EFTA01141955.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. JACKS AR LA Flori ar o.: 169440 Prim mail: E-m s : S y Denney Scaro a art & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorneys for Bradley J. Edwards EFTA01141955 Edwards adv. Epstein Notice of Service of Interrogatory to Jeffrey Epstein Case No.: 502009CA040800300DCMBAG COUNSEL LIST Jack A. Goldber Fort Lauderdale, FL 33394 Pho Fax:11. Attorneys for Jeffrey Epstein Marc S. Nurik Es uire w ices o arc . urik Attorneys for Jeffrey Epstein Fort Lauderdale, FL 33301 Bradley J. Edwards, Esquire Phon larn Lehrman FL ing ards, Fistos & Fax:( Attorneys for Scott Rothstein Tonja Haddad Coleman, Esquire Pho Fort Lauderdale, FL 33301 Fax: nranvormitir, Fred Haddad, Esquire ort FIITMAtinelle I Phone Fax: ( Sc Fred Had 'al . Attorneys for Jeffrey Epstein EFTA01141956 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 EFTA01141957 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 EFTA01141958