744.pdf

NOT A CERTIFIED COPY JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. Electronically Filed 10/04/2013 05: 11 :23 PM ET IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50 2009 CA 040800:XXXXMBAG ________________ / NOTICE OF E-FILING EXHIBITS Plaintiff/Counter-Defendant Jeffrey Epstein, by and through his undersigned counsel and pursuant to Rule 2.516 of the Florida Rules of Judicial Administration, hereby files his exhibits to Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Summary Judgment on Defendant/Counter-Plaintiff Bradley Edwards's Fourth Amended Counterclaim and Supporting Memorandum of Law ("Motion"), previously filed and accepted by the Palm Beach County, Florida Civil Division Filing # 5846906. The files accompanying this Notice of Filing Exhibits were previously filed on September 26, 2013 and again on October 2, 2013, but moved to Pending Queue due to procedural issues. This filing is an attempt to correct those procedural issues. The attachment hereto contains the exhibits to the above referenced Motion, which is not being re-filed contemporaneously herewith. However, the exhibits are being divided based upon the filing requirements of the rules of e-filing; each new exhibit begins when so marked on the is so marked on the bottom of the first page of said exhibit. NOT A CERTIFIED COPY Epstein v. Rothstein, et al. WE HEREBY CERTIFY that a true and correct copy of the foregoing was served, via electronic service (through the e-file portal), to all parties on the attached service list, this October 3, 2013. 2 Isl Tonja Haddad Coleman Tonja Haddad Coleman, Esq. FloridaBarNo.: 176737 Tonja Haddad, PA 5315 SE 7 th Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimile) Attorneys for Epstein NOT A CERTIFIED COPY SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Esq. jsx@searcylaw.com; mep@searcylaw.com Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. jgoldberger@agwpa.com; smahoney@agwpa.com 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. brad@pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews A venue Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Esq. Dee@FredHaddadLaw.com 1 Financial Plaz.a Suite 2612 Fort Lauderdale, FL 33301 W. Chester Brewer, Jr., Esq. wcblawrmaol .com; wcbcg@aol.com W. Chester Brewer, Jr., P.A. One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, FL 33401 (con't) 3 Epstein v. Rothstein, et al. NOT A CERTIFIED COPY Tonja Haddad Coleman, Esquire Tonja@tonjahaddad.com; efiling@tonjahaddad.com Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein 4 Epstein v. Rothstein, et al. NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissine: Edwards Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION protected by privacy rights 02520-02543 06/06/2009 Bradley Edwards Paul Cassell Memo of Assest Transfers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02548-02553 08/03/2009 Beth Williamson Bradley Edwards Federal Subpoena Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02560-02565 07/31/2009 Bradley Edwards Jacquie Johnson Federal Subpoena Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02568-02570 10/13/2009 Jacquie Johnson Bradley Edwards New Times Article Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02578-02583 05/28/2009 Paul Cassell Bradley Edwards Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02619-02622 09/09/2009 Jacquie Johnson Bradley Edwards New client Retainer Work product; attorney /client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02633-02646 05/01/2009 Paul Cassell Bradley Edwards Response to Motion to Work product; attorney/client privilege; Consolidate + Cassell strategy irrelevant and not reasonably calculated to lead Memo for Jay to the discovery of the admissible evidence; protected by privacy rights 07959-07964 09/24/2009 Bradley Edwards Paul Cassell Litigation Strategy Work product; attorney /client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 123 NOT A CERTIFIED COPY Privilege Log - Dated 2-23~2011 I I I I Farmer Jaffe Weissimz Edwards Fistos & Lehrman BATES DATE TO FROM DESCRIPTION ORJECTION 07967-07975 09/22/2009 Jacquie Johnson Mike Fisten Subpoena on Epstein case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07979-08000 08/18/2009 Bradley Edwards Jacquie Johnson Subpoenas for Pilots Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07735-077 36 07/24/2009 Bradley Edwards Jacquie Johnson Releases for therapist Work product; attorney /client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07643-07645 09/09/2009 Bradley Edwards Jacquie Johnson New client Retainer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07698-07706 09/06/2009 Paul Cassell Bradley Edwards Answer to the Complaint Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07620-07632 08/14/2009 Jacquie Johnson Bradley Edwards Review of "Notice of Taking Depa Work product; attorney /client privilege; - RC -Bear Sterns" irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07635-07636 10/15/2009 Mike Fisten Bradley Edwards Questions from forensic Work product; attorney/client privilege; accountant detecting Epstein irrelevant and not reasonably calculated to lead fraudulent transfers to the discovery of the admissible evidence; protected by privacy rights 07617-07618 07/13/2009 Paul Cassell Bradley Edwards Epstein strategy Work product; attorney /client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07550-07589 10/30/2009 Bradley Edwards Paul Cassell Motion to Supplement with the Work product; attorney /client privilege; 124 NOT A CERTIFIED COPY Privilege Log-Dated 2-23-2011 I & I I Farmer Jaffe Weissimi Edwards Fistos & Lehrman BATES DATE TO FROM DESCRIPTION nRJECTION Visoski depo