363.pdf

NOT A CERTIFIED COPY JEFFREY EPSTEIN, Plaintiff, vs. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG ~(/) N r:r: c:= - - SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, 3:~ £:?o:,o :ta, ~t,;- ~ ( ;urr;:Z c::: . ('")}> :::0 G') _,, C::c-,• ;s-~. ~:Cc:::, "' L Defendants. I nnO -o,S:-, ..,, ! -..,,.. < I :ss~· ::c --------------- NOTICE OF TAKING DEPOSITION *Duces Tecum TO: All counsel on the attached Counsel List _.,__ r- -- -,- . 'rr "ri :-- PLEASE TAKE NOTICE that the undersigned attorneys will take deposition(s) of: NAME AND ADDRESS DATE AND TIME LOCATION c~-. w .. "' -., Representative(s) of The Wackenhut Corporation with the most knowledge of the matters set forth below pursuant to Fla. R. Civ. P. September 6, 2011 10:00 AM. Searcy Denney Scarola Barnhart & Shipley, PA 1.3 IO(b )( 6) 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 *DUCES TECUM: TO HA VE AND BRING WITH YOU AT THE TIME OF THE DEPOSITION THE FOLLOWING: Any and all documents** reflecting or relating to services rendered: 1. at or in the general vicinity of 358 EI Brillo Way, Palm Beach, FL 33480-4730; and 2. for the benefit of or at the direction of Jeffrey Epstein and/or Jack Goldberger including but not limited to documents reflecting when the services were performed, how long they were performed, the nature of the services, and by whom they were performed. NOT A CERTIFIED COPY upon oral examination before Signature Court Reporting, Inc., a Notary Public, or any other officer authorized by law to take depositions in the State of Florida. The oral examination is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the applicable Statutes or Rules. **"Documents" shall include, but not be limited to all non-identical copies of writings, drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data compilations from which information can be obtained, translated, if necessary, by the party to whom the request is directed through detection devices into reasonably usable form. "Documents" also include all electronic data as well as application metadata and system metadata. All inventories and rosters of your information technology (IT) systems--e.g., hardware, software and data, including but not limited to network drawings, lists of computing devices (servers, PCs, laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps and security tools and protocols. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by cc: Signature Court Reporting dd ack ar a Flo ·aa ar No.: 169440 S r Denney Scarola Barnhart & Shipley, P.A. 9 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorney for Defendant Edwards E-TRANSCRIPT, ASCII, CD AND/OR DVD REQUESTED NOT A CERTIFIED COPY COUNSEL LIST Jack A. Goldberger, Esquire jgoldberger@agwpa.com; smahoney@agwpa.com Atterbury, Goldberger & Weiss, P.A. 250 Australian A venue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Bradley Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 Joseph L. Ackerman, Jr., Esquire jla@fowler-white.com; NTrompet@fowler-white.com Fowler White Burnett, P.A. 901 Phillips Point West 777 S Flagler Drive West Palm Beach, FL 33401-6170 Phone: (561)-802-9044 Fax: (561)-802-9976 Attorneys for Jeffrey Epstein Marc S. Nurik, Esquire marc@nuriklaw.com Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein Martin Weinberg, Esquire Martin Weinberg, P.C. 20 Park Plaza, Suite 1000 Suffolk, MA 02116 Attorneys for Jeffrey Epstein