EFTA01100994.pdf

• IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG Pft JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant. DEFENDANT BRADLEY J. EDWARDS RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION DATED APRIL 12, 2010 Defendant, BRADLEY J. EDWARDS, hereby files his Response to Request for Production propounded by Plaintiff on April 12, 2010 as follows: 1. None. 2. a. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence. b. None. 3. Objection as to communications to or from investigators as that is protected by the work-product and /or attorney-client privilege. 4. Objection; any such communications are protected by the work-product and /or attorney-client privilege. 5. None. 6. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence; vague; overbroad, without waiving objection, there are no fee agreements with any investor. EFTA01100994 Case No.: 502009CA040800)0O0(MBAG Edwards' Response to Request for Production dated 4/12/10 7. None. 8. None. 9. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence. 10. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence. None. None. None. None. None. None. 17. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence; vague; overbroad, ambiguous. 18. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence. 19. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence and protected by the work-product privilege. 20. Objection, vague overbroad and any and all such documents are protected by the work-product privilege. 21. Objection, vague overbroad and any and all such documents are protected by the work-product and attorney-client privilege. 22. Not yet determined. 2 EFTA01100995 Case No: 502009CA040800XXXXIMBAG Edwards' Response to Request for Production dated 4/12/10 23. Objection. 24. Objection; attorney-client privilege and/or work-product privilege. 25. None in Defendant's possession. 26. None. 27. None In Defendant's possession. 3 EFTA01100996 Case No.: 502009CA040800)OOO(MBAG Edwards' Response to Request for Production dated 4/12/10 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been rei A-op How HI)-- furnished via U.S. Mail to all counsel on the attached list on Ap+" , 2010. Jack Scarola Searcy Denney Scarola Barnhart & Shipley, Attorneys for Defendant, Bradley Edwards 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: By: 4 EFTA01100997 Case No.: 502009CA040800XXXXMBAG Edwards' Response to Request for Production dated 4/12/10 COUNSEL LIST Robert D. Critton, Jr., Esquire Michael J. Pike, Esquire Burman, Critton, Luther & Coleman LLP 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 Phone: Fax: Attorneys for Jeffrey Epstein Jack Goldberger Atterbury, Goldberger & Weiss, PA. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401 Phone: Fax: Attorneys for Jeffrey Epstein Gary M. Farmer, Jr. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 Phone: Fax: Attorneys for L.M. Marc Nurik Law Offices of Marc S. Nurik One East Broward Boulevard, Suite 700 Fort Lauderdale, FL 33301 Phone: Fax: Counsel for Scott Rothstein EFTA01100998