Draft: efta02763776

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

CASE NO.: 502009CA040800)COOMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff/Counterdefendant,¶

VS.¶

J.¶

Defendant/Counterplaintiff.¶

NOTICE OF TAKING VIDEO¶

4\ TO: All counsel on the attached Counsel List¶

PLEASE TAKE NOTICE that the undersign attorneys will take the Duces Tecum video deposition of:¶

NAME AND ADDRESS DATE AND TIME LOCATION¶

C. Culver = III January 24, 2018 at 10:00 a.m.¶

Link & Rockenbach, P.A. 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, FL 33401 Phone: (561)-727-3600¶

*DUCES TECUM: TO HAVE AND BRING WITH YOU AT THE TIME OF THE DEPOSITION THE FOLLOWING:¶

SCHEDULE "A" DUCES TECUM¶

adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Taking Video Deposition DT¶

In compliance with Florida Rule of Civil Procedure 1.280(b)(4) (1997) and the Florida Supreme Court's decision in Elkins v. Syken 672 So. 2d 517 (Fla. 1966), we request that you bring with you to your deposition the following items if they exist:¶

• 1. Any and all data, documents, papers, photographs, filing, video tapes, memoranda or other writings prepared by you pursuant to your employment in this case.
  • 2. All photographs viewed and/or taken by or for you in connectio A64. 't11*s case.
• 3. Copies of all statements, written or recorded, which connection with this case. examined in
• 4. All published professional standards or guidelines us ca) referred to by you in formulating your opinion in connection with this case. 5 All professional literature, treatises, to;tlfQg2s pTother publications which you regard as authoritative in connection with this case.
• 6. Copies of all published articles three (3) years, or drafts of speeches given b opinion in this case. or contributed to by you within the past the past three (3) years, which affect your
• 7. Copies of any publi al Jes written by others on which you have relied that affect your opinion in this case.
• 8. Copies of any tr its of testimony, if available, given in other cases in which you have testified (either deposition or trial) in the past two years.
• 9. attorney. Copes of any reports prepared by you and furnished to the defendant or his
• 10. O y 'dr rawings, graphs, charts, illustrations or plans prepared by you in connection with this.ma r.
• 11. Copies of any and all notes, calculations or other data prepared by you in formulating your opinion in connection with this case.
• 12. Any professional publications, treatises, textbooks or other publications which you have examined in formulating your opinion in connection with this case.
• 13. Office records indicating time spent on your undertaking and hourly charges therefore in connection with this case.
• 14. Reports of any other experts which you have read.
• 15. Any published monograms, treatises, manuals, textbooks or other documents used as a reference by you in connection with this case.
• 16. Copies of any correspondence between you or your office and 1 for the defendants, including but not limited to written letters, a hard copy of d I e-mail communication by and among you and counsel for Defendant and an b the counsel's representatives including secretaries, paralegals and legal assistants, as we i h d copy of any e-mail communication between you and any other health care professional ding this matter.
• 17. Copies of any correspondence written by you or received from others with whom you have consulted in connection with this case, including but not limited to a hard copy of any and all e-mail communications.
• 18. Any memoranda reviewed which the--attorney/engaging you, an investigator, a paralegal, or an adjuster in connection with this case prepared.
• 19. Any other document or writing of any kind or description which you have viewed in formulating your conclusion in cone c whk.this case.
• 20. Any and all charts, diaitrt yoverlays, graphs, photographic enlargements or other demonstrative aids prepared or to be used by you at trial or in aid of your opinions and/or testimony.
  • 21. A copy of your current curriculum vitae.
• 22. An *proximation of the portion of your professional time and/or work devoted to service as an expert for defendant during the past three years. This estimate should be based on

• (1) hours expended, (2) income earned, or (3) the approximate number of examinations performed annually. 23\ All lists of cases in which you have testified as an expert at trial or in deposition which you compiled pursuant to Federal Rule of Civil Procedure 26, any similar state rule, or any court order.

adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Taking Video Deposition DT¶

AND any and all materials that you have reviewed in preparation for your testimony.¶

upon oral examination before Palm Beach Reporting, a Notary Public; or any other officer authorized by law to take depositions in the State of Florida. The oral examination is being taken for the purpose of discovery, for uses at trial, or for such other purposes as are perraed under the OIS applicable Statutes or Rules.¶

*"Documents" shall include, but not be limited to all non-i Cts *dal copies of writings, drawings, graphs, charts, photographs, phono-recordsy di gs, and/or any other data KV\ compilations from which information can be obtained ed, if necessary, by the party to whom the request is directed through detection d cescutto reasonably usable form. "Documents" also include all electronic data as well as lication metadata and system metadata. All inventories and rosters of your informatio ology (IT) systems—e.g., hardware, software and data, including but not limited to ne fork drawings, lists of computing devices (servers, PCs, laptops, PDAs, cell phon et with ir data storage and/or transmission features), programs, data maps and security tools p\d prot Is.¶

[REDACTED] adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Notice of Taking Video Deposition DT¶

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 9th day of JANUARY, 2018.¶

JACK SCAROLA
Florida Bar No.: 169440
Attorney E-Mail: jsx@searcylaw.com; and
mmccann@searcylaw.com
Primary E-Mail: scarolateam@searcylaw.com
Searcy Denney Scarola Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone: (561) 686-6300
Fax: 561-383-9451
Attorneys for [REDACTED] J. [REDACTED]¶

cc: Palm Beach Reporting, Inc. (court reporter)
Above & Beyond Reprographics, Inc. (videographer)¶

E-TRANSCRIPT, ASCII, CD AND/OR DVD REQUESTED¶

[REDACTED] adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Notice of Taking Video Deposition DT¶

COUNSEL LIST¶

[REDACTED] J. [REDACTED], Esquire
staff.efile@pathtojustice.com
425 N Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301
Phone: (954)-524-2820
Fax: (954)-524-2822¶

Jack A. Goldberger, Esquire
jgoldberger@agwpa.com; smahoney@agwpa.com
Atterbury Goldberger & Weiss, P.A.
250 Australian Avenue S, Suite 1400
West Palm Beach, FL 33401
Phone: (561)-659-8300
Fax: (561)-835-8691
Attorneys for Jeffrey Epstein¶

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

[REDACTED] Berard Rockenbach, Esquire
kara@linkrocklaw.com; tbermudez@flacivillaw.com
Link & Rockenbach, P.A.
1555 Palm Beach Lakes Blvd., Suite 301
West Palm Beach, FL 33409
Phone: (561)-727-3600
Fax: (561)-727-3601
Attorneys for Jeffrey Epstein¶

Scott J. Link, Esquire
Scott@linkrocklaw.com; Tina@linkrocklaw.com
Scott J. Link, Esquire
Eservice@linkrocklaw.com; Scott@linkrocklaw.com; Kara@linkrocklaw.com;
Angela@linkrocklaw.com; Tanya@linkrocklaw.com; tina@linkrocklaw.com¶

adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Taking Video Deposition DT¶

Link & Rockenbach, P.A. 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, FL 33401 Phone: (561)-727-3600 Fax: (561)-727-3601 Attorneys for Jeffrey Epstein¶

Marc S. Nurik, Esquire marc@nuriklaw.com One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein¶

A g¶

"If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Americans with Disabilities Act Coordinator at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711."¶

"Si usted es una persona minusvalida que necesita algun acomodamiento pan poder participar en este procedimiento, usted tiene derecho, sin tener gastos propios, a que se le provea cierta ayuda. Tenga la amabilidad de ponerse en contacto con Americans with Disabilities Act Coordinator por lo menos 7 dias antes de la cita fijada pan su comparecencia en los tribunales, o inmediatamente despues de recibir esta notificacion si el tiempo antes de la comparecencia que se ha programado es menos de 7 dias; si usted tiene discapacitacion del oido o de Itvoz, flame al 711."¶

"Si ou se yon moun ki enfim ki bezwen akomodasfon4ou1v ka patisipe nan pwosedi sa, ou kalifye san ou pa gen okenn lajan pou w peye, gen pwovizyon pou jwen kek ed. Tanpri kontakte Americans with Disabilities Act Coordinator nan 7 jou anvan dat ou gen randevou pou park nan tribinal la, oubyen imedyatman apre ou fin resevwa konvokasyon an si le ou gen pou w parlt nan tribinal la mwens ke 7 jou; si ou gen pwoblem pou w tande oubyen pale < claire ele 74."¶