EFTA00805156.pdf

I M R LINK& ROCKENBACH, PA CIVIL TRIAL 8, APPELLATE LAW 1555 Palm Beach Lakes Blvd Suite 301 West Palm Beach. FL 33401 TEL (561) 727.3600 I FAX (561) 727-3601 April 3, 2018 Via Email Via Email Niall T. McLachlan Joseph lanno Jr. Carlton Fields Jorden Burt, P.A. Carlton Fields Jorden Burt, P.A. 100 S.E. Second Street, Suite 4200 CityPlace Tower, Suite 1200 Miami, FL 33131 525 Okeechobee Boulevard West Palm Beach, FL 33401-6350 RE: Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards 15'h Judicial Circuit Case No. 50-2009CA040800XXXXMBAG Dear Niall and Joe: This letter is Jeffrey Epstein's demand to Fowler White, pursuant to section 627.4137, Florida Statutes, for the following: A statement under oath of a corporate officer for Fowler White or Fowler White's insurer's claim manager or superintendent setting forth the following information with regard to each known policy of insurance, including excess or umbrella insurance, that would cover any claim that has or may result from Fowler White's retention of documents and/or a disc that (1) Farmer Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., (2) Bradley J. Edwards, and (3) L.M., E.W. and Jane Doe have alleged were improperly retained: a. The name of the insurer; b. The name of each insured; c. The limits of the liability coverage; d. A statement of any policy or coverage defense which such insurer reasonably believes is available to such insurer at the time of providing the statement; and e. A copy of the policy(ies). Please provide this information within 30 days as required by the statute. Thank you for your attention to this matter. Sincerely, Scott J. Link SJUtic EFTA00805156