road

J.¶

COSA¶

Case No.: 502009CA040800XXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff¶

Page 13 of 22¶

Palm Beach, FL 33480¶

Officer Minot
Palm Beach Police Department
345 South County Road
Palm Beach, FL 33480
Sgt. Sorge
Palm Beach Police Department
345 South County Road
Palm Beach, FL 33480
[REDACTED]
Address Currently Unknown
[REDACTED] Pagnano
1217 S Flagler Drive, Suite 301
West Palm Beach, FL 33401
Stephan Kosslyn
28 Garfield Street
Cambridge, [REDACTED] 02138-1802
Cecile Dejongh
23 S Estate Mafolie
St. [REDACTED] VI 00802
Tommy Mottola
302 Caribbean Road
Palm Beach, FL 33480-3012
Mike Sanka
449 S Beverly Drive, Suite 101
Beverly Hills, CA 90212
[REDACTED]
William "Bill" [REDACTED]
5645 Coral Ridge Drive # 391
Coral Springs, FL 33076

Case No.: 502009CA040800XXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff¶

Page 14 of 22¶

Howard Rubenstein
1345 Avenue of the Americas
New York, NY 10105
Robert Meister
101 Seminole Ave.
Palm Beach, FL 33480
Todd Meister
101 Seminole Ave
Palm Beach, FL 33480
President William J. Clinton
William Hammond
2965 Fontana Place
[REDACTED] Palm Beach, FL
Robert Roxburgh
5600 North Flagler Dr, #250
West Palm Beach, Florida
Michele Pagan
Palm Beach Police Department
345 South County Road
Palm Beach, FL 33480
Michele Dawson
Palm Beach Police Department
345 South County Road
Palm Beach, FL 33480
Amy Fortimer
12309 North Old Country Road
Wellington, FL 33414
[REDACTED]

Case No.: 502009CA040800XXXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff [REDACTED] J. [REDACTED]¶

Page 15 of 22¶

[REDACTED]
[REDACTED]
[REDACTED]
Latasha Lowe
c/o Adam Horowitz.
Horowitz Law
425 North Andrews Avenue, Suite 2
Fort Lauderdale FL 33301
[REDACTED]
Zack Bryan
1150 Larch Way
Wellington, Florida
[REDACTED]
Larry Morrison
11148 Cobblefield Dr..
Wellington, FL 33449
Story Cowles
801 S Olive Ave., Unit 201S
West Palm Beach, FL 33401
Michael Dawson
Palm Beach Police Department
345 South County Road
Palm Beach, FL 33480

ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 16 of 22¶

1. Salaam Kahlid Monroe 119 Menores Ave., Apt. 3 Coral Gables, FL 33134
1. Jelitza Negrette 503 Chandlers Warf Portland, ME 04101
1. Sergia Cordero 825 Brickell Bay Drive, #1141 Miami, FL 33131
1. Cassandra Rivera 5011 El Clam Circle West Palm Beach, FL 33415
1. Randee Speciale Palm Beach Victim Services 205 North Dixie Highway, # West Palm Beach, FL 3
1. Steven H. enberg Address C q, Unknown
1. Mi6110eI Stroll urrently Unknown
1. glas Shoettle 43 Riverside, Dr. New York, NY 10025
1. Ghislaine Maxwell Address Currently Unknown
1. Amazon Records Custodian
1. Yellow Cab Records Custodian

elnW. EPSTEIN 009CA040800XXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff a. a¶

Page 17 of 22¶

1. Citrix Systems, Inc. Records Custodian
1. Federal Bureau of Investigation Records Custodian
1. Milton Girls Juvenile Facility Records Custodian 5770 East Milton Road Milton, FL
1. School District of Palm Beach County Records Custodian O 'S A 3344 Forest .1 13lvd., Suite C-I24 West Palm Beac, FL 33406 C.)
1. St. Mary's Medical Center Records Custodian 901 45th Street West Palm Beach, FL 33401
1. Wellington Re inal Hospital Reco Wellington, FL 414 s,,, 4 10104 Forrest Blvd.
1. All witnesses that Defer hav listed on their Witness List not objected to by Plaintiff
1. All rebuttal wi
1. All Peopl n Jeffrey Epstein's Inmate Visitor Log while he was in jail.

WJ ES TESTIMONY EXPECTED TO BE PRESENTED BY MEANS OF DEPOSITION¶

1. Epstein andam Street ew York, NY 10013 1" 1.1 1 .L iascl• 358E n o ay Palm Beach, FL 33480
1. Alfredo Rodriguez

DV. EPSTEIN No.: t009CA040800:OOCXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff M. Page 18 of 22¶

do Federal Public Defender or Bureau of Prisons 11349 SW 86TH Lane Miami, FL
¶

1. Scott Rothstein do Mark Nurik One East Broward Boulevard, Suite 700 Fort Lauderdale, Florida 33301
1. Jeffrey Epstein
1. Horowitz Law do Adam Horo witz. 425 Noth Andrews Avenue, Suite 2 \ Fort Lauderdale FL 33301 EXPER"SSSES
1. Bernard J. Jansen, Ph.D do Jack Scarola Searcy Denney Sc art & Shipley 2139 Palm Beac lvd. West Palm Beac 3409

CO¶

The followin witn are attorneys that are not retained or specially employed to provide expert to ny, b t may provide opinions relating to the propriety of Brad Edward's conduct of di t he prosecution of the Epstein claims.¶

162.N scert C. Josefsberg, Esquire odhurst Orseck, PA One S.E. rd Avenue, Suite 2700 Miami, FL 33131
1. Charles Lichtman, Esquire Berger Singerman 300 East Las Olas Boulevard, Suite 1000 Ft. Lauderdale, FL 33301
1. Isidro M. Esquire Law Firm, P.A. 224 Datum Street, Suite 900 West Palm Beach, FL, 33401
1. Earleen Cote, Esquire S ue 1600 Kubicki Draper One East Broward Boul Fort Lauderdale, FL
1. William Berger, Weiss, Handler, I, P.A. 2255 Gla Road, uite 218A Boca Rato 33431
1. Spencer Kuvin, Esquire 1800 S. Australian Avenue, #400 West Palm Beach, Florida 33409
1. Theodore Leopold, Esquire Milstein 2925 PGA Boulevard, Suite 200 A(Iptc Palm Beach Gardens, Florida 33410
1. Adam Horowitz, Esquire 425 N. Andrews Ave., Suite 2 Ft. Lauderdale, FL 33301 "S C)

Plaintiff reserves 44 ght / to amend this list.¶

l ADV. EPSTEIN¶

Case No.: 502009CA040800XXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff M.¶

Page 19 of 22¶

O '¶

Case No.: 502009CA040800XXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counter-Plaintiff [REDACTED] J. [REDACTED]¶

Page 20 of 22¶

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 GPR day of November, 2017.¶

JACK SCAROLA¶

Florida Bar No.: 169440¶

Attorney E-Mail(s): jsx@searcylaw.com and mep@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]¶

Case No.: 502009CA040800XXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counterplaintiff¶

Page 21 of 22¶

COUNSEL LIST¶

Jack Scarola, Esquire
scarolateam@searcylaw.com;
Searcy Denney Scarola Barnhart & Shipley PA
2139 Palm Beach Lakes Boulevard
West Palm Beach, FL 33409
Phone: (561) 686-6300
Fax: (561) 383-9451
Attorneys for [REDACTED] J. [REDACTED]¶

Scott J. Link, Esq.
Link & Rockenbach, P.A.
Scott@linkrocklaw.com
Kara@linkrocklaw.com
1555 Palm Beach Lakes Boulevard, Suite 301
West Palm Beach, FL 33401
Phone: 561-727-3600
Fax: 561-727-3601
Attorneys for Jeffrey Epstein¶

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¶

ADV. EPSTEIN¶

Case No.: 502009CA040800XXXXMBAG¶

Seventh Amended and Supplemental Witness List of Counterplaintiff J.¶

Page 22 of 22¶

J. M, Esquire¶

staff efile@pathtojusticomn¶

Jaffe Weissing Fistos & Lehrman, P.L.¶

425 N Andrews Avenue, Suite 2¶

Fort Lauderdale, FL 33301¶

Phone: (954)-524-2820¶

Fax: (954)-524-2822 A"' CO 'S Attorneys for Jeffrey Epstein I.S 5) ? ' Fort Lauderdale, FL 33301 S Attorneys for Scott Rothstein C¶

Tonja Haddad Coleman, Esquire¶

tonja@tonjahaddad.com; efiling@tonjahaddad.com ¶

Tonja Haddad, P.A.¶

315 SE 7th Street, Suite 301¶

Fax: (954)-337-3716¶

Fort Lauderdale, FL 33301¶

Phone: (954)467-1223¶

Marc S. Nurik, Esquire¶

marc@nuriklaw.com ¶

One E Broward Blvd., Suite 700¶

Phone: (954)-745-5849¶

Fax: (954)-745-3556¶