EFTA01107603.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT EPSTEIN'S AMENDED RESPONSES TO INTERROGATORIES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to this Court's order and Rule 1.350 of the Florida Rules of Civil Procedure, hereby files his amended' responses to Defendant/Counter-Plaintiff Bradley Edward's Interrogatories to Jeffrey Epstein as follows: A. With regard to all communications that occurred at any time prior to the filing of your civil lawsuit against Bradley Edwards in which communication you expressed the position that Bradley Edwards was a knowing participant in the efforts of Scott Rothstein to defraud investors (the Scott Rothstein Ponzi scheme) or that Bradley Edwards engaged in any misconduct relating to the Scott Rothstein Ponzi scheme, state the following: 1. a detailed description of the contents of the communication; 2. all participants in and parties to the communication; I As per the trial court's order and pending hearing, Epstein is not responding as to any communication that may have occurred with counsel. EFTA01107603  3. the date, time, place and circumstances of the communication including how the communication was made; 4. whether, when, how and why the contents of the communication were ever subsequently related to any other person; 5. whether and how the contents of the communication were ever memorialized in any manner and, if so, the identity of everyone having custody of such memorialization. ANSWER: No such non-privileged communication occurred. In other words, I never had any conversation regarding the propriety of filing suit against Rothstein and Edwards with anyone other than my counsel(s), which would require the disclosure of information that is protected by the attorney/client privilege. United Services Auto. Ass'n. v. Roth, 859 So. 2d 1270, 1271 (Fla. 4th DCA 2003); Nevin v. Palm Beach County School Bd., 958 So. 2d 1003 (Fla. 1st DCA 2007). Accordingly, I assert the attorney/client privilege as provided for in § 90.502 of the Florida Statutes. B. With regard to any request, direction, or authorization to sue Bradley Edwards communicated by you at any time prior to the filing of your civil lawsuit against Bradley Edwards, state the following: 1. a detailed description of the contents of the communication; 2. all participants in and parties to the communication; 3. the date, time, place and circumstances of the communication including how the communication was made; 4. whether, when, how and why the contents of the communication were ever subsequently related to any other person; 5. whether and how the contents of the communication were ever memorialized in any manner and, if so, the identity of everyone having custody of such memorialization. ANSWER: No such non-privileged communication occurred. In other words, I never had a EFTA01107604 conversation as delineated above with anyone other than my counsel(s), which would require the disclosure of information that is protected by the attorney/client privilege. United Services Auto. Ass'n. v. Roth, 859 So. 2d 1270, 1271 (Fla. 4th DCA 2003); Nevin v. Palm Beach County School Bd., 958 So. 2d 1003 (Fla. 1st DCA 2007). Accordingly, I assert the attorney/client privilege as provided for in § 90.502 of the Florida Statutes. WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this November 5, 2013. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONIA HADDAD, PA 315 SE Th Street Suite 301 Fort Lauderdale Florida 33301 EFTA01107605  JEFFREY EPSTEIN STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) Before me, the undersigned authority, this day personally appeared Jeffrey Epstein, who produced as Identification, and who first being duly sworn, says that he has read the foregoing, and that all of the matters are true and correct, this November , 2013. NOTARY PUBLIC, STATE OF FLORIDA Sworn and Subscribed before me this EFTA01107606  SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Esq. 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Ton'a Haddad Coleman, E uire Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein W. Chester Brewer, Jr. One Clearlake Center Suite 1400 250 Australian Avenue South West Palm Beach, Florida 33401 EFTA01107607