Court reporting services shall be provided by Palm Beach Reporting Service Palm Beach Lakes Blvd Suite West Palm Beach Florida and the video equipment will be operated by Visual Evidence Dixie Hwy Suite A West Palm Beach Florida CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on November through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration LINK ROCKENBACH P.A Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Angela linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Secondary Tanya linkrocklaw.com Secondary Eservice linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Burlington Rockenbach P.A Palm Beach Lakes Boulevard Courthouse Commons Suite West Palm Beach FL West Railroad A venue mep searcylaw.com West Palm Beach FL jsx searcylaw.com njs FLAppellateLaw.com scarolateam searcylaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Fort Lauderdale FL Ft Lauderdale FL brad epllc.com marc nuriklaw.com staff.efile pathtojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Tonja Haddad Coleman Fred Haddad S.E Seventh Street Suite Haddad Navarro PLLC Ft Lauderdale FL Financial Plaza Suite tonj a tonjahaddad.com Fort Lauderdale FL efiling tonjahaddad.com dee haddadandnavarrolaw.com Co-Counsel for Plaintiff/Counter-Defendant Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Jeffrey Epstein Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrev Evstein JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No SUBPOENA DUCES TECUM FOR VIDEOTAPED DEPOSITION THE STATE OF FLORIDA TO TO Dr Bernard Jansen c/o Jack Scarola Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL YOU ARE COMMANDED to appear before a person authorized by law to take depositions on Friday December at a.m at the Law Offices of Edwards Pottinger LLC Andrews Avenue Suite Ft Lauderdale Florida for the taking of your videotaped deposition in this action If you fail to appear you may be in contempt of court You are subpoenaed to appear by the following attorneys and unless excused from this Subpoena by the attorneys or the Court you shall respond to this Subpoena as directed You are further directed to produce to Plaintiff/Counter-Defendants counsel by November the documents identified in the attached Exhibit A to the extent not already produced Dated November LINK ROCKENBACH P.A Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Angela linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Secondary Tanya linkrocklaw.com Secondary Eservice linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein If you are a person with a disability who needs any accommodation in order to respond to this Subpoena you are entitled at no cost to you to the provision of certain assistance Please contact Link Rockenbach Palm Beach Lakes Boulevard Suite West Palm Beach Florida at least seven days before your scheduled appearance or immediately upon receiving this notification if the time before the scheduled appearance is less than seven days if you are hearing or voice impaired call Copies provided to SERVICE LIST Jack Scarola Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL mep searcylaw.com jsx searcylaw.com scarolateam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Nichole Segal Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL njs FLAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Fort Lauderdale FL Ft Lauderdale FL brad epllc.com marc nuriklaw.com staff.efile pathtojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Tonja Haddad Coleman Fred Haddad S.E Seventh Street Suite Haddad Navarro PLLC Ft Lauderdale FL Financial Plaza Suite tonj a tonjahaddad.com Fort Lauderdale FL efiling tonjahaddad.com dee haddadandnavarrolaw.com Co-Counsel for Plaintiff/Counter-Defendant Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Jeffrey Epstein Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrev Epstein EXHIBIT A DEFINITIONS I Communication or communications mean any oral written or electronic utterance notation or statement of any nature whatsoever by and to whomsoever made including but not limited to any documents correspondence letters facsimiles e-mails text messages voice recordings video recordings voicemail instant messages conversations dialogues discussions interviews conferences meetings consultations agreements and other understandings or exchanges between or among two or more people Document or documents mean all paper documents graphic or auditory records or representations tangible items and electronically stored information and shall have the broadest possible meaning accorded to it consistent with Florida Rule of Civil Procedure which is incorporated in this definition as if fully set forth and includes by way of illustration only and not by way of limitation the following items which are in your possession control knowledge or are known to you a All written paper or printed material of any kind including but not limited to all transmittal slips memoranda notes schedules agendas notices books brochures calendars employment files announcements meeting minutes records of meetings records of conversations newsletters telegrams summanes lists compilations facsimile transmissions transcripts diaries appointment books agreements contracts reports studies checks check stubs invoices financial statements bank statements receipts communications interoffice and intraoffice exchanges conversations inquiries replies correspondence and letters whether in person by telephone in writing or by means of any other transmittal devices and all originals reproductions copies changes amendments drafts and all non-identical copies of the foregoing Graphic or auditory records or representations of any kind including but not limited to all images photographs charts drawings sketches diagrams maps schematics microfiche microfilm slides videotapes laser discs digital versatile discs Blu-ray discs Ultra Violet discs cassette tapes reel to reel tapes recordings sound bites motion pictures voice messages and all originals reproductions copies changes amendments drafts and all non-identical copies of the foregoing and Electronically stored information electronic mechanical and electrical records or representations of any kind including but not limited to all electronic communications text messages e-mails instant messages computer logs network logs Internet history document files spreadsheet files presentation files database files desktop publishing files source code files object code files executable files data files script files project management files text files portable document format files tabulated data files virtual machine files XML files webpage files image files design files GIS files system files compressed files disk image files audio files video files backup files metadata and all originals reproductions copies changes amendments drafts and all non-identical copies of the foregoing defined herein as ESI each individual electronically stored document is defined herein as an ESI document For purposes of the foregoing documents may be located stored or archived in any physical location or on any electronic storage media including without limitation any computer server appliance cloud-based service web-based service database internal hard drive external hard drive solid-state drive hard or floppy diskette compact disc digital versatile disc Blue-ray disc Ultra Violet disc flash memory flash card thumb drive cartridge magnetic tape mobile phone tablet device or personal digital assistant Moreover for purposes of the foregoing the term draft means any earlier preliminary preparatory or tentative version of all or part of a document whether or not such draft was superseded by a later draft and whether or not the drafts terms are the same as or different from the final documents terms Please note that Document and Documents as defined herein specifically include Communication and Communications as defined above Native Format means the file format of ESI in the application in which such ESI was originally created Person as used herein means any natural person or any entity including without limitation any individual public company private company firm corporation limited liability company joint venture trust proprietorship tenancy association partnership business agency department governmental body bureau board commission or any other form of public or private entity With respect to an entity Person shall include all subsidiaries and affiliates of the entity as well as the present and former directors officers employees attorneys agents and anyone acting on behalf of at the direction of or under the control of the entity or its subsidiaries or affiliates The terms you or your mean Dr Bernard Jansen and include all employees staff representatives attorneys accountants agents and any other person acting under his control or on his behalf Relates to or relating to mean authorizing concermng constituting compnsmg containing consisting of connected with describing disclosing discussing evidencing explaining mentioning pertaining to proposing reflecting regarding referring to directly or indirectly setting forth showing or summarizing Lawsuit means the litigation styled Jeffrey Epstein Scott Rothstein and Bradley Edwards Case No pending in the Fifteenth Judicial Circuit in and for Palm Beach County Florida Other Lawsuits means all lawsuits filed by Jane Doe L.M E.W or any other clients represented by Bradley Edwards against Jeffrey Epstein from January to the present Tagged Image File Format or TIFF refer to the CCITT Group IV graphic file format for storing bit-mapped images Where appropriate a use of the singular includes the plural and vice versa the past tense includes the present tense the words and and or are both conjunctive and disjunctive the words all and any mean any and all the word including means including without limitation and use of the masculine includes the feminine and vice versa INSTRUCTIONS General Instructions In response to this Subpoena Duces Tecum you are required to furnish all information and documents which are or have been in your possession custody or control or in your possession custody or control Unless otherwise specifically stated in each request the relevant time period shall be the period from January to the present ESI Instructions ESI Production Format ESI shall be produced electronically either in Native Format or as single-page uniquely and sequentially numbered Group IV TIFF image files For each ESI document all metadata must remain intact and all parent/child document relationships must be maintained All ESI shall be collected using methods that prevent the spoliation of data Production Media The production of ESI as described herein shall be made on an external hard drive flash drive CD or DVD Production Media The Production Media shall include a unique identifying label specifying a your identity the date of the production of ESI and the Lawsuit name and number ESI of Limited Accessibility If you contend that any ESI document responsive to this Subpoena is not reasonably accessible timely identify such ESI document with reasonable particularity and provide the basis for declining to produce the ESI document including for example any limitations on access the likely costs that might be incurred in accessing and producing the ESI document the method used for storage of the ESI document and all locations in which the ESI document is kept TIFF Production ESI produced as TIFF image files shall be produced as follows each production of TIFF image files shall be accompanied by a corresponding load file Image Load File each TIFF image file must contain the same information and same physical representation as the Native Format file from which the TIFF image file was created each TIFF image file must not be less than dpi resolution each TIFF image file shall be accompanied by an extracted text file containing the extracted text of the Native Format file from which the TIFF image file was created each extracted text file shall be named to match the endorsed number assigned to the first page of each corresponding TIFF image file the extracted text files shall be accompanied by a Control List File LST each production of TIFF image files shall be accompanied by an image cross-reference load file such as Opticon OPT which shall provide the beginning and ending endorsed number of each TIFF image file and the number of pages it includes and each production of TIFF image files must be accompanied by a data load file Data Load File or DAT that contains both the hash value and all available metadata of the Native Format files from which the TIFF image files were created Further the following instructions apply to the production of TIFF image files a Processing Specifications For each Native Format file that is converted to TIFF format all tracked changes shall be maintained so that all changes are visible OLE Embedded files shall not be extracted as separate documents author comments shall remain or be made visible hidden columns cells rows worksheets and other hidden data shall remain or be made visible presenter notes shall remain or be made visible and to the extent ESI in a foreign language is produced processing of such ESI shall be unicode-compliant Document Unitization If a Native Format file that is converted to TIFF format is more than one page the unitization of the file and any attachments or affixed notes must be maintained as it existed when collected If unitization cannot be maintained the original unitization must be documented in the Data Load File or otherwise electronically tracked Color If a Native Format file that is converted to TIFF format contains color the TIFF image file need not be produced in color However we reserve the right to make a request for a file to be produced in color Where TIFF Image File Format is Impracticable In the event that production of a Native Format file as a TIFF image would be impracticable you shall produce such file in Native Format with all metadata intact You shall provide a single page TIFF image placeholder referencing the title of the Native Format file not being produced as a TIFF image Spreadsheets All Microsoft Excel files similar non-Microsoft spreadsheet files and graphical compilations of spreadsheet data shall be produced in Native Format with all cells columns rows and worksheets and other information unhidden and expanded Right to Request Native Format files We reserve the right to demand production in Native Format of any file produced by you as a TIFF image file REQUESTED DOCUMENTS Your current curriculum vitae Any reports prepared by you or at your direction relating to your services or participation in this Lawsuit and your analysis of the Other Lawsuits Copies of any notes made by you or provided to you relating to your opinions or conclusions in this Lawsuit and your analysis of the Other Lawsuits whether you relied on those notes or not Communications between you and any person relating to your analysis op1mons or conclusions in this Lawsuit as well as your analysis of the Other Lawsuits Any photographs or videos taken by you or provided to you that you have observed and reviewed in relation to this Lawsuit Any deposition or hearing transcripts provided to you or parts of deposition transcripts or any other statements or written materials provided to you which you have examined or will examine in relation to this Lawsuit Any diagrams or drawings made by you or provided to you which you have examined in relation to this Lawsuit Any statements or affidavits taken by you at your direction or provided to you for your review concerning any of the facts which are involved in this Lawsuit Any memoranda or written notice made by you or provided to you concerning the subject matter of this Lawsuit Any documents prepared by you provided to you or obtained by you or reviewed by you whether intended for your use or not and regardless of whether or not you actually reviewed or relied on those documents in connection with this Lawsuit All literature and/or documents that you considered relevant to your assignment in this Lawsuit and which you considered in the development of your opinions or conclusions concerning the subject matter of the lawsuit All documents prepared by you to illustrate or demonstrate any fact or opinion considered relevant to this Lawsuit and/or to your assignment investigation or opinions Copies of any articles books papers or other publications prepared by you which relate to facts similar to the facts surrounding the subject matter of this Lawsuit Any and all materials considered consulted and used by you as a basis or predicate for your opinions and conclusions in this Lawsuit including but not limited to published reports by any private or government agency textbooks articles data or documents furnished by the party engaging your services or government or industry standards or regulations Any and all models or demonstrative tools upon which you have or plan to rely in the formulation and expression of your opinions and conclusions concerning the subject matter of this Lawsuit A copy of any retainer agreement or other agreement between you and Bradley James Edwards or counsel for Bradley James Edwards that sets forth the terms of your engagement in this matter including but not limited to the fees for your services in this Matter A copy of all statements bills invoices check stubs or any other document that reflects payment or compensation or a request for payment or compensation for your services in this Lawsuit or any of the Other Lawsuits All marketing materials that market or advertise your expert witness services A list of all other expert witness services performed for Bradley James Edwards or any clients represented by Bradley James Edwards in the last ten years A list of other depositions or trials in which you have testified from January to the present All expert reports testimony videos and affidavits in which you have testified as an expert on any issue in the last ten years Copies of all publications expert reports depositions or other documents in which you have discussed analyzed or otherwise referenced the subject of the scope of discovery in litigation Your file regarding your opinions possible opinions expert testimony and/or consultation relating directly or indirectly to the issues in this Lawsuit All complaints filed against you with the Florida Bar as well as all communications to you by the Florida Bar and all documents relating to any disciplinary proceedings or investigations conducted by the Florida Bar or any committee of the Florida Bar A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 qrM?r?qr?r9 q?10Cy rCX qr l1 X?l 3K fm?Q Z2f CX CX gT L??T 2E Cy 3P EM3 J4T L?h??M q?ᡚ?Y r??O?rJt CTX i P!e i I CTX rC YY I 1e 2j CTX X0T1i k3v Jh/e0h1 H(K W/Q0 CTX j?!k 5B r2 CTX A A A 4v z"p A A A0A?A AK CTX A A?!k CX qCX YCX i!d A fi8 l8 yuZ 6L pH m?c sP;0 6ZR Ni P0 0Q X(P0s s(s p0 Pp CTX qq dR B/J Va A N?q qr NEeD K?i N?M?qr EeD k??O I CTX U3 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