Filing E-Filed AM JEFFREY EPSTEIN Plaintiff SCOTT ROTHSTEIN et al Defendants I IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No Severed Claim Epstein Rothstein PLAINTIFFS REQUEST FOR PRODUCTION TO DEFENDANT SCOTT ROTHSTEIN IN THE EPSTEIN ROTHSTEIN SEVERED CLAIM Plaintiff Jeffrey Epstein pursuant to Florida Rule of Civil Procedure requests that Defendant Scott Rothstein produce the following documents within the time permitted under Rule or a shorter time as the Court may order DEFINITIONS 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 FILED PALM BEACH COUNTY FL SHARON BOCK CLERK AM 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 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 summaries 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 Scott Rothstein and his representatives attorneys accountants agents and any other person acting under his control or on his behalf Relates to or relating to mean authorizing concerning 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 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 the Rothstein Adler law firm 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 Request for Production 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 Request for Production 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 LSI 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 REQUEST FOR PRODUCTION All communications and documents presented to actual or potential investors or their representatives and other third parties in connection with the Ponzi scheme for which you were convicted CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on July through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration 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 Plaintiff Jeffrey Epstein SERVICE LIST Marc Nurik Law Offices of Marc Nurik Broken Sound Parkway Suite Boca Raton FL marc nuriklaw.com Counsel for Defendant Scott Rothstein Jack A Goldberger Atterbury Goldberger Weiss P.A Australian Avenue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff Jeffrey Epstein
