JEFFREY EPSTEIN Plaintiff SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants IN THE CIRCUIT COURT OF THE FIFfEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Complex Litigation Fla Civ Case No CA AG SUBPOENA DUCES TECUM FOR DEPOSITION THE STA TE OF FLORIDA TO Ms Conchita Sarnoff Grapetree Dr Unit llCS Key Biscayne FL YOU ARE COMMANDED to appear before a person authorized by law to take depositions at the law offices of Fowler White Burnett P.A Brickell Ave th Floor Miami FL on the th day of May at a.m for the taking of your deposition in this action and to have with you at that time and place the following See Attached Schedule A If you fail to appear you may be in contempt of court You are su oenaed to appear by the following attorney and unless excused from this subpoena by this a orney or the court you shall respond to this subpoena as directed For the Court Lilly Ann Sanchez Fowler White Burnett P.A Attorneys for Plaintiff Jeffrey Epstein FOWLER WHITE SCHEDULE A I Definitions Document as used herein means any document known to you and every such document which can be located or discovered by your reasonably diligent efforts and any original or copy of such in your custody possession or control including but not limited to any printed whether typed or written by hand recorded taped electronic e.g e-mails and text messages graphic or other tangible matter from any source however produced or reproduced whether in draft or otherwise whether sent or received or neither including the original and any copies which contain markings or notations all attachments amendments and addenda of any and all writings all correspondence notes notations recordings or other memorials of any type of face to face or telephone conversations and interviews meetings or conferences including but not limited to telephone bills and long distance charge slips letters telegrams facsimiles cables papers newsletters memoranda inter-office communications releases agreements contracts books pamphlets minutes of meetings reports analyses evaluations statements diaries calendars desk pads appointment books stenographers notebooks transcripts worksheets journals summaries lists tabulations digests newspapers periodical or magazine materials and any material underlying supporting or used in the preparation of any documents or record whatsoever Written communications means any Documents evidencing communications between you and another person or persons of any kind including but not limited to e-mails and text messages transcripts and notes Referring to reflecting regarding supporting evidencing or relating to means in any way directly or indirectly concerning disclosing describing confirming or representing And and or shall be construed in the disjunctive or conjunctive as necessary in order to bring within the scope of each request all documents which might otherwise be construed to be outside its scope Epstein refers to Jeffrey Epstein the Plaintiff in the captioned lawsuit Sarnoff you or yours refers to Conchita Sarnoff Edwards means Bradley Edwards a defendant in the captioned lawsuit Rothstein means Scott Rothstein a defendant in the captioned lawsuit RRA means the law firm of Rothstein Rosenfeldt Acller P.A and any of its past or present employees independent contractors attorneys partners shareholders investigators agents or other representatives and persons purporting to be affiliated with such law firm Searcy Denny means the law firm of Searcy Denney Scarola Barnhart Shipley P.A and any of its past or present employees independent contractors attorneys partners shareholders investigators agents or other representatives of or persons purporting to be affiliated with such law firm Farmer Jaffe means the law firm of Farmer Jaffe Weissing Edwards Fistos Lehrman P.L and any of its past or present employees independent contractors attorneys partners shareholders investigators agents or other representatives of or persons purporting to be affiliated with such law firm Person means any individual natural person partnership assoc1at1on firm including law firms corporation organization trust and any of his/her or its agents employees assigns or representatives Unless otherwise stated the time frame for this Subpoena covers matters and Documents from January through the present II Documents Requested Any and all Documents reflecting or memorializing communications for the purpose of writing a book whether such communications be oral or written between you and Edwards Rothstein or any past or present employees independent contractors attorneys partners shareholders agents or other representatives of or persons purporting to be affiliated with RRA including without limitation Mike Fisten Ken Jenne Wayne Black Patrick Roberts Patrick Diaz Rick Fandry Cara Holmes William Berger Russell Adler and Mark Nurik or any other representatives of or persons purporting to be affiliated with RRA or representing themselves to have knowledge of RRAs cases against Epstein at any time regarding any pending or contemplated litigation past or settled litigation investigations surveillance incidents of misconduct or claims in any way involving or alleged to involve Epstein Any and all Documents reflecting or memorializing communications for the purpose of writing a book whether such communications be oral or written between you and Edwards or any past or present employees independent contractors attorneys partners shareholders agents or other representatives of or persons purporting to be affiliated with Farmer Jaffe regarding any pending or contemplated litigation past or settled litigation investigations surveillance incidents of misconduct or claims in any way involving or alleged to involve Epstein Any and all Documents reflecting or memorializing c:ommunications for the purpose of writing a book whether such communications be oral or written between you and any of the following persons regarding any pending or contemplated litigation past or settled litigation investigations surveillance incidents of misconduct or claims in any way involving or alleged to involve Epstein A Paul Cassell Spencer Kuvin Stuart Mermelstein any past or present employees independent contractors attorneys partners shareholders agents or other representatives of or persons purporting to be affiliated with Searcy Denney including without limitation John Jack Scarola and any other attorneys who disclosed to you that they represent or represented in the past clients who have or had had claims against Epstein Any and all Documents reflecting or memorializing communications for the purpose of writing a book whether such communications be oral or written between you and any of the following persons regarding any pending or contemplated litigation past or settled litigation investigations surveillance incidents of misconduct or claims in any way involving or alleged to involve Epstein including investments in actual or purported settlements of claims involving or alleged to involve Epstein A A.J Discala and any persons who claim to have invested directly or indirectly with Rothstein including without limitation those who invested in Razorback Funding LLC or D3 Capital Club LLC Any and all Documents that you received for the purpose of writing a book from any of the persons including law firms identified in items above Any and all Documents that you sent delivered or transmitted for the purpose of writing a book to any of the persons including law firms identified in items above Any and all Documents reflecting or memorializing communications for any purpose other than writing a book whether such communications be oral or written between you and Edwards Rothstein or any past or present employees independent contractors attorneys partners shareholders agents or other representatives of or persons purporting to be affiliated with RRA including without limitation Mike Fisten Ken Jenne Wayne Black Patrick Roberts Patrick Diaz Rick Fandry Cara Holmes William Berger Russell Adler and Mark Nurik or any other representatives of or persons purporting to be affiliated with RRA or representing themselves to have knowledge of RRAs cases against Epstein at any time regarding any pending or contemplated litigation past or settled litigation investigations surveillance incidents of misconduct or claims in any way involving or alleged to involve Epstein Any and all Documents reflecting or memorializing communications for any purpose other than writing a book whether such communications be oral or written between you and Edwards or any past or present employees independent contractors attorneys partners shareholders agents or other representatives of or persons purporting to be affiliated with Farmer Jaffe regarding any pending or contemplated litigation past or settled litigation investigations surveillance incidents of misconduct or claims in any way involving or alleged to involve Epstein Any and all Documents reflecting or memorializing communications for any purpose other than writing a book whether such communications be oral or written between you and any of the following persons regarding any pending or contemplated litigation past or settled litigation investigations surveillance incidents of misconduct or claims in any way involving or alleged to involve Epstein A Paul Cassell Spencer Kuvin Stuart Mermelstein any past or present employees independent contractors attorneys partners shareholders agents or other representatives of or persons purporting to be affiliated with Searcy Denney including without limitation John Jack Scarola and any other attorneys who disclosed to you that they represent or represented in the past clients who had claims against Epstein Any and all Documents reflecting or memorializing communications for any purpose other than writing a book whether such communications be oral or written between you and any of the following persons regarding any pending or contemplated litigation past or settled litigation investigations surveillance incidents of misconduct or claims in any way involving or alleged to involve Epstein including investments in actual or purported settlements of claims involving or alleged to involve Epstein A A.J Discala and any persons who claim to have invested with Rothstein including without limitation those who invested in Razorback Funding LLC or D3 Capital Club LLC Any and all Documents that you received for any purpose other than writing a book from any of the persons including law firms identified in items above Any and all Documents that you sent delivered or transmitted for any purpose other than writing a book to any of the persons including law firms identified in items above Any and all Documents relating to reflecting or memorializing the substance of interviews about Epstein you conducted with or research information or materials about Epstein you obtained from any person purporting to be affiliated with RRA or representing themselves to have knowledge of RRAs cases against Epstein for the purpose of writing a book Any and all Documents relating to reflecting or memorializing the substance of interviews about Epstein you conducted with or research information or materials about Epstein you obtained from any person purporting to be affiliated with RRA or representing themselves to have knowledge of RRAs cases against Epstein for any purpose other than writing a book WED JEFFREY WED FAX rO 245ler wru.t:.e tturnc,t:.t Lilly Sanchez Powler White Burnett P.A Attorneys for Plaintiff Jeffrey Ep FOWLER WHITE WED FAX Fowier wnite Hurnett SCHEDULE A I Definitions Document us used herein meurns uny dot.:umenl known lo you and every such document which 1:un be located or discovered by your reasonably diligent efforts and any original or copy of such in your custody possession or control including but not limited to any printed whether typed or written by hum recorded taped ele tronic e.g e-muils and text messuges graphk or other tangible mauer rrom any source however produced or reproduced whether in draft or otherwise whcU1c1 sent or received or nclthcr including the original and any copies which contain markings or notations all attachment amendments and addenda of any and all writings all con-cspondcncc notes notations recordings or other memorials of nny type of foce to fnce or telephone conversations and interviews meetings or conferences including but nvt limited tu tdephone hills nnd long distance charge slips leuen telegrams facsimiles cables papers newsletters memoranda jnter-office communications releases agreements contracts books p11mphlets minute of meetings repo11.s unulyses evuluution.i stutem nl diaries calendars desk padr appointment hooh stenographers notebooks transcripts worksheets journals snnunarics lists tabulations digests newspapers periodical or mugazine materials und uny material underlying supporting or used in the prepurution of uny documents or teC rd whatsoever Written communications means any Documents evidencing communications between you and another person or persons of uny kind including but not limited to e-muils und text messuges transcripts un notes Refen-ing lo renecting regarding supporting evidencing or relating tu meuns in uny way directly or indirectly conccming di1:closing describing confirming or representing And and or shall be construed in the disjunctive or conjunctive as necessary in order to bring within the scope of each request all documents which might otherwise be construe lo be outsid ils scope Epstein refers to Jeffrey Epstein the Plaintiff in 1he captioned lttw uit Samoff you or yoms refers to Conchita Sarnoff Edwards means Bradley Edwards a defendant in the captioned law uit Rothstein mew1s Scott Rothstein a defendant in tl1c captioned lawsuit RRA means the law firm of Rothstein_ Rosenfeldt Adlel P.A WHI uny of it pw;t or present employees independent contractors attorneys pwtners shareholders investigators agents Oll other representatives w1d persons purporting tu be uffiliutecl with such law firm Searcy Denny meuns the luw fim1 of Senrcy Denney Scarola Bamharl Shipley P.A and any or its pa1;t or present employees independent contractors attorneys parcners shareholders investigators agents or other representutives of or persons purpo1ting to be affiliated with such 1uw firm Fu1mer Juffo means the lnw lim1 or Pam1cr Jaffe Wcissing Edwards Fistos l,ehrmun P.L and any of its past or present employees independent contractors attorneys partners shareholders h1vestigators agents or other representutiws of or ptm;ons purporting to be affiliuted with sul:h luw finn Pen;on means any individual natural person pattnership association firm including lriw firms corporation organization tmst w1d ony of his/her or its agents employees assigns or representntives Unless otherwise stated the time frame fur this Subpoena covers matters ond Documents from J1muusy I through lhe present II Documents Requested Any nnd all Documents reflecting or memorializing communications for the purpose of writing a book whether such communications be orul or written between you rutd Edwnrds Rothstein or uny pusl or present employees independent conLractors ullomeys puitners shureholders agents or other representatives of or persons purporting to be affiliated with RRA including without limitation Mike Fisten Ken Jenne Wayne Black Patrick Robe1ts Patrick Diaz Rick Fw1ctry Cara Holme Willium Berger Russell Adler und Murk Nurik or uny other representutives or or persons purporting Lo be affiliated with RRA or representing themselves have know1cdge of RRA cases against Epstein at any time regarding nny pending or contemplated litigation past or seletl litigation invei;ligations surveillunce i11cidenli of misconduct or claims in any way involving or alleged to involve Epstein Any and all Documents rctlccting or mcmoriallziug communications for the purpose of writing a book whether such communications be oral or written between yon and Edwards or any past or present employees independent contructors attorneys purt.ners shareholders ugents or other representative of or person purporting to be ufliliated with Funner Jaffe regarding any pending or contemplated litigation past or scttlcd litigation investigations surveillance incidents of misconduct or claims in nny wuy involving or alleged to involve Epstein Any and all Documents reflecting or memorializing communications for tl1e purpol!e of writing a book whether such communicutiom be orul or written between you und uny of the following persons regurding any pending or contempluter.l liligution pust or seltled litigation invesLigations surveillance incident of misconduct or claims in any way involving or alleged to involve Epstein A Paul Cassell Spencer Kuvin Stua11 Mermelstein uny pust or present employees independent conu 267actors c1ttorncys partners shareholders agents or other represenlotives of OT persons purporting to be affiliated with Searcy Denney including without limitation John ck Scarola and any other attorneys who disclosed to you th:it they represent or rnpresenLed in the pusl clients who huve OT hud hud cluims against Epstein Any and all Documents rellecling or memoriuli;dng communicutiorui for the purpose of writing a book whether such communications be oral or wriuen between you und uny of the foJlowing persons regw 267ding any pending or contemplated litigation pa or seuled litigation investigations survt:illunce incidents of misconduct or claims in any way involving or alleged to involve Epstein including investments in uctuul OT purpo1ted settlements of claims involving or alleged to involve Epstein A A.J Discala and any persons who claim to have invested direcLly or indirectly with Rothstein including without limitation those who invested in Razorback Funding LLC or D3 Capitol Cluh LLC Any and oil Documents thal you received for the purpose of writing a book from ny of the persons including law firms identified in items ubove AJ1y and all Documci1ts tl1at yon s.cnl delivered or trunsmitted for the purpose of writing book to uny of the persons including law firms identified in items al?Qve Any uml all Documents reflecting or memorializing communications for any purpose other tlrnn writing a book wheU1cr such communications he OTul or written between you um Bdwnrd Rothstein or uny pust or present employees independent contractors uuomey!i partners shareholders agents or other repre1;enlalives of or persons purporting to be affiliated with RRA including without limitation Mike Pistcn Ken Jenne Wayne Bluck Putrick Roberts Patrick Diu7 Rick Fandry rn Holmes William Berger Russell AdJcr and Mark Nurik or any other representative of or persons purporting to be uffiliuted with RR.A or representing WED Fl 267ow:J.er wn z,u,:nei..i them.selvei to have knowledge of R,RAs cases against Epstein ut uny time regur ling uny pending or contemplated litigation pust QI ettled liLiguLion investigations iiurveillance incidents of misconduct or claims in uny way involving or alleged to involve Epstein Any und ull Documents re11ecting or memorializing communications for any purpose other than writing a book whether such communications be ornl or written between you and Edwards or any past or present employees independent contrm.:Lors ullomeys partners hareholders agents or other representatives of or person purporting to be affiliated with Parmer Juffe regarding any pending or contemplated litigation past oi settled litigation inve11tigntions surveillance incidents of misconduct or claims in uny wuy involving or ulleged to involve Epstein Any und all Documents renecling or memorializing communkulions for ony purpo other lhun writing book whether such communications be ornl or written between you and any of the following persons regarding JJny pending or contempl11ted litigation past or settled litig11tion inve:stigutions surveillum:e incidenl:-i of misconduct or cluims in uny wuy involving or ulleged to involve Ep tein A Paul Cassell Spencer Kuvin Stuart Mermelstein any past or present employees independent contractors attorneys pmtners sh11reholders ugents or other represenlutivr;:s of or per.c;ons purporting lo be uffiliutt with Searcy Denney including without limitation John Jack Scarola and any other attorneys who disclo ed to you that they represent or represented in Lhe past clients who had claims against Epstein Any and all Documents reflecting or memorializing communications for any purpose other than writing a book whether 11ueh communications be oral or written between you and any of the following person regunling uny pending or contempluted litigation p11st or seletl li1iga1ion inves1igri1ions surveillance incidents or mii.conduct or duims in uny wuy involving or alleged to involve Epstein including investments in actual or purported settlements of claims involving or alleged to involve Epstein A A.J Disc..:ulu und nny persons who claim have invested with Rothstein including without limitation those who invested in Razorback Pund1ng LLC or D3 Capital Club LLC Any and all Documents that you received for any purpose other than writing a book from uny of the persvns in luding law firms identified in items 7-IO nbove WED FAX Fo er wn te surnett Any ancl all Documents that you sent delivered or trunsmiued or nny purpose other than wJit1ng a book to any of the er:,ons induding low fim1s identified in items above Any and ull Documents relating to reflecting or memorializing the substance qf inte1views about Epstein you conducted with or research infon11ution or muteriuls abo Epstein you obtained from any person purporting to be uffilialed wirh RRA or representing themselves to have knowledge ufRRAs cnse.ci against Epstein for the purpose of writing book Any und all Documents relating to rctlccting or memorializing the substance of interviews uhoul Ep,qlein you conducted with 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