EFTA01081084.pdf

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla.R.Civ.Pro. 1.201 Case No. 502009CA040800XMMBAG Plaintiff, v. SCOTT ROTHSTEIN, Individually, BRADLEY J. EDWARDS, Individually, and L.M., Individually Defendants. PLAINTIFF, JEFFREY EPSTEIN'S NOTICE OF SERVING ANSWERS TO DEFENDANT, BRADLEY J. EDWARDS' EXPERT INTERROGATORIES AND REOUEST TO PRODUCE EXPERT REPORTS DATED NOVEMBER 22, 2010 Plaintiff, Jeffrey Epstein, by and through his undersigned counsel, and pursuant to Rule 1.340(e) Florida Rules of Civil Procedure, files this his Notice of Serving Answers to Defendant, Bradley J. Edwards' Expert Interrogatories numbered 1 through 13 and Request to Produce Expert Reports numbered 14-16 bearing certificate of service date of November 22, 2010. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a trusdnd correct copy of the foregoing has been duly furnished via O Email, O Facsimile, e U.S. Mail, O Hand Delivery, O Federal Express this 26 day of , 2010 to: Jack Scarola, Esq. Searc Deane Scarola Barnhart & Shipley, P.A West Palm Beach, FL 33409 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. West Palm Beach, FL 33401-5012 EFTA01081084  Epstein v. Rothstein, et al. 2 Case No. 50 2009 CA 040800XXXXMBAG Epstein's Ans to Edws' Exp Interrog and RTP Esp Reports 11-22-2010 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik Ft. Lauderdale, FL 33301 By: - (1-4,,, Jo h L. Ackerman, Jr. Fla. Bar No. 235954 FOWLER WHITE BURNETT P.A. West Palm Beac Florida 33401 Tele hone: Attorneysfor Jeffrey Epstein, Plaint j Counter-defendant EFTA01081085  Epstein v. Rothstein, et al. 3 Case No. 50 2009 CA 0408003OOCXMBAG Epstein's Ans to Edws' Eap Interrog and RTP Eap Reports 11-22-2010 EPSTEIN'S ANSWERS TO EDWARDS EXPERT INTERROGATORIES 1. State the name, address and profession of each person whom you expect to call as an Expert witness at trial or for any other purposes in this cause. Answer: We have not retained any experts at this time. 2. With regard to each listed above, state his/her background, education and experience which qualify him/her to testify as an expert in his/her area of expertise; and/or in lien thereof, please provide a copy of each expert's most recent curriculum vitae. Answer: Not applicable. 3. Give the name or title of each paper which each expert has authored in the field of his/her expertise. Answer: Not applicable. 4. State the name, volume and page number of the publication in which each article or paper listed above can be found. Answer: Not applicable. 5. State the substance of the facts to which each expert listed is expected to testify. Answer: Not applicable. 6. Give a complete list of all documents, depositions, exhibits, plans, drawings, ordinances or statutes which each expert has used in basing his/her opinion. Answer: Not applicable. 7. State the opinion to which the experts aforementioned are expected to testify. Answer: Not applicable. 8. Give a summary of the grounds of each opinion stated. Answer: Not applicable. 9. Has the expert listed above practiced or worked in his/her field during the past five years? Answer: Not applicable. EFTA01081086  Epstein v. Rothstein, et al. 4 Case No. 50 2009 CA 040800VOCKMBAG Epstein's Ans to Edws' Exp Interrog and RTP Exp Reports 11-22-2010 10. If so, please state: a. Whether the expert was self-employed, employed by someone else or associated as a partner. b. Each address where the expert practiced or was employed. c. The dates the expert was with each employer. d. The type of duty the expert performed with each employer. Answer: Not applicable. 11. If the expert was not practiced or worked in his/her field during the last five years, what was his/her employment during this time? Answer: Not applicable. 12. Did the expert submit a report setting forth his/her opinions or conclusions reached from his/her examination or any tests he/she conducted? a. If so, state the date the report was submitted. b. The name or other means of identification of the person to whom this report was submitted. c. The name and address of the person who has present custody of the report. Answer: Not applicable 13. Did the expert submit any other reports based upon tests, examinations or analysis of documents that he/she conducted in which he/she did not render an opinion? a. If so, state description of each report that was made. b. the date that each report was made. c. The name or other means of identification of the person to whom each report was submitted. d. The name and address of the person who has present custody of said report. Answer: Not applicable. EPSTEIN'S RESPONSE TO REQUEST TO PRODUCE EXPERT REPORTS 14. Attach a copy of any reports made by each expert on the basis of his/her tests, examinations or analyses to your answers to these Interrogatories. Answer: Not applicable. 15. Is the expert to be compensated for his/her work and efforts in connection with this action? EFTA01081087  Epstein v. Rothstein, et al. 5 Case No. 50 2009 CA 040800XXXXMBAC Epstein's Ans to Edws' Exp Interrog and RTP Exp Reports 11-22-2010 a. If so. How much is the expert to be paid? b. If the expert has been paid, then give the basis for payment, such as hourly rate, weekly rate, etc. Answer: Not applicable. 16. Has the expert served as an expert witness in any other litigated case in the past three years? a. The style of the case, the Court in which it was filed and the names and addresses of the attorneys involved. b. Whether the expert testified for the Plaintiff or Defendant. c. the area or field in which the expert held himself/herself out to be an expert. Answer: Not applicable. 2 oseph 6-421L. Ackerman, Jr. As Attorney-In-Fact State of Florida County of Palm Beach) r of December, 2010 The foregoing instrument was acknowledged before me thi0 7/ day by Joseph L. Ackerman, Jr., who is personally to me or who-has-produced N/A as identification and who did did/not take an oath. (SEAL) // 14 Idd g°&- Signature) /Li angdoc (Print Notary Name) Notary Public, State of 17,6ebag 4 12% WA DAVIDSON (Serial Number, if any) tVatt i DORM %n or Bat letatlizi it 2014 n sake EFTA01081088 14:48 NOV 22. 2010 FAX NO: 1234567 467493 PAGE: 2/11 #291874/mep IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003OOOCMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). NOTICE OF PROPOUNDING EXPERT INTERROGATORIES TO PLAINTEFF/CO'UNTERDEFENDANT, JEFFREY EPSTEIN Defendant/Counterplaintiff, Bradley J. Edwards, hereby gives notice that pursuant to Rule 1.340(e), Florida Rules of Civil Procedure, Expert Interrogatories numbered 1 through 16 have been directed to Plaintiff/Counterdefendant, Jeffrey Epstein, this a Ail day of qb,temovA. , 2010. I HEREBY CERTIFY that a true and correct copy of the foregoing has been Runished by Fax and U.S. Mail to all Counsel on the attached list on this 00 day of A.20411taffi;'— 2010. Attorney for Bradley I. Edwards EFTA01081089 14:41 NOV 22, 2010 FAX NO: 1234567 467493 PAGE: 3/11 Edwards adv. Epstein Case No.: 502009CA040800XXXXIABAG Expert Interrogatories To Jeffrey Epstein COUNSEL LIST Jack A. Goldberger, Esquire iliaiggiNi At ss aP.A. Palm Beac FL 33401 Attorneys for Jeffrey Epstein Gary M. Farmer, Esq. Farmer. Jaffe. * in Edwards, Fistos & Lehrman, PL Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. White BurnettP.A. Attorneys for Jeffrey Epstein Marc S. Nurik, Esq. Offices of Marc S. Nurik Attorneys for Scott Rothstein EFTA01081090 • 14:42 N0V 22, 2010 FAX NO: 1234567 467493 PAGE: 4/11 Edwards adv. Epstein Case No.: 502009CA040800)OOO0BAG Eicpert Interrogatories To Jeffrey Epstein EXPERT INTERROGATORIES TO JEFREY EPSTEIN 1. State the name, address and profession of each person whom you expect to call as an expert witness at trial or for any other purposes in this cause. 2. With regard to each listed above, state his/her background, education and experience which qualify him/her to testify as an expert in his/her area of expertise; and/or in lieu thereof, please provide a copy of each expert's most recent curriculum vitae. 3. Give the name or title of each paper which each expert has authored in the field of his/her expertise. EFTA01081091 14:43 43V 22. 2010 FAX I43: 1234567 467493 PAGE: 5/11 Edwards adv. Epstein Case No.: 502009CA04080DXX?CCMBAG Expert Interrogatories To Jeffrey Epstein 4. State the name, volume and page number of the publication in which each article or paper listed above can be found. 5. State the substance of the facts to which each expert listed is expected to testify. 6. Give a complete list of all documents, depositions, exhibits, plans, drawings, ordinances or statutes which each expert has used in basing his/her opinion. EFTA01081092 ' 14:44 NOV 22. 2010 FAX NO: 1234567 467493 PAGE: 6/11 Edwards adv. Epstein Case No.: 502009CA040800XXSOCIABAG Expert Interrogatories To Jeffrey Epstein 7. State the opinion to which the experts aforementioned are expected to testify. 8. Give a summary of the grounds of each opinion stated. 9. Has the expert listed above practiced or worked in his/her field during the past five years? 10. If so, please state: a. Whether the expert was self-employed, employed by someone else or associated as a partner. b. Each address where the expert practiced or was employed. EFTA01081093 '• 14:45 NOV 22, 2010 FAX NO: 1234567 067493 PAGE: 7/11 Edwards adv. Epstein Case No.: 502009CA040800)CC(XMBAG Expert Interrogatories To Jeffrey Epstein c. The dates the expert was with each employer. d. The type of duty the expert performed with each employer. 11. If the expert has not practiced or worked in his/her field during the last five years, what was his/her employment during this time? 12. Did the expert submit a report setting forth his/her opinions or conclusions reached from his/her examination or any tests he/she conducted? a. If so, state the date the report was submitted. b. The name or other means of identification of the person to whom this report was submitted. c. The name and address of the person who has present custody of the report EFTA01081094 14:46 NOV 22. 2010 FAX NO: 1234567 467493 PAGE: 8111 Edwards adv. Epstein Case No.: 502009CA040800XXXXIvfBAG Expert Interrogatories To Jeffrey Epstein 13. Did the expert submit any other reports based upon tests, examinations or analyses of documents that he/she conducted in which he/she did not render an opinion? a. If so, state description of each report that was made. b. The date that each report was made. c. The name or other means of identification of the person to whom each report was submitted. d. The name and address of the person who has present custody of said report. EFTA01081095 .14:47 NOV 22, 2010 FAX ND: 1234567 067493 PAGE: 9/11 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Expert Intemsgatories To Jeffrey Epstein REQUEST TO PRODUCE EXPERT REPORTS 14. Attach a copy of any reports made by each expert on the basis of his/her tests, examinations or analyses to your answers to these Interrogatories. 15. Is the expert to be compensated for his/her work and efforts in connection with this action? a. If so, how much is the expert to be paid? b. If the expert has been paid, then give the basis for payment, such as hourly rate, weekly rate, etc. EFTA01081096 14:47 NOV 22, 2010 FAX NO: 1234567 467493 PAGE: 10/11 Edwards adv. Epstein Case No.: 502009CA040800X}Ct7CMEA6 Expert Intarogatories To Jeffrey Epstein 16. Has the expert served as an expert witness in any other litigated case in the past three years? If so, state as to each case: a. The style of the case, the Court in which it was filed and the names and addresses of the attorneys involved. b. Whether the expert testified for the Plaintiff or Defendant. c. The area or field in which the expert held himself/herself out to be an expert. STATE OF COUNTY OF EFTA01081097 14:449 N0V 22. 2010 FAX NO: 1234567 *67493 PAGE: 11/11 Edwards adv. Epstein Case No.: 502009CA040800)OOOCMDAG Expert Interrogatories To Jeffrey Epstein The foregoing instrument was acknowledged before me this day of , 20 , by who is personally known to me or who has produced as identification and who did did/ not take an oath. (SEAL) (Notary signature) (Notary name - print) NOTARY PUBLIC, State of Florida (Serial number, if any) EFTA01081098