639.pdf

NOT A CERTIFIED COPY Electronically Filed 06/26/2013 10:38:27 AM ET IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, I ---------------- RESPONSE TO SCHEDULE A TO NOTICE OF TAKING DEPOSITION OF BRADLEY J. EDWARDS Bradley J. Edwards, by and through his undersigned counsel, files this Response to Schedule A attached to the Notice of Taking Deposition of Bradley J. Edwards as follows: 1-6. are being collected to be provided to the Court for inspection. 7. Attached. The first document is all time spent on defense of Epstein's claim; the second is time billed by Brad Edwards personally on hourly billable cases during the same time period. 8. The responsive documents are already in Epstein's possession and are ALL pleadings filed by Epstein in the Rothstein Bankruptcy Proceeding Proceeding Case# 09-34791- BKC-RBR, as well as all submissions submitted publicly and circulated by Epstein in preparation for the deposition of Scott Rothstein. 9. None 10. None 11. All responsive documents are already in the possession of Epstein, and are: all settlement agreements between Jeffrey Epstein and the victims of his sexual molestation; NOT A CERTIFIED COPY Edwards adv. Epstein Case No.: 502009CA040800:XXXXMBAG Response to Schedule A to Notice of Taking Deposition of Bradley J. Edwards Page 2 of3 All deposition testimony given by Jeffrey Epstein in all civil cases that were prosecuted against him; as well as Edwards's Motion for Summary Judgment and all attachments thereto. 12. Not yet determined Attachments follow separately. 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 -J_{p r--;;_y of June, 2013. Florida ar N . : 169440 Prim~ E-ail: jsx@searcylaw.com Seco dat E-mail(s): mep@searcylaw.com Sear enney Scarola Barnhart & Shipley, P.A. 213 ' Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for Bradley J. Edwards NOT A CERTIFIED COPY Edwards adv. Epstein Case No.: 502009CA040800:XXXXMBAG Response to Schedule A to Notice of Taking Deposition of Bradley J. Edwards Page 3 of3 COUNSEL LIST Jack A. Goldberger, Esquire j goldberger@agwpa.com; smahoney@agwpa.com Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Bradley J. Edwards, Esquire staff.efile@pathtojustice.com Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, FL 425 N01ih Andrews A venue, Suite 2 F01i Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (954) 524-2822 Fred Haddad, Esquire Dee@FredHaddadLaw.com; haddadfm@aol.com Fred Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: (954)-467-6767 Fax: (954)-467-3599 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 Tonja Haddad Coleman, Esquire tonj a@tonjahaddad.com; Debbie@Tonjahaddad.com Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: (954)-467-1223 Fax: (954)-337-3716 Attorneys for Jeffrey Epstein