IN THE CIRCUIT COURT OF THE th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CIVIL DIVISION AG CASE NO Judge David Crow JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiffs I NOTICE OF PROPOUNDING PLAINTIFFS THIRD 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 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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 nwnber and current business and home addresses or if the current telephone nwnbers and/or current business and home addresses are not known the last known telephone nwnbers and/or business and home addresses of the person._ Address 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 each limited liability company of which the person is a manager Epstein Rothstein and Edwards Case No AG 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 interrogatory answer 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 document Epstein Rothstein and Edwards Case No AG the name of the person who participated the creation of the the date of the document the person or entity to whom the documerifis 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 Document means any agreement contract letter 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 in 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 interrogatory 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 principals agents employees assigns or representatives of the same Substantiate state or explain means to set forth the circumstances or bases for any belief contention or position or to give information or direction in response to a question If all the information furnished in an answer to all or part of an interrogatory is not _within your personal knowledge identify each person to whom all or part of the information furnished is a matter of personal knowledge and each person who communicated to you any part of the information furnished If the answer to all or any part the interrogatory is not presently known or available to you include a statement to that effect furnish the information known or available and respond to the entire interrogatory by supplemental answer in writing under oath within ten days from the time the entire answer becomes known or available and in any event no less than ten days prior to trial Whenever in any answer to any interrogatory a reference made to one or more persons specify by name the particular person to whom the reference is intended Epstein Rothstein and Edwards Case No AG INTERROGATORIES Identify each and every fact that supports the allegations set forth in your Second Amended Counterclaim by providing a a detailed description of the damages you allege you have suffered including but not limited to those you claim have resulted in injury to your reputation and interference in your professional relationships and a detailed description of the special damages you allege that you have suffered including but not limited to the loss of the value of your time diverted from your professional responsibilities and the cost of defending claims against you in this lawsuit Explain in detail how your reputation has been injured as a direct result of this action against you from the filing of this action to the present With specificity identify the following a Your alleged reputation prior to the filing of this action Any and all persons who have made statements about your reputation after the filing of this action Any and all communications whether verbal or written made about your reputation and Epstein Rothstein and Edwards Case No AG The date manner and substance of communications which said statements have been made about your reputation Explain in detail how the filing of this action against you has interfered with your professional relationships and for each such relationship a identify its nature and the person with whom you have or had the relationship specify exactly how the relationship has been interfered with identify each person with knowledge of the interference and identify actual damages as a result of such interference Identify each and every witness that has knowledge of the damages you seek to recover in this action including but not limited to your employer your partners your family members associates colleagues referral sources and clients and for each describe the nature of his or her knowledge Explain the basis for your claim that your reputation has been injured by the allegations against you in this action Explain the method by which you have distinguished injury to your reputation resulting directly from allegations against you in this action from injury to your reputation resulting from your having been a partner in the defunct firm of Rothstein Rosenfeldt Adler Identify all fees and costs that you have incurred for the defense of this action against you Epstein Rothstein and Edwards Case No AG If you have a written engagement agreement with the firm of Searcy Denny Scarola Barnhart Shipley P.A describe the date of the agreement the scope of services and the terms on which your counsel are to be compensated If you do not have a written engagement agreement with the firm of Searcy Denny Scarola Barnhart Shipley A describe the terms of your oral representation agreement the scope of services and the terms on which your counsel are to be compensated Identify any other attorney and firm with whom you have any relationship in conn ction with your defense of this action If you or another on your behalf have paid any legal fees and costs incurred for the defense of this action provide the amounts paid and the date of each payment State by week or month the amount of hours that you devoted to your professional work since the filing of this action against you in and and describe in detail the source of this information e.g time sheets personal diary manual or computer calendar State by week or month the amo of hours that you have devoted to your professional work during the two ye_ars prior to the filing of this action against you in and and describe in detail the source of this information e.g time sheets personal diary manual or coqiputer calendar State the amount of gross income that you received from providing services a lawyer for each of the years and and identify the source of that income including the payor of the same Epstein Rothstein and Edwards Case No AG State the amount of gross income that you received from the provision of goods or services other than while acting as a lawyer for each of the years and and identify the source of that income including the payor of the same State the amount of hours that you have devoted to pro bono work for the years and and substantiate your answer with the names of the cases or causes for which you provided such service You claim damages for emotional distress embarrassment and mental anguish_ as a result of this action against you Have you sought professional medical or psychological services If so a identify each provider of such services state the dates during which you received treatment or assistance for such services and state the amount of money you have paid for such services If you have not sought professional medical or psychological services please explain why If you claim to have suffered any loss of income wages or other remuneration as a result of the claims made against you in this action describe in detail a the nature of the lost income whether by wages or other remuneration e.g loss of clients loss of earnings for hours engaged in the practice oflaw etc the amount of lost income whether by wages or other remuneration for each period for which you typically receive the above e.g if you bill or otherwise keep track of Epstein Rothstein and Edwards Case No AG legal services you provide by the hour the number of hours which you were unable to perform such services for each month since the filing of this action the duration of the loss i.e the date the loss commenced and concluded the basis for determining the loss i.e identify the specific client and matter and the method used in calculating your loss of income whether by wages or other remuneration for the period you have claim to have suffered damages If you are claiming that you have suffered loss of future earning capacity as a result of the allegedly wrongful conduct describe with specificity a the duration of the lost future earning cap11city the amount of the lost future earning capacity and the basis for your calculation If you are claiming to have lost business or employment opportunities as a result of the allegedly wrongful conduct of the plaintiff describe each with specificity and for each state the amount of money damages you seek to recover Describe the method used in-calculating your loss of future earnings With respect to each alleged lost business opportunity please state for each the following a the name and address of the employer client attorney or entity who offered or pre_sented the business opportunity that you claim was lost the nature and scope of work involved in the lost business opportunity Epstein Rothstein and Edwards Case No AG the amount of compensation or remuneration you estimated that you would earn or be paid had you undertaken the opportunity and the basis for that estimation and the date you determined that you had lost the business opportunity State each instance in which you have spoken to or communicated with the press or any other media representative relating to Plaintiff Jeffrey Epstein Provide the identity of each contact the date of the contact and a description of the communication Identify the confidential source listed on your Privilege Log in this case dated February I Identify the legal basis for including a confidential source in your Privilege Log Provide an explanation for your belief that law enforcement is still investigating the Plaintiff/Counter-Defendant Jeffrey Epstein Identify contacts with government/law enforcement media other attorneys or anyone else from which you claim to form this belief including the names dates substance of communication etc Identify the basis for your claim that others still persist in prosecuting claims against the Plaintiff/Counterdefendant Jeffrey Epstein Identify the persons still prosecuting claims against the Plaintiff/Counterdefendant or with knowledge of the persons still prosecuting claims against him including names dates of contact with such persons substance of communication etc Provide support for 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 Epstein Rothstein and Edwards Case No AG Identify all clients and list all payments made to clients in connection with their cases against the Plaintiff/Counter-Defendant Jeffrey Epstein Identify all third parties non-clients who received or made payments in connection with the client cases or purported client cases against the Plaintiff/Counter-Defendant Jeffrey Epstein and with specificity I explain the relationship of such third parties list the payments made to or by each and list the date of payments and purpose of payments Your answer should include without limitation all investigators witnesses referring persons referring attorneys outside counsel outside experts It should also include any and all payments made to or by investors in any of the client cases against the Plaintiff/Counter-Defendant Jeffrey Epstein or payments made by or to any other person in connection with the client cases Identify all attorneys who worked on the client cases against Plaintiff/Counter Defendant Jeffrey Epstein including but not limited to the attorneys formerly at Rothstein Rosenfeldt Adler the attorneys at Farmer Jaffe Weissing Edwards Fistos Lehrman PL outside attorneys and referring attorneys Identify all members of support staff paralegals secretaries investigators etc who worked on client cases against the Plaintiff/Counter-Defendant Jeffrey Epstein including but not limited to Bradley Edwards office the attorneys formerly at Rothstein Rosenfeldt Adler the office of Farmer Jaffe Weissing Edwards Fistos Lehrman PL and offices of outside attorneys and referring attorneys Identify any agreements proposals offers discussions negotiations etc related to the sale or development of any movie book or other rights or similar deals Epstein Rothstein and Edwards Case No AG Under penalty of perjury I do hereby swear and affirm that the answers to the foregoing interrogatories are true and correct STATE OF FLORIDA ss COUNTY OF BRADLEY EDWARDS The foregoing instrument was acknowledged before me this day of by BRADLEY EDWARDS who_ is personally known to me or has produced as iden tfication and who did did not take an oath Sworn to and subscribed before me this day of SEAL Signature of Notary Public Print Name My Commission Expires
