EFTA01203647.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and El., individually, Defendant(s). NOTICE OF SERVING EXPERT INTERROGATORIES TO JEFFREY EPSTEIN REGARDING MOTION FOR APPELLATE ATTORNEY'S FEES Bradley J. Edwards, hereby gives notice that pursuant to Rule 1.340(e), Florida Rules of Civil Procedure, Expert Interrogatories numbered 1 through 16 have been directed to JEFFREY EPSTEIN, this 1 i day of At) ea, , 2015. I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve 1 to all Counsel on the attached list, this 11, 2015. Jack Hod o.: 169440 Au. e Mail: and m ary E-Mail: earcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for Bradley J. Edwards EFTA01203647 Edwards v. Epstein Notice of Serving Expert Interrogatories Regarding Motion for Appellate Attorney's Fees COUNSEL LIST William Chester Brewer, Esquire 250 S Australian Avenue, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-655-4777 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Jack A. Goldberger, Esquire jgoldberger@agwpa.corn; Atterbury Goldberger & 'P r 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein John R. Beranek, Esquire Ausley & McMullen 123 South Calhoun Street Tallahassee, FL 32301 Phone: (850)-224-9115 Fax: (850)-222-7560 Attorneys for Jeffrey Epstein Andrew A. Harris, Esquire • Burlington & Rockenbach 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: (561)-721-0400 Fax: (561)-721-0465 Attorneys for Bradley J. Edwards EFTA01203648 Edwards v. Epstein Notice of Serving Expert Interrogatories Regarding Motion for Appellate Attorney's Fees Bradley J. Edwards, Es uire Farmer Jaffe Weissing Edwards Fistos & Lehrman, E. 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 Fred Haddad, Esquire Fred Haddad, One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: (954)-467-6767 Fax: (954)-467-3599 Attorneys for Jeffrey Epstein Tonja Haddad Coleman, E uire Tonja Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: (954)467-1223 Fax: (954)-337-3716 Attorneys for Jeffrey Epstein EFTA01203649 Edwards v. Epstein Notice of Serving Expert Interrogatories Regarding Motion for Appellate Attorney's Fees EXPERT INTERROGATORIES TO JEFFREY EPSTEIN REGARDING MOTION FOR APPELLATE ATTORNEY'S FEES 1. State the name, address and profession of each person whom you expect to call as an expert witness at trial or on whose expert opinions others have relied in forming opinions which you will or may offer at trial. 2. With regard to each listed above, state his/her background, education and experience which qualify him/her to testify as an expert in his/her area of expertise; and/or in lieu thereof, please provide a copy of each expert's most recent curriculum vitae. 3. Give the name or title of each paper which each expert has authored in the field of his/her expertise. EFTA01203650 Edwards v. Epstein Notice of Serving Expert Interrogatories Regarding Motion for Appellate Attorney's Fees 4. State the name, volume and page number of the publication in which each article or paper listed above can be found. 5. State the substance and identify the source of the facts on which each expert has relied in forming any opinion about which the expert is expected to testify. 6. Give a complete list of all documents, depositions, exhibits, plans, drawings, ordinances or statutes which each expert has reviewed in forming his/her opinion. EFTA01203651 Edwards v. Epstein Notice of Serving Expert Interrogatories Regarding Motion for Appellate Attorney's Fees 7. State the opinions to which the experts aforementioned are expected to testify. 8. Give a summary of the grounds of each opinion stated. 9. Identify where the expert listed above has practiced or worked in his/her field during the past 10 years? EFTA01203652 Edwards v. Epstein Notice of Serving Expert Interrogatories Regarding Motion for Appellate Attorney's Fees 10. As to each position identified above, please state: a. Whether the expert was self-employed, employed by someone else or associated as a partner. b. Each address where the expert practiced or was employed. c. The dates the expert was with each employer. d. The type of duty the expert performed with each employer. 11. If the expert has not practiced or worked in his/her field during the last 10 years, what was his/her employment during this time? EFTA01203653 Edwards v. Epstein Notice of Serving Expert Interrogatories Regarding Motion for Appellate Attorney's Fees 12. Did the expert prepare anything or have anything prepared setting forth his/her opinions or conclusions reached from his/her examination or any tests he/she conducted? a. If so, state the date of preparation b. The name or other means of identification of each individual and entity to whom the material prepared was distributed. c. The name and address of each person who has present custody of each non- identical copy of the material. 13. Did the expert prepare or have prepared any material based upon tests, examinations or analyses of documents that he/she conducted in which he/she did not render an opinion? a. If so, state description of all material that was prepared by or for the expert. b. The date that the material was prepared. EFTA01203654 Edwards v. Epstein Notice of Serving Expert Interrogatories Regarding Motion for Appellate Attorney's Fees c. The name or other means of identification of the person to whom all material was distributed. d. The name and address of the person who has present custody of each non- identical copy of the material. 14. If you will do so without a Request to Produce, attach a copy of all materials prepared by or for each expert on the basis of his/her tests, examinations or analyses to your answers to these Interrogatories. EFTA01203655 Edwards v. Epstein Notice of Serving Expert Interrogatories Regarding Motion for Appellate Attorney's Fees 15. Is the expert to be compensated for his/her work and efforts in connection with this action? a. If so, describe in detail the basis and/or rate of compensation, the total amount paid to or on behalf of the expert, the amount currently payable to the expert for all services rendered as of the date of your answers to these interrogatories. b. Estimate the total amount of time reasonably expected to be spent by the expert in completing all services to be rendered in this matter from the date of your answers to the conclusion of the case. c. Describe all additional services expected to be rendered by the expert. 16. Has the expert served as an expert witness in any other litigated case in the past 5 years? If so, state as to each case: a. The style of the case, the Court in which it was filed and the names and addresses of the attorneys involved. b. Whether the expert was retained on behalf of the Plaintiff or Defendant. EFTA01203656 Edwards v. Epstein Notice of Serving Expert Interrogatories Regarding Motion for Appellate Attorney's Fees c. The general subject matter as to which the expert provided services. d. Whether sworn testimony was given in the case, and, if so, whether the expert or you are in possession of a transcript of the testimony. EFTA01203657 Edwards v. Epstein Notice of Serving Expert Interrogatories Regarding Motion for Appellate Attorney's Fees 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) EFTA01203658