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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 Epstein Rothstein and Edwards Case No AG Florida Bar No FOWLER WHITE Epstein Rothstein and Edwards Case No AG DEFINITIONS AND INSTRUCTIONS The term Edwards you or your means the party or parties to whom this Request for Production is addressed i.e Defendant/Counter-Plaintiff Bradley Edwards including all persons acting or purporting to act on his behalf Second Amended Counterclaim means the Second Amended Counterclaim which you served on November on the Plaintiff/Counter-Defendant Jeffrey Epstein in this action The term witness means any natural person individual proprietorship partnership limited liability company corporation affiliate subsidiary association organization joint venture firm other business enterprise governmental body group of natural persons or other entity The terms identify describe or provide when used with reference to a natural person means A the full name current telephone number and current business and home addresses or if the current telephone number and/or current business and home addresses are not known the last known telephone numbers and/or business and home addresses of the person Addresses shall include the street and post office box if known and the city _state country and zip code the full name and address of each employer each corporation of which the person is an officer or director and each limited liability company of which the person is a Epstein Rothstein and Edwards Case No AG manager or a member each partnership of which the person is a partner and each other business in which the person is a principal the persons current or if the current is not known the last known position and the position or positions held by the person at the time of the act to which the response to a specific request relates and such other information as is sufficient to provide full identification of the person The terms identify describe or provide when used with reference to any entity other than a natural person means A the full name of the entity the type of entity e.g corporation limited liability company partnership etc the address of its principal place of business its principal business activity the jurisdiction under the laws of which it has been organized and the date of such organization each of the entitys officers directors shareholders managers members partners or other principals any other available information concerning the existence or identity of the entity The terms identify describe or provide when used with reference to a document means A the name or designation of the document docwnent Epstein Rothstein and Edwards Case No AG the name of the person who participated the creation of the the date of the docwnent the person or entity to whom the document is addressed if any and those to whom any copies of the document were addressed or delivered a brief description of the contents of the document and all signatories to the document Doc 265ment means any agreement contract lerier correspondence memorandum report calendar diary appointment book log record including business financial and medical records ledger audit bill invoice statement schedule recording of sound or photographs electronic file whether on disk tape drive or otherwise printout writing drawing sketch notes handwritten or otherwise map blueprint e-mail data compilation and written or recorded material of any kind and character Referring to reflecting evidencing or relating to means any way directly or indirectly concerning referring to disclosing describing confirming supporting evidencing 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 which might otherwise be construed to be outside its scope Person means any individual natural person partnership association firm limited liability company corporation organization trust governmental or public entity and any Epstein Rothstein and Edwards Case No AG of the officers directors shareholders members managers partners agents employees assigns or representatives of the same Substantiate state or explain means to produce documents or things that set forth the circumstances or bases for any belief contention or position or give information or direction in response to a request If documents or things that are responsive to all or part of a specific request are not within your custody possession or control for each state when it was last in your custody possession or control and why it is no longer in your custody possession or control and identify the person that you know has or last had or that you believe has or last had custody possession or control of such document or thing If you do not presently have in your custody possession or control documents or things that are responsive to a request include a statement to that effect and at such time as any responsive document or thing comes into your custody possession or control produce same within ten days of its location and in any event produce it no less than ten days prior to trial Except where otherwise stated the time period for the requests made herein is January through the present Epstein Rothstein and Edwards Case No AG REQUESTS Each and every document that tends to support the claim in your Second Amended Counterclaim that you have suffered damage to your reputation as a result of the filing of this action against you Each and every document that tends to support the claim in your Second Amended Counterclaim that you have suffered damage as a result of interference in your professional relationships Each and every document that tends to support any claim you are making for special damages including loss of income this request specifically shall include but not be limited to production of your federal income tax returns for and records of income in Each and every document that tends to support the claim in your Second Amended Counterclaim that you have suffered money damages resulting from the loss of the value of your time diverted from your professional responsibilities this request specifically shall include but not be limited to the production of all your time and billing records calendars and diaries from through the date on which you respond to this request Each and every document including but not limited to invoices and statements that tends to support the claim in your Second Amended Counterclaim that you have paid money or incurred obligations to pay money for your defense in this lawsuit Each and every document evidencing communications from others with respect to your reputation and standing in the legal community I I I Epstein Rothstein and Edwards Case No AG Witness statements you intend to use in this case All.invoices and statements for legal services and costs incurred for the defense of this action against you Each agreement or other writing memorializing the arrangement pursuant to which you are receiving legal services for the defense of this action including but not limited to a retainer agreement with Searcy Denney Scarola Barnpart Shipley P.A Each and every document that tends to show that your reputation has been damaged as a result of your relationship with Rothstein Rosenfeldt Adler Each and every document reflecting gross collections received from your providing services as a lawyer for each of the years and Invoices statements of account or other documents reflecting treatment for any physical or psychological injury you claim to have suffered as a result of this action being brought against you Each and every document reflecting the method used in calculating your loss of income whether by wages or other remuneration for the period you claim to have suffered damages Each and every document reflecting the method used in calculating your alleged loss of future earning capacity as a direct result of the allegedly wrongful conduct Each and every document reflecting all lost business opportunities you claim to have suffered between the present Epstein Rothstein and Edwards Case No AG Each and every document reflecting the identity of the confidential source listed on your Privilege Log dated February Each and every document reflecting the legal authority that justifies your refusal to disclose the identity of the person identified as a confidential source in your Privilege Log dated February All closing statements for all clients who you represented that brought claims against the Plaintiff and all other documents with respect to such clients reflecting amounts paid to such clients or to you your time referring attorneys and amounts paid to the same advance costs and payments to any other person or entity All records of your contacts with the press or other media outlets Any agreements and communications relating to agreements or potential agreements for the sale of development of or any other transaction relating to movie book or other rights that you may or will benefit from which are related to the claims you or your clients brought against the Plaintiff All documents supporting your alleged belief that law enforcement is still investigating the Plaintiff/Counter-Defendant Jeffrey Epstein including those reflecting communications with or information received from the government/law enforcement media other attorneys or anyone else from which you claim to form this belief All documents supporting your claim that others still persist in prosecuting claims against Jeffrey Epstein Epstein Rothstein and Edwards Case No AG All documents supporting your claims in Paragraphs and of the Second Amended Counterclaim in which you allege the sole purpose of filing civil claims was never to recover monetary damages that Plaintiff/Counter-Defendant Jeffrey Epstein knew he never suffered monetary damages and that he knowingly asserted baseless and unsupportable claims etc
