EFTA01142065.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003OOOGABAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). NOTICE OF SERVICE OF INTERROGATORY TO JEFFREY EPSTEIN Bradley J. Edwards, hereby gives notice pursuant to Rule 1.340(e), Florida Rules of Civil Procedure, that an Interrogatory has been directed to Jeffrey Epstein, this Olay of August, 2013. It is requested that the aforesaid answers be served within thirty (30) days at the offices of Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409. 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 daiiifykugust, 2013. y l enney art & Shipley, P.A. 2139 Palm Beach Lakes Boulevard 3409 Attorneys for Bradley J. Edwards EFTA01142065 Edwards adv. Epstein Notice of Service of Interrogatory to Jeffrey Epstein Case No.: 502009CA040800300C(MBAG COUNSEL LIST Jack A. Goldberger, Esquire Fort Lauderdale, FL 33394 Atterbury, Goldberger & Weiss, P.A. Attorneys for Jeffrey Epstein 250 Australian Avenue South, Suite 1400 West Palm Beach FL 33401 w ces o arc . unk Attorneys for Jeffrey Epstein One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 armer, Jaffe, Weissing, s, Fistos & Attorneys for Scott Rothstein Lehrman, FL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Fred Haddad, P.A. Attorneys for Jeffrey Epstein One Financial Plaza, Suite 2612 EFTA01142066 Edwards adv. Epstein Notice of Service of Interrogatory to Jeffrey Epstein Case No.: 502009CA040800)OCOCMBAG INTERROGATORY TO JEFFREY EPSTEIN (If answering for another person or entity, answer with respect to that person or entity, unless otherwise stated.) 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; 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. 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; 2 EFTA01142067 Edwards adv. Epstein Notice of Service of Interrogatory to Jeffrey Epstein Case No.: 502009CA040800)OOOCMBAG 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. In the event that you claim that any responsive information sought by these interrogatories is privileged, identify every privilege pursuant to which you claim protection. STATE OF COUNTY OF 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) 3 EFTA01142068