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 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 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 Edwards adv Epstein Case No Plaintiff failed to serve the Trustee Depo Notice on Defendant/Counter-Claimant Bradley Edwards Furthermore the scheduling or canceling of the subject deposition was not coordinated with or communicated to Defendants counsel On February at a.m Trustees counsel Charles Lichtman sent an email to Plaintiffs counsel Defendants counsel and Special Master Robert Camey stating that the Trustee would produce pages of email exchanged between RRA attorneys and government officials and law enforcement officers pursuant to the cancelled Trustee Depo Notice This was the first notice that Defendants counsel received of the existence of the Trustee Depo Notice and the fact that Plaintiff is seeking additional discovery from the Trustee To date Defendants counsel has not received a copy of the putative Trustee Depo Notice Epstein requested thousands of emails from the trustee in his first Trustee discovery request Pursuant to this first request the Trustee turned over more than pages of email to the Defendant that the Trustee identified as being responsive to Epsteins request Edwards and his counsel reviewed all of the email that was turned over The document review clearly demonstrates that the vast majority of email was absolutely irrelevant to any action Epstein is purportedly pursuing Edwards previously filed objections directed to the first discovery request and requested that this Court stay enforcement of the subpoena that resulted in the large volume of irrelevant and otherwise protected emails being dumped on Edwards for review and this Court elected not to intervene since the emails had already been produced but made clear that discovery rulings would be made by this Court for this case Edwards adv Epstein Case No Plaintiffs discovery requests have necessitated that Mr Edwards his counsel and their staff expend hundreds of hours reviewing documents which are the supposed subject of his request The parties previously agreed to the appointment of Robert Carney as a special master before the U.S Bankruptcy Court to address the issues that arose in connection with the first discovery request The parties have agreed to the appointment of Robert Carney as a special master by this Honorable Court OBJECTIONS Edwards objects to the second discovery request the Trustee Depo Notice based on the grounds that the review and production of pages of email is burdensome and the request is overly broad and irrelevant and not reasonably calculated to lead to the discovery of admissible evidence Edwards further objects on the grounds that the requested emails are also protected by the work product doctrine and/or attorney client communication privileges Epstein has absolutely no proof nor any reasonable basis to allege that Edwards was in any way involved in Scott Rothsteins Ponzi scheme yet he continues wage the instant litigation This incredibly voluminous fishing expedition discovery is clearly intended to harass annoy and oppress Mr Edwards since it is not capable of returning any relevant discovery or things that are reasonably calculated to lead to the discovery of admissible evidence Edwards adv Epstein Case No MEMORANDUM OF LAW Plaintiffs Trustee Depo Notice exceeds the permissible scope of discovery Defendant has filed objections to the Trustee Depo Notice contending that the subject requests are not discoverable because they exceed the scope The Court must rule on the objections and the scope of discovery before Defendant has any duty to file a privilege log Gosman Luzinski So.2d 4th DCA A party is required to file a log only if the information is otherwise discoverable Gosman at referring to Florida Rule of Civil Procedure Before a written objection to a discovery request is ruled upon the documents are not otherwise discoverable Gosman at Edwards has objected and claimed that reviewing and producing the I pages of requested email is burdensome and harassing In addition Edwards has objected to this discovery on the grounds that it seeks documents that are irrelevant and not calculated to lead to the discovery of admissible evidence Therefore the scope of the discovery is at issue Until the court rules on the request Defendant does not know what will fall into the category of discoverable documents See Gosman at Defendant/Counter-claimant respectfully requests that the Court appoint Robert Camey as a special master to make a report to the Court concerning all objections raised to the second discovery request Moreover Edwards seeks an order directing Mr Camey to conduct any in camera review of the email and to hold any hearings that he deems necessary to prepare a report addressing the asserted objections Edwards adv Epstein Case No WHEREFORE Defendant/Counter-Claimant respectfully requests that the Court grant the following relief a Grant this motion for protective order and enjoin the production of any email documents or things from Trustee Stettin to Plaintiff in connection with the Trustee Depo Notice Sustain Defendant/Counter-Claimants Objections to discovery and prohibit any discovery from being made responsive to the Trustee Depo Notice on this basis Appoint Robert Carney as a Special Master to issue a report to the Court on all contested discovery issues And to grant such other and further relief as may be deemed just I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Fax and U.S Mail to all Counsel on the attached listJi_s Jack Sea la Florid a enney Scarola Barnhart Shipley alm Beach Lakes Boulevard st Palm Beach Florida Phone Fax Attorney for Bradley Edwards Edwards adv Epstein Case No COUNSEL LIST Jack A Goldberger Esquire Atterbury Goldberger Weiss P.A Attorney For Jeffrey Epstein Australian Avenue South Suite West Palm Beach FL Phone Fax Farmer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Avenue Suite Fort Lauderdale FL Phone Fax Marc Nurik Esq Law Offices of Marc Nurik Attorney For Scott Rothstein One Broward Blvd Suite Fort Lauderdale FL Phone Fax Joseph Ackerman Jr Esquire Fowler White Burnett P.A Attorney For Jeffrey Epstein Phillips Point West Flagler Drive West Palm Beach FL Phone Fax From Charles Lichtman mailto:CLichtman bergersingerman.com Sent Wednesday February AM To Lilly Ann Sanchez Robert Carney Gary Farmer Seth Lehrman Cc Hmstettin bellsouth.net Subject MORE DOCUMENTS re Epstein As you know Mr Epsteins counsel served upon the Trustee a refined email search which sought documents reflecting communications between RRA lawyers and state and or governmental officials largely if not all law enforcement officers I now have a disc of documents for each of you responsive to the subpoena bate stamped pages through I have not reviewed the disc at all and based upon the search terms I highly doubt there is anything that could qualify as privileged since the search terms by definition included solely third party communicati?ns Nevertheless i an abundance of caution we will review our standard protective order just to make sure the estate Is protected Assuming that to be the case I intend to then forward to each of you a copy of the disc BERGER SINGERMAN Charles Lichtman East Las Olas Boulevard Suite Fort Lauderdale FL Telephone Fax Direct Line attotneys at law E-mail Clichtman bergersingerman.com Boca Raton Ft Lauderdale Miami Tallahassee w.bergersingerman.com Please consider the environment before printing this email This transmission is intended to be delivered only to the named addressee and may contain information that is confidential proprietary attorney work-product or attorney-client privileged If this information is received by anyone other than the named and intended addressee the recipient should immediately notify the sender by E-MAIL and by telephone at the phone number of the sender listed on the email and obtain instructions as to the disposal of the transmitted material In no event shall this material be read used copied reproduced stored or retained by anyone other than the named addressee except with the express consent of the sender or the named addressee Thank you CIRCULAR DISCLAIMER This communication does not constitute a covered opinion as such term is defined within Circular and does not comply with the requirements for a covered opinion We have not conducted nor have we been asked to conduct that type of analysis in this communication To EXIDBIT A
