EFTA01112400.pdf

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 L.M., individually, Defendant(s). MOTION FOR PROTECTIVE ORDER BRADLEY EDWARDS, by and through his undersigned attorneys, move this Honorable Court for the entry of an Order of Protection limiting the production required in response to the attached Amended Notice of Taking Deposition Duces Tecum on the grounds that production requested is overly broad, irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence, and is unnecessarily intrusive into the financial privacy of BRADLEY EDWARDS. 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 day of C •-• Jack Sczarola Florida Bar No.: 169440 fimary E-mail: /S econdary E-mail(s): Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorneys for BRADLEY J. EDWARDS EFTA01112400 Edwards adv. Epstein Case No.: 502009CA040800XX30CMBAG Motion for Protective Order COUNSEL LIST Jack A. Goldberger, E utre Fort Lauderdale, FL 33394 PFax:hon' Atterbury, Goldberger & Weiss, P.A. Attorneys for Jeffrey Epstein 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Marc S. ire Phon Fax: Law Offices of Marc S. Nurik Attorneys for Jeffrey Epstein One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Phon Fax: Farmer, Jaffe, Weissing, Edwards, Fistos & S M. Attorneys for Scott Rothstein Lehrman, FL Ton'a Haddad Coleman, Esquire 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Tonja Haddad, P.A. F Pahx°:n1.111. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Fred Haddad, Es uire Phon • Fax: Attorneys ore ey Epstein Fred Haddad, P.A. One Financial Plaza, Suite 2612 EFTA01112401 JEFFREY EPSTEIN, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN Plaintiff, AND FOR PALM BEACH COUNTY, FLORIDA vs. SCOTT ROTHSTEIN, individually, CASE NO.: 502009CA040800XXXXMBAG and BRADLEY J. EDWARDS, individually. JUDGE: CROW Defendants. AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM (VIDEOTAPED) PLEASE TAKE NOTICE that Pursuant to Rule 1.410 of the Florida Rules of Civil Procedure, the undersigned attorney will take the deposition of Defendant/Counter-Plaintiff Bradley J. Edwards on Wednesday, May 15, 2013 at 10:00AM at Empire Legal Support, Inc., 401 East Las Olas Boulevard, Suite 1400, Fort Lauderdale, FL 33301, upon oral examination before Empire Legal Support, Notaries Public, or any other notary public or officer authorized by law to take depositions in the state of Florida. The oral examination will continue all day and day to day thereafter until completed. This deposition is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the rules of Court. If you fail to appear, you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. This includes bringing with you the documents listed in "Schedule A" attached hereto. We hereby certify that this date was coordinated with opposing counsel, and that a true and correct copy of this amended notice was served upon all parties listed in the service list below, via Electronic Service, this April 23, 2013. EFTA01112402 /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Sired Suite 301 Fort Lauderdale, Florida 33301 (facsimile) EFTA01112403  SCHEDULE A (To Bring With You For Deposition) 1. Copies of income tax returns for the past five (5) calendar years of the Defendant/Counter-Plaintiff Bradley J. Edwards (hereinafter "Edwards") (2007-2012). 2. Income tax records for the current tax year, and copies of any estimated income tax returns filed for the current year for Edwards. 3. Copies of income tax returns, distributions, schedule K-1, and any and all other documents related to the gross income for the past four (4) calendar years of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 4. Copies of all documentation related to all settlements, attorneys' fees awards, jury verdict awards, and arbitration/mediation income received by Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., and/or Bradley J. Edwards, PA. 5. Income tax records for the current tax year, and copies of any estimated income tax returns filed for the current year for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 6. A copy of Edwards's (or Bradley J. Edwards, PA's) partnership agreement with Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 7. Copies of any and all memoranda, diaries, journals, appointment books, calendars, electronic mails, notes, correspondence, or other documents upon which you rely in support of your allegation of lost income/value of time diverted from your professional responsibilities as alleged in your Counterclaim. 8. Copies of any and all memoranda, diaries, journals, appointment books, calendars, electronic mails, notes, correspondence, or other documents upon which you rely in support of your allegation of injury to your reputation as alleged in your Counterclaim. 9. Copies of any and all receipts, reports, invoices, or other documents evidencing treatment for your mental anguish, embarrassment, and anxiety as alleged in your Counterclaim. 10. Copies of any and all receipts, reports, or invoices evidencing lost income suffered as a result of your mental anguish, embarrassment, and anxiety as alleged in your Counterclaim. 11. Copies of any and all memoranda, diaries, journals, appointment books, calendars, electronic mails, notes, correspondence or other documents upon which you rely in support of your claim for Punitive Damages. EFTA01112404  12. Copies of any and all documents you intend to introduce at trial in support of the allegations made by you in your Fourth Amended Counterclaim you filed in this matter. EFTA01112405  SERVICE LIST CASE NO. 502009CA0408003OOOOvEBAG Jack Scarola, Esq. Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. 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 EFTA01112406