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 d6h N?M 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 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 CTX I CK M?qr K?SK?PQZ I IRZX 8YCX 10Cy qr CX kv zg S5kB??a iG wA CTX Z6 I L(K4 P:u Z6P CTX y8 Epstein Rothstein Edwards CASE NO Epsteins case Objections were filed based on work product and/or attorney-client privilege and to date no privilege log has been filed Paragraph requested fee sharing agreements between Mr Edwards RRA and/or Scott Rothstein relating to any aspect of Mr Epsteins case Objections were based on relevance and other non-privilege grounds Paragraph of the Complaint demonstrates that these records are relevant Moreover in addition the Defendant Edwards has a counterclaim that seeks damages for among other things his reputation interference in professional relationships loss of value of time required to be diverted from his professional responsibilities The compensation relationship by and between Mr Edwards and/or RRA are relevant to that issue and should be produced Paragraph asks for costs or payment of costs made by the Rothstein firm against Mr Epstein Defendant Edwards response is based on relevance and not on any claim of privilege The Requests are relevant based on the allegations in Paragraphs and of the Complaint Paragraph of the Request is similar to Paragraph in that it requests documentation pertaining to any liens for any attorneys fees or costs asserted by the trustee for RRA The objection is based on relevance Paragraphs and of the Complaint shows that the allegation is relevant Paragraph seeks documents supporting the contention made by the Plaintiff for alleged sexual assaults on airplanes Defendant Edwards objects on several non-privilege grounds which include relevance vague over broad etc See Paragraphs of the Complaint where this is a material part of the Plaintiffs abuse of process claim FOWLER WHITE Epstein Rothstein Edwards CASE NO Paragraph seeks records similar to those described in Paragraphs and Defendant Edwards has not made a privilege claim The documents are relevant See the allegations in Paragraphs and of the Complaint Paragraph seeks the foundation for statements made to the court in one of the pending cases The objection is based on work product for which no privilege log has been provided Objections of vagueness and over broad have also been lodged Paragraph seeks documents relating to potential deponents named by Edwards in each of the three cases against Mr Epstein The objections include work product and attorney-client privilege for which no privilege log has been prepared The documents are relevant based on the allegations contained in Paragraphs of the Complaint and should be produced Paragraph seeks documents supporting Mr Edwards claim for damages with a response of not yet determined Plaintiff Epstein cannot formulate a defense to such a claim in absence of those damages and requests an order compelling the production of those records Paragraph seeks emails exchanged between Mr Edwards and a number of named individuals relating to Mr Epstein The objections are based on attorney-client work product privilege and no privilege log has been prepared Under the case of TIG Insurance Corporation of America Johnson So 2d Fla th DCA and its progeny states that the failure to timely provide a privilege log may be grounds to determine that a waiver of privileges have occurred Given the extraordinary passage of time without the preparation of privilege log the Plaintiff submits those privileges have been waived FOWLER WHITE Epstein Rothstein Edwards CASE NO The Plaintiff submits that the discovery request are reasonable relevant and calculated to lead to other discoverable and admissible evidence The undersigned counsel certifies that this motion is made in good faith and not for the purpose of delay I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this JV day of February to Marc Nurik Esq One East Broward Boulevard Suite Fort Lauderdale FL and Jack Scarola Esquire Palm Beach Lakes Boulevard P.O Drawer West Palm Beach FL i fo;f eke Fla Bar No FOWLER WHITE JEFFREY EPSTEIN Plaintiff SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M Individually Defendants IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Complex Litigation Fla Civ Case No AG EPSTEINS REQUEST TO PRODUCE TO EDWARDS Defendant JEFFREY EPSTEIN Epstein pursuant to Fla Civ requests that Defendant BRADLEY EDWARDS Edwards produce or make available for inspection documents responsive to the requests below within thirty days from the date of service DEFINITIONS AND INSTRUCTIONS A Document means any written or graphic matter or other means of preserving thought or expression and all tangible things from which information can be processed or transcribed including the orlginaHs and all non-identical copies whether different from the original by reason of any notation made on such copy or otherwise including but not limited to correspondence memoranda notes messages letters purchase orders telegrams teletype telefax bulletins e-mails electronic data meetings reports or other communications interoffice and intra-office telephone calls diaries chronological data minutes books reports charts ledgers invoices worksheets receipts returns trade information regarding fabric carpets samples EXHIBIT II I etc computer printouts prospectuses financial statements schedules affidavits contracts cancelled checks transcripts statistics surveys magazine or newspaper articles releases and any and all drafts alterations and modifications changes and amendments of any of the foregoing graphs or aural records or representations of any kind including without limitation photographs charts graphs microfiche microfilm video tape recordings motion pictures and electronic mechanical or electric recordings or representations of any kind including without limitatron tapes cassettes discs and recordings and including the file and file cover The term Document also means any and all computer records data files directories electronic mail and information of whatever kind whether printed out or stored on or retrievable from floppy diskette compact diskette magnetic tape optical or magnetic-optical disk computer memory hard drive zip drive jaz drive orb drive microdisk external memory stick software or any other fixed or removable storage media including without limitation all back-up copies dormant or remnant files and any and all miscellaneous files and/or file fragments regardless of the media on which they reside and regardless of whether the data consists in an active file deleted file or file fragment Communications means any oral or written statement dialogue colloquialism discussion conversation or agreement Plaintiff means L.M L.M Jeffrey Epstein Palm Beach County Case E.W E.W Jeffrey Epstein Palm Beach County Case Jane Doe Jane Doe Jeffrey Epstein United States District Court Case 08-civ-80893-Marra/Johnson and any other person who is or was represented by Rothstein Rosenfeldt Adler that has not yet filed an action against Jeffrey Epstein and any employee agent or attorney for any plaintiff and/or any other person acting for or on behalf of any plaintiff or under her authority and control RRA means Rothstein Rosenfeldt Adler P.A Money means any tangible thing of value Costs include but are not limited to court costs filing fees Sheriffs service and any other necessary service of legal papers or notices or subpoenas court reporters charges long distance telephone charges postage courier services or Federal Express or UPS investigative costs investigative bills photocopies faxes Westlaw computerized research travel expenses and witness fees and expert witness fees and costs Trustee means Herbert Stettin as bankruptcy trustee for RRA REQUEST FOR PRODUCTION For the time period from March to present any and all documents between or on behalf of RRA its employees or agents or cllents and any third party regarding a purported settlement of any litigation between Jeffrey Epstein and a RRA client or Plaintiff or the financing of any litigation between Jeffrey Epstein and a RRA client or Plaintiff whether existing clients or fabricated clients including but not limited to a Documents indicating that litigation with Jeffrey Epstein has been settled Soliciting or receiving money in return for settlement funds allegedly paid or to be paid by Jeffrey Epstein Soliciting money to help finance ongoing litigation against Jeffrey Epstein Soliciting money to be given to or used on behalf of the Plaintiffs In litigation against Jeffrey Epstein Communication between third party investors or potential investors and the Plaintiffs or their attorneys involved in litigation against Due to the potential volume of documents Involved the parties and the Court should consider appointment of a sp cial master and/or an In camera Inspection to address any objections claims of privilege and generally manage the production of docutnents following Jeffrey Epstein Payments made by RRA to or on behalf of any Plaintiff Any and all fee agreements that exist or have existed between the a Any Plaintiff and Bradley Edwards or any entity with which he has been associated Any Plaintiff and the law firm RRA All emails data correspondence memos or similar documents between Bradley Edwards Scott Rothstein WIiam Berger and Russell Adler and/or any attorney or representative of RRA and any investor or third party person or entity regarding Jeffrey Epstein or which mentions Jeffrey Epstein inclu ing Mike Fisten Kenneth Jenne Patrick Roberts or Rick Rich Fandrey All emails data correspondence memos or similar documents between Bradley Edwards Scott Rothstein and/or any attorney or representative of RRA regarding Jeffrey Epstein or which mentions Jeffrey Epstein including Mike Fisten Kenneth Jenne Patrick Roberts or Rick Rich Fandrey All agreements or documents of any nature which were provided to or received from an investor or potential Investor relating to any case real or fabricated involving Jeffrey Epstein and any of the following a Scott Rothstein Bradley Edwards RRA any entity formed by RRA or Bradley Edwards or Scott Rothstein to create investment opportunities for third party investors to invest In any plaintiffs case against Jeffrey Epstein All fee sharing agreements between Bradley Edwards RRA or Scott Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiffs case All documents made available to any investor or potential investor by Bradley Edwards RRA Scott Rothstein or any of Scott Rothstelns entities to solicit investors for any case Involving Jeffrey Epstein All document reflecting the names and addresses of all individuals or entities who invested or purported to Invest in any aspect of any case 267against Jeffrey Epstein All documents evidencing the Costs and payment of any bill or Costs in each Plaintiffs case against Jeffrey Epstein and the source for said payments of any Costs All documents received by you or your current firm wherein the Trustee of RRA has asserted a lien for attorneys fees or Costs arising out of work done and Costs incurred related to the Plaintiffs cases during the time Plaintiffs were represented by RRA All documents and tangible things retrieved from the trash at El Brillo Way Palm Beach Florida which is alleged to be the home of Jeffrey Epstein All conversations recorded from any telephones which purported to be that of Jeffrey Epstein that are contained in any media audio tapes CDs DVDs zip drives hard drives or any other electronic format and any written transcriptions All conversations recorded from any telephones which purported to be from Jeffrey Epsteins attorneys including Roy Black Alan Dershowitz or Jack Goldberger that are contained in any media audio tapes CDs DVDs zip drives hard drives or any other electronic format and any written transcriptions All intercepted phone conversations authorized by RRA including but not limited to any one of Its attorneys or investigators or anyone retained by or working for RRA related to Jeffrey Epstein that are saved or stored in any media audio tapes CDs DVDs zip drives hard drives or any other electronic format and any written transcriptions All Intercepted or acquired electronic mail e-mails to or from Jeffrey Epstein authorized by RRA including but not limited to any one of its attorneys or investigato or anyone retained by or working for RRA All intercepted or acquired electronic mail e-mails to and from the attorneys for Jeffrey Epstein including but not limited to Roy Black Alan Dershowitz or Jack Goldberger authorized by RRA including but not limited to any one of Its attorneys or investigators or anyone retained by or working for RRA All documents supporting the contention that a sexual assault took place on an airplane purportedly owned by Jeffrey Epstein or a Jeffrey Epstein entity at any time between and All documents related to the amount of all Costs that were incurred by you in the representation of you and/or your law firm in representing Jane Doe L.M and E.W prior to joining RRA All documents setting forth to the amount of Costs were incurred by RRA in its representation of Jane Doe L.M and E.W during the time you were employed by RRA or that is being claimed by the Trustee In the attached transcript dated July you stated to Judge Hafele with regard to the E.W and L.M cases the following What the evidence is really going to show is that Mr Epstein at least dating back as far as our Investigation resources have permitted back to or has every single day of his life made an attempt to sexually abuse children Were not talking about five were not talking about were not talking about were not talking about which I believe is the number known to law enforcement we are talking about thousands of children and it is through a very intricate and complicated system that he devised where he has as many as people working underneath him that he is paying well to schedule these appointments to locate these girls A Provide all documents to support this assertion including any documents which are the source of the information All documents related to or mentioning potential deponents in the Jane Doe L.M or E.W cases All documents that support your claim of damages in your counterclaim in this case The written fee agreement with the Searcy Denney firm for their representation of you in this case AJI emails exchanged between you or anyone of your behalf and one or more of the following individuals wherein Epstein a Palm Beach billionaire or a similar reference was mentioned a Scott Rothstein Russell Adler William Berger Michael Fisten Kenneth Jenne David Boden Deborah Villegas Andrew Barnett i Patrick Roberts Richard Rick Fandrey Christina Kitterman A copy of your RRA business card Any employment agreements letter agreements or memos given to you by RRA or a representative or agent of RRA describing your compensation and benefrts at RRA All documents and communications from Herbert Stettin as bankruptcy Trustee for RRA asserting liens against recoveries in a L.M Epstein Case No E.W Epstein Case No Jane Doe Epstein Case No 08-CV-80119-MARRA/JOHNSON Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was ent by fax and U.S Mail to the following addres 267sees on this 12th day of April Gary Farmer Jr Esq Farmer Jaffe Weissing Edwards Flstos Lehrman PL Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Andrews Avenue Suite Fort Lauderdale FL fax Attorneys for Defendant L.M Jack Scarola Esq Suite West Palm Beach FL Fax Co-Counsel for Defendant Jeffrey Epstein MARC NURIK ESQ Searcy Denney Scarola Barnhart Shipley P.A Law Offices of Marc Nurik One East Broward Boulevard Suite Palm Beach Lakes Blvd West Palm Beach FL Fort Lauderdale FL Fax Attorneys for Defendant Bradley Edwards Attorneys for Defendant Scott Rothste;n BURMAN CRITTON LUTTIER COLEMAN LLP Banyan Boulevard Suite West Pal U1g Ro ritton Jr Florida Bar Michael Pike Florida Bar Counsel for Defendant Jeffrey Epstein FAX SEARCY DENNEY IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN lndlvldually BRADLEY EDWARDS lndlvldually and L.M lndMdually Defendant I DEFENDANT BRADLEY EDWARDS RESPONSE TO PLAINTIFFS REQUEST FOR PRODUCTION DATED APRIL Defendant BRADLEY EDWARDS hereby files his Response to Request for Production propounded by Plaintiff on April as follows None a Objection relevance not reasonably calculated to lead to the discovery of admissible ev1dence None Objection as to communications to or from investigators es that Is protected by the work-product and or attorney-client privilege Objection any such communications are protected by the work product and or attorney-client privilege None Objection relevance not reasonably calculated to lead to the discovery of admissible evidence vague overbroad without waiving obJectlon there are no fee agreements with any investor EXHIBIT FAX SEARCY DENNEY Ill Case No Edwards Response to Request for Production dated None None Objection relevance not reasonably calculated to lead to the discovery of admissible evidence Objection relevance not reasonably calculated to lead to the discovery of admissible evidence None None None None None None Objection relevance not reasonably calculated to lead to the discovery of admissible evidence vague overbroad ambiguous Objection relevance not reasonably calculated to lead to the discovery of admissible evidence Objection relevance not reasonably oalcurated to lead to the discovery of admissible evldence and protected by the work-product prlvllege Objection vague overbroad and any and all such documents are protected by the work 225product privilege Objection vague overbroad and any and all such documents are protected by the work-product and artomey-olient privilege Not yet determined FAX SEARCY DENNEY ltJ Case No EdWclrd;S Response to Request for Production dated Objection Objection attorney-client privilege and/or work--product privllege None In Defendants possession None None In Defendants possession FAX SEARCY DENNEY Case No Edwards Response to Request for Production dated CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been kl ji1 fumlshed yja U.S Mail to all counsel on the attached list on Jack Scarola Searcy Denney Scarola Barnhart Shipley P.A Attorneys for Defendant Bradley Edwards Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax FAX SEARCY DENNEY Case No Edwards Resp0nse to Request for Production dated Robert Critton Jr Esquire Michael Pike Esquire COUNSEL LIST Burman Critton Luttier Coleman LLP Banyan Boulevard Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Jack Goldberger Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Gary Farmer Jr Farmer Jaffe Welsslng Edwards Flstos Lehrman P.L Andrews Avenue Suite Fort Lauderdale FL Phone Fax Attorneys for L.M Marc Nurik Law Offices of Marc Nurik One East Broward Boulevard Suite Fort Lauderdale FL Phone Fax Counsel for Scott Rothstein
19,880 characters
