Filing E-Filed AM 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 PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS NOTICE OF FILING UPDATED UNVERIFIED ANSWERS TO EXPERT INTERROGATORIES Plaintiff/Counter-Defendant Jeffrey Epstein pursuant to Florida Rule of Civil Procedure hereby provides notice of the filing of his Updated Unverified Answers to Defendant/Counter-Plaintiff Bradley Edwards September Expert Interrogatories in further support of his December Motion for Leave to Disclose Expert Witness and pursuant to counsels statements at the January hearing FILED PALM BEACH COUNTY FL SHARON BOCK CLERK AM CERTIFICATE OF SERVICE I certify that the Notice has been furnished to the attorneys listed on the Service List below on January through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration and the Notice with the Answers have been served via e-mail Jack Scarola LINK ROCKENBACH PA 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 Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL mep searcylaw.com jsx searcylaw.com scarolateam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards 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 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 Jeffrey Epstein IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff I PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS UPDATED ANSWERS TO EXPERT INTERROGATORIES Plaintiff/Counter-Defendant Jeffrey Epstein Epstein pursuant to Florida Rule of Civil Procedure hereby provides updated answers to Defendant/Counter-Plaintiff Bradley Edwards September Expert Interrogatories EXPERT INTERROGATORIES TO JEFFREY EPSTEIN 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 ANSWER Culver Skip Smith I Esq Culver Smith I P.A South Australian Avenue Suite West Palm Beach FL Lawyer 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 experts most recent curriculum vitae ANSWER A copy of Mr Smiths Curriculum Vitae was attached to Epsteins December Amended Trial Witness List Give the name or title of each paper which each expert has authored in the field of his/her expertise ANSWER See Mr Smiths Curriculum Vitae attached to Epsteins December Amended Trial Witness List State the name volume and page number of the publication in which each article or paper listed above can be found ANSWER See Mr Smiths Curriculum Vitae attached to Epsteins December Amended Trial Witness List 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 ANSWER Mr Smith will testify as to legal ethics and responsibility probable cause for commencing a civil action and professional reputation The sources of the facts on which he is relying are principally the pleadings other public information that was available before the original proceeding was initiated or discovered during the pendency of the original civil proceeding deposition testimony and the circumstances of Mr Edwards defamation action against Alan Dershowitz Give a complete list of all documents depositions exhibits plans drawings ordinances or statutes which each expert has reviewed in forming his/her opinion ANSWER Nov News articles marked as Exhibits and at Bradley Edwards November deposition Razorback Complaint Epsteins Complaint Edwards Fourth Amended Counterclaim Edwards Dershowitz Notice of Withdrawal of Motion for Partial Summary Judgment Article Defamation lawsuits involving U.S lawyer Dershowitz end in settlement Affidavit of Jeffrey Epstein Deposition Transcript of Bradley Edwards Order Granting Epsteins Motion for Continuance of Trial etc Hearing Transcript Hearing Transcript Hearing Transcript Notice of Taking Video Deposition Debrincat Fischer So 3d Fla Endacott International Hospitality Inc So 2d Fla 3d DCA Fundament May So 2d Fla th DCA Gill Kostroff Supp 2d M.D Fla Rule of the Rules Regulating The Florida Bar Restatement Third of Law Governing Lawyers Florida Bar Ethics Opinion State the opinions to which the experts aforementioned are expected to testify ANSWER Based on the information available to them Mr Epstein had probable cause to file a civil action against Mr Edwards-i.e a reasonable person had cause to believe that Mr Edwards was involved in a scheme to entice investors to invest in purported settlements of claims against Mr Epstein Mr Edwards was ethically obligated to L.M to disclose the conflict between his personal interests and her interests in connection with his representation of her in Mr Epsteins lawsuit against them and should have obtained her informed consent to his representation before representing her Give a summary of the grounds of each opinion stated ANSWER While at the Rothstein firm Mr Edwards represented three alleged sexual-abuse victims of Mr Epstein in litigation against Mr Epstein and participated in litigation tactics and strategies which could be perceived as not directly related to his clients but in furtherance of Rothsteins Ponzi scheme Extensive media coverage and other criminal and civil court filings described a Ponzi scheme operated by individuals at the Rothstein firm which utilized cases against Epstein to corroborate and bolster the claims made to investors in the Ponzi scheme including that there were million of settlements relating to cases against Epstein Mr Edwards held himself out as a partner at the firm thus implying that he had the authority to direct and manage the cases that he was handling Mr Edwards and L.M.s interests in defense of Mr Epsteins claims against them either were directly adverse from the outset or there existed a substantial risk that they would become adverse during the course of the litigation Identify where the expert listed above has practiced or worked in his/her field during the past years ANSWER See Mr Smiths Curriculum Vitae attached to Epsteins December Amended Trial Witness List As to each position identified above please state a Whether the expert was self-employed by someone else or associated as a partner Each address where the expert practiced or was employed The dates the expert was with each employer The type of duty the expert performed with each employer ANSWER See Mr Smiths Curriculum Vitae attached to Epsteins December Amended Trial Witness List If the expert has not practiced or worked in his/her field during the last years what was his/her employment during this time ANSWER NIA 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 The name or other means of identification of each individual and entity to whom the material prepared was distributed The name and address of each person who has present custody of each nonidentical copy of the material ANSWER No 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 The date that the material was prepared The name or other means of identification of the person to whom all material was distributed The name and address of the person who has present custody of each nonidentical copy of the material ANSWER No 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 ANSWER None 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 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 Describe all additional services expected to be rendered by the expert ANSWER Mr Epstein provided Mr Smith with a refundable/replenishable deposit To date Mr Smith has billed or incurred approximately in fees and in expenses Mr Smith estimates that he will bill for his time preparing for and testifying at his deposition and trial Has the expert served as an expert witness in any other litigated case in the past 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 Whether the expert was retained on behalf of the Plaintiff or Defendant The general subject matter as to which the expert provided services 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 ANSWER See attached chart The following attorneys were lead counsel affiliations and addresses as of that time Sarabay Marine Inc Greene Plaintiffs counsel Steven Dupre Carlton Fields Jorden Burt P.A West Boy Scout Boulevard Suite Tampa FL Defendants counsel Matthew Schwartz Cole Scott Kissane P.A West Boy Scout Boulevard Suite Tampa FL Kapral GEICO Indem Co Plaintiffs counsel Kerry McGuinn Jr Rywant Alvarez Jones Russo Guyton P.A North Brush Street Suite Tampa FL Defendants counsel Amanda Kidd Young Bill Roumbos Boles P.A South Palafox Street Suite Pensacola FL Cordell Consultant Inc Abbott Plaintiffs counsel Irwin Gilbert Gilbert Yarnell Law Offices Prosperity Farms Road Suite Palm Beach Gardens FL Defendants counsel Deborah Corbishley Kenny Nachwalter P.A South Biscayne Boulevard Suite Miami FL Mr Smith has copies of the transcripts of his depositions in the three cases Date Dec.18 Oct.17 Aug.19 Oct CULVER SMITH Ill Testimony as an Expert in Court by Deposition or by Affidavit/Declaration in Last Five Years as of January Matter Subj of Testimony Sarabay Marine Inc Greene Counsels conflicts of interest No Fla 12th Cir Ct Sarabay Marine Inc Greene Counsels conflicts of interest No Fla 12th Cir Ct Kapral GEICO Indemnity Co Conduct of insurance-defense No M.D Fla counsel Cordell Consultant Inc etc Abbott Counsels breach of fiduciary No S.D Fla duty 5035-001.list.experttestimony.dcs.20180115 Type of o/b/o Proceeding Testimony at jury Defs trial Deposition Defs Deposition Defs Deposition Pl 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 GH FT I CTX U3 U3 U3 U3 S6 E"L I I I5K7C:I 9O U3 Cn qrr qr q??r?q 9qr CTX G5 qr CX rC l0 WS zN pf1 ODV8L?m jC1DxV CTX CTX A qr 10Cy rYY Ң??P?V CTX C"C rqM?rq?q?qr qr CTX YY Jb?C.y CTX CTX GG4 A A G5 C.C M??r 10Cy rq YY C?J?yO c/XE?lgF GM??H p?ݡG Dp9Oh CTX CTX CJ4 I J6 CJ4 CK qrrM?q qq 9/CX?o CX qYqr rC dd?Z c6S ttcx A CTX CTX 10Cy rq rqYY X?qiX:4 3J Db ZH uD-8 1g?BH I vS 7Oo7u E?K?O J6 UJP U0 UT??ʴ UT UT UT O(p U(u UF1 iZ qr?r CX CX Yr zKW:E A K5M P-M UW VW L1J KJ56 N/Q SQ rC 6J ߵl ߵl 5TZ w8ĥDG oj?K _4 N)?Y Hp pRqc?W26 vz?WBrz?ZB??3X H4 CTX A CTX X4 U5 P8 5D qr qr 10Cy qr YY Mo?ANp D01jJ 9F bzEV 4O 8V CTX O!o CTX KK AA qr A C5 qr rYY 1A?CC V9 a c?F CTX A G5 qr EeD?M CTX 9?rY 10Cy rq qY ȠX1 a f??B CTX 9F I CTX 6D N?qr rrqq qC O?J RmA??b"0 M?.F q?D B?G CTX CTX F4 d6P A F4 qr rYY 4G AV8 CTX UY UL0 U0 U0 U0 UF UF UFAGA UA UA UAL UL UL UL UL UL UL U7 U7 U7 U7 U7 U7 U7 2EH GTU U/U OUoU UV G1 CTX TUV 1G 7A UA UAL X7 U7 U7 U77XL UL UL ULLYX KTX 8Y GJ A UMAT UD 7M GVW GF10 MWA LL MPM M?M 4M XY qr qr qr NEeD 10Cy qYY E2 GH l1 Pd h3V g?KIq V5kL O65S d_xKKU vV 5H p1 Z6 CTX U0 U1 CTX U0 U1 A0 1D qr qr 10Cy YY K??Kl 1B AMwv 1K F1 KV yW Gd T?H CTX CTX I CK M?qr K?SK?PQZ I IRZX 8YCX 10Cy qr CX kv zg S5kB??a iG wA CTX U2 6Y CTX U2 6Y I K,,j j,s 6Y P!p qr 10Cy qr YY G?O 9K mSd X0 9r?yal 1d bY0 XNf??qN D?J CTX P!Z b!o C,C qrM 10Cy qr8 I fX2 9R lO KV CTX Oo CTX A qr r?qr rq YY Lsy7H4 C,6E IL CTX U3 CTX J,O3_3xx qrM?r q?CX Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8
