EFTA00808629.pdf

Filing # 62456833 E-Filed 10/05/2017 02:26:33 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and ■1.,individually, Defendant(s). RESPONSE TO PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S REQUEST FOR PRODUCTION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS Bradley J. Edwards, by and through his undersigned attorneys and pursuant to Rule 1.350, Florida Rules of Civil Procedure, hereby responds to Jeffrey Epstein's, Request for Production dated September 5, 2017 as follows: 1. Objection. Attorney work product. 2. Objection. The reference to "the period in question" is undefined, vague and ambiguous; the request is overly broad and seeks information that is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence; information requested includes attorney work product; attorney-client privileged information, and information protected by rights to financial privacy. 3. Objection. The request is overly broad and seeks information that is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence; information requested includes attorney work product; attorney-client privileged information, and information protected by rights to financial privacy. EFTA00808629 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Response to Epstein's Request for Production served 9.5.17 4. Objection. The request is overly broad and seeks information that is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence; information requested includes attorney work product; attorney-client privileged information, and information protected by rights to financial privacy. 5. Objection. The request is overly broad and seeks information that is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence; information requested includes attorney work product; attorney-client privileged information, and information protected by rights to financial privacy. 6. Objection. The request is overly broad and seeks information that is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence; information requested includes attorney work product; attorney-client privileged information, and information protected by rights to financial privacy. 7. Objection. The request is overly broad and seeks information that is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence; information requested includes attorney work product; attorney-client privileged information, and information protected by rights to financial privacy. 8. Objection. The request is overly broad and seeks information that is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence; information requested includes attorney work product; attorney-client privileged information, and information protected by rights to financial privacy. 2 EFTA00808630 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Response to Epstein's Request for Production served 9.5.17 9. Objection. The request is overly broad and seeks information that is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence; information requested includes attorney work product; attorney-client privileged information, and information protected by rights to financial privacy. 10. Objection. The request is overly broad and seeks information that is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence; information requested includes attorney work product; attorney-client privileged information, and information protected by rights to financial privacy. 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 imary E-Mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorneys for Bradley J. Edwards 3 EFTA00808631 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Response to Epstein's Request for Production served 9.5.17 COUNSEL LIST William Chester BrewerEsquire Tonia Haddad Coleman, Esquire • R5 i Australian Avenue, Suite 1400 West Palm Beach, FL 33401 Tonja Haddad, Pho 315 SE 7th Street, Suite 301 Fax: Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein Phon Fax: Jack A. Goldberger, Esquire Attorneys for Jeffrey Epstein Marc S. Esquire Atterbury Goldberger & Weiss, E. 250 Australian Avenue S, Suite 1400 One E Broward Blvd., Suite 700 West Palm Beach, FL 33401 Fort Lauderdale, FL 33301 Phon Pho Fax: Fax: Attorneys for Jeffrey Epstein Attorneys for Scott Rothstein Bradle J. ward E kire Fanner Jaffe Weissing Edwards Fistos & Lehrman, E. 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Pho Fax: Fred Haddad, Fred Haddad, One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Pho Fax: Attorneys for Jeffrey Epstein 4 EFTA00808632