Filing E-Filed AM 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 COUNTER-DEFENDANT JEFFREY EPSTEINS RESPONSES AND OBJECTIONS TO NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM Counter-Defendant Jeffrey Epstein Epstein pursuant to Florida Rule of Civil Procedure responds and objects to the Duces Tecum contained in Counter-Plaintiff Bradley Edwards Edwards September Notice of Taking Video Deposition Duces Tecum and states EDWARDS ORIGINAL DUCES TECUM Edwards original Duces Tecum sought All communications and all records relating to all communications concerning or containing information derived from documents or data over which a claim of privilege was asserted by or on behalf of Bradley Edwards Pursuant to Florida Rule of Civil Procedure days and Florida Rule of Judicial Administration days Epsteins Response is due on October However in the spirit of cooperation Epstein has served his response in advance of his October deposition FILED PALM BEACH COUNTY FL SHARON BOCK CLERK AM Documents shall include but not be limited to all non-identical copies of writings drawings graphs charts photographs phono records recordings and/or any other data compilations from which information can be obtained translated if necessary by the party to whom the request is directed through detection devices into reasonably usable form Documents also include all electronic data as well as application metadata and system metadata All inventories and rosters of your information technology IT systems-e.g hardware software and data including but not limited to network drawings lists of computing devices servers PCs laptops PDAs cell phones with data storage and/or transmission features programs data maps and security tools and protocols On July Epstein objected to the Duces Tecum on the basis that the Court has not reopened document discovery and because the request sought documents that are protected by the attorney-client privilege documents that have been sealed and access to Epsteins computers and electronic devices Epstein also pointed out that Epsteins deposition was limited in scope to the following topics Whether and to what extent Epstein reviewed any of the alleged privileged materials prior to March Whether and to what extent Epstein reviewed any of the alleged privileged materials after March Whether Epstein has any knowledge regarding compliance with the Courts verbal rulings on the record at the March hearing regarding destruction of those documents Edwards has claimed are privileged Whether and to what extent Epstein has shared any of the alleged privileged materials with anyone other than his attorneys Which if any of the alleged privileged materials Epstein plans to use to testify at trial Epstein reincorporates without restating his July objection EDWARDS SEPTEMBER DUCES TECUM Epsteins July objections were heard on August at which time the Court allowed Edwards to narrow his document request to correspond with the deposition topics On September Edwards filed a new Duces Tecum seeking the following documents All documents tending to establish Whether and to what extent Epstein reviewed any of the alleged privileged materials prior to March Whether and to what extent Epstein reviewed any of the alleged privileged materials after March Whether Epstein has any knowledge regarding compliance with the Courts verbal rulings on the record at the March hearing regarding destruction of those documents Edwards has claimed are privileged Whether and to what extent Epstein has shared any of the alleged privileged materials with anyone other than his attorneys Documents shall include but not be limited to all non-identical copies of writings drawings graphs charts photographs phono records recordings and/or any other data compilations from which information can be obtained translated if necessary by the party to whom the request is directed through detection devices into reasonably usable form Documents also include all electronic data as well as application metadata and system metadata All inventories and rosters of your information technology IT systems-e.g hardware software and data including but not limited to network drawings lists of computing devices servers PCs laptops PDAs cell phones with data storage and/or transmission features programs data maps and security tools and protocols EPSTEINS RESPONSE AND OBJECTION A General Response Epsteins current trial counsel Link Rockenbach PA received the disc which is the subject of Epsteins deposition from Epsteins former counsel Fowler White in February Epstein never received the disc nor did he know of the discs existence before that time At the March hearing this Court directed the parties to seal the disc and ensure no further dissemination of the documents Edwards claimed were privileged Link Rockenbach PA took immediate steps to comply with this Courts March directives as set forth in Epsteins Notices of Compliance The disc has been sealed and Edwards privilege claims are currently the subject of Epsteins request that the Court conduct an in camera review to make a determination as to whether the documents are privileged as claimed by Edwards Specific Response Epstein objects to the first three bullet point requests because they seek documents that are protected by the attorney-client privilege and work product doctrine Epstein does not have any non-privileged documents in response to the first three requests Epstein however is producing evidence of his counsels receipt of the disc In response to the fourth bullet point Epstein states that no responsive documents exist because he did not share the alleged privilege materials with anyone other than his attorneys CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on October through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration Jack Scarola Karen Terry David Vitale Jr LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Counsel for Counter-Defendant Jeffrey Epstein SERVICE LIST Philip Burlington Nichole Segal Burlington Rockenbach P.A Searcy Denny Scarola Barnhart Shipley P.A Courthouse Commons Suite Palm Beach Lakes Boulevard West Railroad A venue West Palm Beach FL West Palm Beach FL mep searcylaw.com pmb FLAppellateLaw.com jsx searcylaw.com njs FLAppellateLaw.com dvitale searcylaw.com kbt FLAppellateLaw.com scarolateam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff terryteam searcylaw.com Bradley Edwards Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley 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