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Epstein Release Interview Victim Statements Evidence Maxwell
← Back to Epstein v. Rothstein, No. 50-2009-CA-040800-XXXX-MB (Fla. 15th Cir. Ct. 2009)
Extracted Text

JEFFREY EPSTEIN Plaintiff/Counter-Defendant vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually Defendant/Counter-Plaintiff I Electronically Filed PM A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S 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 H?o I Idc rM?M rM 10Cy f헊?f?Tz e?e:Aa 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 y!k N?M??N rC f?Nla3 Yz 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 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 had impermissibly served these Subpoenas Duces Tecum Without Deposition upon the attorneys simultaneously with serving the copies of the Subpoenas on Epstein On September Epstein was also informed that Edwards served one of Epsteins former attorneys with a Subpoena Duces Tecum without Deposition for whom a copy was never even sent to Epstein Lilly Sanchez Accordingly Epstein requests that this Court quash the subpoenas preclude Edwards from seeking discovery from Epsteins former counsels on the eve of trial and award attorneys fees and costs as sanctions for Edwards flagrant disregard for the Rules MEMORANDUM OF LAW Epsteins former attorneys are irrefutably not parties to this action As such Rule of the Florida Rules o/Civil Procedure governs Rule provides A party desiring production under this rule shall serve notice as provided in rule on every other party of the intent to serve a subpoena under this rule at least days before the subpoena is issued if service is by delivery and days before the subpoena is issued if the service is by mail or e-mail The proposed subpoena shall be attached to the notice and shall state the time place and method for production of the documents or things and the name and address of the person who is to produce the documents or things if known and if not known a general description sufficient to identify the person or the particular class or group to which the person belongs shall include a designation of the items to be produced and shall state that the person who will be asked to produce the documents or things has the right to object to the production under this rule and that the person will not be required to surrender the documents or things A copy of the notice and proposed subpoena shall not be furnished to the person upon whom the subpoena is to be served If any party serves an objection to production under this rule within days of service of the notice the documents or things shall not be produced pending resolution of the objection in accordance with subdivision Fla R.Civ Here Epstein filed a timely objection to the subpoenas as delineated by the Rule Conversely Edwards in flagrant disregard for this Rule failed not only to provide the requisite notice but also immediately and impermissibly served these subpoenas upon Epsteins former attorneys forcing Epstein to file this Motion Edwardss actions mandate that this Court quash the subpoenas prohibit Edwards from seeking the information requested in the improper subpoenas and award Epstein his costs and fees incurred in responding to Edwards impermissible tactics Epsteins timely objection to the subpoenas duces tecum would have been self-executing and would not have required Epstein to incur the additional costs and fees associated with responding to Edwardss disregard of procedure See ABC Liquors Inc Berkey So 2d Fla.5th DCA see also Rule If the person upon whom the subpoena is served objects at any time before the production of the documents or things the documents or things shall not be produced under this rule and relief may be obtained pursuant to the rule governing depositions Morgan Colling Gilbert P.A Pope So 2d Fla 2d DCA However because Edwards impermissibly served these subpoenas upon Epsteins former counsel he must seek redress from the Court The court upon motion made promptly and in any event at or before the time specified in the subpoena for compliance therewith may quash or modify the subpoena if it is unreasonable and oppressive Fla R.Civ Likewise a party who successfully opposes a subpoena duces tecum may be awarded attorneys fees Expeditions Unlimited Inc Rolly Marine Services Inc So 2d Fla 4th DCA Here subpoenas requesting information from Epsteins former attorneys regarding their representation of him which were impermissibly served upon them on the eve of trial and without compliance of the Rules of Civil Procedure are irrefutably and on their faces unreasonable and oppressive mandating that they be quashed and sanctions awarded See Exhibit A While it is apodictic that one who is a party has no standing to object to a subpoena issued to a non-party witness unless that subpoena asks for documents in which the party claims some personal right or privilege or asks for documents in the partys possession Engel Rigot So 2d Fla 3d DCA Pearson concurring it is obvious from the face of the subpoenas in the instant case not only that Epsteins timely objection to the issuance of the subpoenas was proper but also that he has standing to move this court to quash them Accordingly Edwards attempts to circumvent the Rules and this privilege mandate that these subpoenas be quashed and sanctions awarded CONCLUSION For all of the reasons cited above and in reliance upon the law cited herein Epstein requests that this Court enter and Order Quashing Edwardss Subpoenas precluding him from seeking this discovery from Epsteins former attorneys on the eve of trial and awarding attorneys fees incurred in the bringing of this Motion WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via electronic service to all parties on the attached service list this September Isl Tonja Haddad Coleman Tonja Haddad Coleman Esq Florida Bar No Tonja Haddad PA SE th Street Suite Fort Lauderdale Florida facsimile Attorneys for Epstein SERVICE LIST CASE NO Jack Scarola Esq jsx searcylaw.com mep searcylaw.com Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach FL Jack Goldberger Esq jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss PA Australian Ave South Suite West Palm Beach FL Marc Nurik Esq East Broward Blvd Suite Fort Lauderdale FL Bradley Edwards Esq brad pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman Andrews Avenue Suite Fort Lauderdale Florida Fred Haddad Esq Dee FredHaddadLaw.com Financial Plaza Suite Fort Lauderdale FL Tonja Haddad Coleman Esquire Tonja tonjahaddad.com efiling tonjahaddad.com Law Offices of Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Attorneys for Jeffrey Epstein JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant I IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO SUBPOENA WITHOUT DEPOSITION TIIE STATE OF FLORIDA TO Alan Dershowitz Esquire YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida on October at a.m and to have with you at that time and place the following Duces Tecum All documents reflecting any and all communications between you or anyone acting on your behalf and Jeffrey Epstein or anyone acting on his behalf which communication related directly or indirectly to the basis for and/or the viability of any claim by Epstein against Bradley Edwards These items will be inspected and may be copied at that time You will not be required to surrender the original items You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose nan1e appears on this subpoena on or before the EXHIBIT A Edwards adv Epstein Case No Subpoena to Non-Party Page2 scheduled date of production You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena TIDS WILL NOT BE A DEPOSITION NO TESTIMONY WILL BE TAKEN The term documents includes but is not limited to all non-identical copies of letters notes memoranda e-mails faxes records transcripts and entries regardless of whether they were made manually mechanically electronically magnetically digitally or by any other means and regardless of whether they are on papers tape film electronic devices electronic media as well as application metadata and system metadata or any other media or thing If you fail to Appear as specified or Furnish the records instead of appearing as provided above or Object to this subpoena Edwards adv Epstein Case No Subpoena to Non-Party Page3 You may be in contempt of court You are subpoenaed to appear by the following attorney and unless excused from this subpoena by this attorney or the court you shall respond to this subpoena as directed DATED this_ __ day of September la ar No ary E-mail jsx searcylaw.com condary E-mail mep searcylaw.com Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Bradley Edwards Edwards adv Epstein Case No Subpoena to Non-Party Page4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The undersigned as custodian of records for certifies that the attached documents consisting of pages represents a true copy of all items within my possession custody or control which are described in the Subpoena Duces Tecum Without Deposition served on me in the above styled action and each page is numbered by me for identification Production is complete and has been numbered by the custodian of records It is further certified that originals of the items produced are maintained under the direction custody and control of the undersigned TI1e foregoing Ce1tification was acknowledged before me an officer duly authorized in the State and County aforesaid to take acknowledgments this day of __ is personally known to me or has produced as identification and who did or did not take an oath and who executed the foregoing certification and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited Notary Public State of Florida at Large My Commission Expires Edwards adv Epstein Case No Subpoena to Non-Party Page5 COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Bradley Edwards Esquire staff.efile pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman,FL North Andrews A venue Suite Fort Lauderdale FL Phone Fax Fred Haddad Esquire Dee FredHaddadLaw.com baddadfm aol.com Fred Haddad P.A One Financial Plaza Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com Law Offices of Marc Nurik One Broward Blvd Suite Fo1t Lauderdale FL Phone Fax Attorneys for Scott Rothstein Tonja Haddad Coleman Esquire tonja tonjahaddad.com Debbie Tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant IN THE CIRCUIT COURT OF THE FIFTEENTH IDDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO SUBPOENA WITHOUT DEPOSITION THE STATE OF FLORIDA TO Joseph Ackerman Jr Esquire YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida on October at a.m and to have with you at that time and place the following Duces Tecum All documents reflecting any and all communications between you or anyone acting on your behalf and Jeffrey Epstein or anyone acting on his behalf which communication related directly or indirectly to the basis for and/or the viability of any claim by Epstein against Bradley Edwards These items will be inspected and may be copied at that time You will not be required to surrender the original items You may comply with tins subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the Edwards adv Epstein Case No Subpoena to Non-Party Page2 scheduled date of production You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena TIDS WILL NOT BE A DEPOSITION NO TESTIMONY WILL BE TAKEN The term documents includes but is not limited to all non-identical copies of letters notes memoranda e-mails faxes records transcripts and entries regardless of whether they were made manually mechanically electronically magnetically digitally or by any other means and regardless of whether they are on papers tape film electronic devices electronic media as well as application metadata and system metadata or any other media or thing If you fail to Appear as specified or Furnish the records instead of appearing as provided above or Object to this subpoena Edwards adv Epstein Case No Subpoena to Non-Party Page3 You may be in contempt of court You are subpoenaed to appear by the following attorney and unless excused from this subpoena by this attorney or the court you shall respond to this subpoena as directed DATED this ri day of September E-mail jsx searcylaw.com ondary E-mail mep searcylaw.com earcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phon Fax Attorneys for Bradley Edwards Edwards adv Epstein Case No Subpoena to Non-Party Page4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The wldersigned as custodian of records for certifies that the attached documents consisting of pages represents a true copy of all items within my possession custody or control which are described in the Subpoena Duces Tecum Without Deposition served on me in the above styled action and each page is numbered by me for identification Production is complete and has been numbered by the custodian ofrecords It is further certified that originals of the items produced are maintained under the direction custody and control of the undersigned The foregoing Certification was acknowledge.d before me an officer duly authorized in the State and County aforesaid to take acknowledgments this day of is personally known to me or has produced as identification and who didor did not take an oath and who executed the foregoing certification and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited Notary Public State of Florida at Large My Commission Expires Edwards adv Epstein Case No Subpoena to Non-Party Page5 COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Bradley Edwards Esquire staff.efile pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman FL North Andrews Avenue Suite Fort Lauderdale FL Phone Fax Fred Haddad Esquire Dee FredHaddadLaw.com haddadfm aol.com Fred Haddad P.A One Financial Plaza Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com Law Offices of Marc Nurik One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein Tonja Haddad Coleman Esquire tonja tonjahaddad.com Debbie Tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attomeys for Jeffrey Epstein JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant I IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORlDA CASE NO SUBPOENA WITHOUT DEPOSITION 1HE STATE OF FLORIDA TO Jack A Goldberger Esquire YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida on October at a.m and to have with you at that time and place the following Duces Tecum All documents reflecting any and all communications between you or anyone acting on your behalf and Jeffrey Epstein or anyone acting on his behalf which communication related directly or indirectly to the basis for and/or the viability of any claim by Epstein against Bradley Edwards These items will be inspected and may be copied at that time You will not be required to surrender the original items You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the Edwards adv Epstein Case No Subpoena to Non-Party Page2 scheduled date of production You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena TIDS WILL NOT BE A DEPOSITION NO TESTIMONY WILL BE TAKEN The tern1 documents includes but is not limited to all non-identical copies of letters notes memoranda e-mails faxes records transcripts and entries regardless of whether they were made manually mechanically electronically magnetically digitally or by any other means and regardless of whether they are on papers tape film electronic devices electronic media as well as application metadata and system metadata or any other media or thing If you fail to Appear as specified or Furnish the records instead of appearing as provided above or Object to this subpoena Edwards adv Epstein Case No Subpoena to Non-Party Page3 You may be in contempt of court You are subpoenaed to appear by the following attorney and unless excused from this subpoena by this attorney or the court you shall respond to this subpoena as directed DATED this I clay of September Jack a Flo a ar No Pr E-mail jsx searcylaw.com ondary E-mail mep searcylaw.com earcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Bradley Edwards Edwards adv Epstein Case No Subpoena to Non-Party Page4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The undersigned as custodian of records for certifies that the attached documents consisting of pages represents a true copy of all items within my possession custody or control which are described in the Subpoena Duces Tecum Without Deposition served on me in the above styled action and each page is numbered by me for identification Production is complete and has been numbered by the custodian of records It is further certified that originals of the items produced are maintained under the direction custody and control of the undersigned The foregoing Certification was acknowledged before me an officer duly authorized in the State and County aforesaid to take acknowledgments this day of is personally known to me or has produced as identification and who did or did not take an oath and who executed the foregoing certification and who acknowledged the foregoing certification to be freely and volw1tarily executed for the purposes therein recited Notary Public State of Florida at Large My Commission Expires Edwards adv Epstein Case No Subpoena to Non-Party Page5 COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Bradley Edwards Esquire staff.efile pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman FL North Andrews Avenue Suite Fort Lauderdale FL Phone Fax Fred Haddad Esquire Dee FredHaddadLaw.com haddadfm aol.com Fred Haddad P.A One Financial Plaza Suite Fort Lauderdale FL Phone Fax Attorneys for ef:frey Epstein Marc Nurik Esquire marc nuriklaw.com Law Offices of Marc Nurik One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein Tonja Haddad Coleman Esquire tonja tonjahaddad.com Debbie Tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant __ IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCIBT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO SUBPOENA WITHOUT DEPOSITION THE STATE OF FLORIDA TO Darren Indyke Esquire I East th Street IOB New York NY YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida on October at a.m and to have with you at that time and place the following Duces Tecum All documents reflecting any and all communications between you or anyone acting on your behalf and Jeffrey Epstein or anyone acting on his behalf which communication related directly or indirectly to the basis for and/or the viability of any claim by Epstein against Bradley Edwards These items will be inspected and may be copied at that time You will not be required to surrender the original items You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the Edwards adv Epstein Case No Subpoena to Non-Party Page2 scheduled date of production You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena THIS WILL NOT BE A DEPOSITION NO TESTIMONY Wll,L BE TAKEN The term documents includes but is not limited to all non-identical copies of letters notes memoranda e-mails faxes records transcripts and entries regardless of whether they were made manually mechanically electronically magnetically digitally or by any other means and regardless of whether they are on papers tape film electronic devices electronic media as well as application metadata and system metadata or any other media or thing If you fail to Appear as specified or Furnish the records instead of appearing as provided above or Object to this subpoena Edwards adv Epstein Case No Subpoena to Non-Party Page3 You may be in contempt of court You are subpoenaed to appear by the following attorney and unless excused from this subpoena by this attorney or the court you shall respond to this subpoena as directed DATED this fTlr day of September rLtna-vt E-mail jsx searcylaw.com ndary E-mail mep searcylaw.com earcy Denney Scarola Barnhart Shipley P.A Palm Beach Lalces Boulevard West Palm Beach Florida Phone Fax Attorneys for Bradley Edwards Edwards adv Epstein Case No Subpoena to Non-Party Page4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The undersigned as custodian of records for __ certifies that the attached docilents consisting of pages represents a true copy of all items within my possession custody or control which are described in the Subpoena Duces Tecil Without Deposition served on me in the above styled action and each page is numbered by me for identification Production is complete and has been numbered by the custodian of records It is further certified that originals of the items produced are maintained under the direction custody and control of the undersigned The foregoing Certification was acknowledged before me an officer duly authorized in the State and County aforesaid to take acknowledgments this day of is personally known to me or has produced as identification and who did or did not take an oath and who executed the foregoing certification and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited Notary Public State of Florida at Large My Commission Expires Edwards adv Epstein Case No Subpoena to Non-Party Page5 COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Bradley Edwards Esquire staff.efile pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehnnan FL North Andrews A venue Suite Fort Lauderdale FL Phone Fax Fred Haddad Esquire Dee FredHaddadLaw.com haddadfm aol.com Fred Haddad P.A One Financial Plaza Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com Law Offices of Marc Nwik One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein Tonja Haddad Coleman Esquire tonja tonjahaddad.com Debbie Tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant I IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO SUBPOENA WITHOUT DEPOSITION THE STATE OF FLORIDA TO Robert Critton Esquire YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida on October at a.m and to have with you at that time and place the following Duces Tecum All documents reflecting any and all communications between you or anyone acting on your behalf and Jeffrey Epstein or anyone acting on his behalf which communication related directly or indirectly to the basis for and/or the viability of any claim by Epstein against Bradley Edwards These items will be inspected and may be copied at that time You will not be required to surrender the original items You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose nan1e appears on this subpoena on or before the Edwards adv Epstein Case No Subpoena to Non-Party Page2 scheduled date of production You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena TIDS WILL NOT BE A DEPOSITION NO TESTIMONY WILL BE TAKEN The term documents includes but is not limited to all non-identical copies of letters notes memoranda e-mails faxes records transcripts and entries regardless of whether they were made manually mechanically electronically magnetically digitally or by any other means and regardless of whether they are on papers tape film electronic devices electronic media as well as application metadata and system metadata or any other media or thing If you fail to Appear as specified or Furnish the records instead of appearing as provided above or Object to this subpoena Edwards adv Epstein Case No Subpoena to Non-Party Page3 You may be in contempt of court You are subpoenaed to appear by the following attorney and unless excused from this subpoena by this attorney or the court you shall respond to this subpoena as directed DATED this of September rAmlil E-mail jsx searcylaw.com condary E-mail mep searcylaw.com Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Bradley Edwards Edwards adv Epstein Case No Subpoena to Non-Party Page4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The undersigned as custodian of records for certifies that the attached documents consisting of pages represents a true copy of all items within my possession custody or control which are described in the Subpoena Duces Tecum Without Deposition served on me in the above styled action and each page is numbered by me for identification Production is complete and has been numbered by the custodian of records It is further certified that originals of the items produced are maintained under the direction custody and control of the undersigned The foregoing Certification was acknowledged before me an officer duly authorized in the State and County aforesaid to take acknowledgments this day of who is personally known to me or has produced as identification and who did or did not take an oath and who executed the foregoing certification and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited Notary Public State of Florida at Large My Commission Expires Edwards adv Epstein Case No Subpoena to Non-Party Pages COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Bradley Edwards Esquire staf 243efile pathtojustice.com Fanner Jaffe eissing Edwards Fistos Lehrman FL North Andrews A venue Suite Fort Lauderdale FL Phone Fax Fred Haddad Esquire Dee FredHaddadLaw.com haddadfm aol.com Fred Haddad P.A One Financial Plaza Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com Law Offices of Marc Nurik One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein Tonja Haddad Coleman Esquire tonja tonjahaddad.com Debbie Tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for ef:frey Epstein JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant IN THE CIRCUIT COURT OF THE FIFTEENTH nJDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO SUBPOENA WITHOUT DEPOSITION THE STATE OF FLORIDA TO Christopher Knight Esquire YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida on October at am and to have with you at that time and place the following Duces Tecum All documents reflecting any and all communications between you or anyone acting on your behalf and Jeffrey Epstein or anyone acting on his behalf which communication related directly or indirectly to the basis for and/or the viability of any claim by Epstein against Bradley Edwards These items will be inspected and may be copied at that time You will not be required to surrender the original items You may comply with this subpoena by providing legible copies of the items to be produced to the attomey whose name appears on this subpoena on or before the Edwards adv Epstein Case No Subpoena to Non-Party Page2 scheduled date of production You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena TIDS WILL NOT BE A DEPOSITION NO TESTIMONY WILL BE TAKEN The term documents includes but is not limited to all non-identical copies of letters notes memoranda e-mails faxes records transcripts and entries regardless of whether they were made manually mechanically electronically magnetically digitally or by any other means and regardless of whether they are on papers tape film electronic devices electronic media as well as application metadata and system metadata or any other media or thing If you fail to Appear as specified or Furnish the records instead of appearing as provided above or Object to this subpoena Edwards adv Epstein Case No Subpoena to Non-Party Page3 You may be in contempt of court You are subpoenaed to appear by the following attorney and unless excused from this subpoena by this attorney or the court you shall respond to this subpoena as directed DATED this day of September l"Am E-mail jsx searcylaw.com condary E-mail mep searcylaw.com Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Bradley Edwards Edwards adv Epstein Case No Subpoena to Non-Party Page4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The undersigned as custodian of records for certifies that the attached documents consisting of pages represents a true copy of all items within my possession custody or control which are described in the Subpoena Duces Tecum Without Deposition served on me in the above styled action and each page is numbered by me for identification Production is complete and has been numbered by the custodian of records It is further certified that originals of the items produced are maintained under the direction custody and control of the undersigned The foregoing Certification was acknowledged before me an officer duly authorized in the State and County aforesaid to take acknowledgments this day of is personally known to me or has produced as identification and who did or did not take an oath and who executed the foregoing ce11ification and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited Notary Public State of Florida at Large My Commission Expires Edwards adv Epstein Case No Subpoena to Non-Party Pages COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Bradley Edwards Esquire staff.efile pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Leluman FL North Andrews Avenue Suite Fort Lauderdale FL Phone Fax Fred Haddad Esquire Dee FredHaddadLaw.com haddadfm aol.com Fred Haddad P.A One Financial Plaza Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com Law Offices of Marc Nurik One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein Tonja Haddad Coleman Esquire tonj a tonjahaddad.com Debbie Tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO SUBPOENA WITHOUT DEPOSITION THE STATE OF FLORIDA TO Roy Black Esquire YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida on October at a.m and to have with you at that time and place the following Duces Tecum All documents reflecting any and all communications between you or anyone acting on your behalf and Jeffrey Epstein or anyone acting on his behalf which communication related directly or indirectly to the basis for and/or the viability of any claim by Epstein against Bradley Edwards These items will be inspected and may be copied at that time You will not be required to surrender the original items You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the Edwards adv Epstein Case No Subpoena to Non-Party Page2 scheduled date of production You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena TIDS WILL NOT BE A DEPOSITION NO TESTIMONY WILL BE TAKEN Toe term documents includes but is not limited to all non-identical copies of letters notes memoranda e-mails faxes records transcripts and entries regardless of whether they were made manually mechanically electronically magnetically digitally or by any other means and regardless of whether they are on papers tape film electronic devices electronic media as well as application metadata and system metadata or any other media or thing If you fail to Appear as specified or Furnish the records instead of appearing as provided above or Object to this subpoena Edwards adv Epstein Case No Subpoena to Non-Party Page3 You may be in contempt of court You are subpoenaed to appear by the following attorney and unless excused from this subpoena by this attorney or the court you shall respond to this subpoena as directed DATED this Ir day of September Jack Flo ar No ary E-mail jsx searcylaw.com econdary E-mail mep searcylaw.com Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Bradley Edwards Edwards adv Epstein Case No Subpoena to Non-Party Page4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The undersigned as custodian of records for certifies that the attached documents consisting of pages represents a true copy of all items within my possession custody or control which are described in the Subpoena Duces Tecum Without Deposition served on me in the above styled action and each page is numbered by me for identification Production is complete and has been numbered by the custodian of records It is further certified that originals of the items produced are maintained under the direction custody and control of the undersigned The foregoing Certification was acknowledged before me officer duly authorized in the State and County aforesaid to take acknowledgments this day of who is personally known to me or has produced as identification and who did or did not take an oath and who executed the foregoing certification and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited Notary Public State of Florida at Large My Commission Expires Edwards adv Epstein Case No Subpoena to Non Party Page5 COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Bradley Edwards Esquire staff.efile pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman FL North Andrews A venue Suite Fort Lauderdale FL Phone Fax Fred Haddad Esquire Dee FredHaddadLaw.com haddadfm aol.com Fred Haddad P.A One Financial Plaza Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com Law Offices of Marc Nurik One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein Tonja Haddad Coleman Esquire tonja tonjahaddad.com Debbie Tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein JEFFREY EPSTEIN Plaintiff/Counter-Defendant vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually Defendant/Counter-Plaintiff IN THE CIRCUIT COURT OF THE FIFfEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No CA PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS NOTICE OF OBJECTION PURSUANT TO RULE OF THE FLORIDA RULES OF CIVIL PROCEDURE Plaintiff/Counter-Defendant Jeffrey Epstein Epstein by and through his undersigned counsel and pursuant to Rule of the Florida Rules of Civil Procedure hereby files this Objection to Defendant/Counter-Plaintiff Bradley Edwardss Edwards Subpoena Without Deposition which Epstein assumes Edwards intends to serve upon the following non-party individuals on or about September Darren Indyke Esq Roy Black Esq Christopher Knight Esq Robert Critton Esq Joseph Ackerman Jr Esq Alan Dershowitz Esq and Jack Goldberger Esq Said objection is self-executing and there is no need for Epstein to specify his objections at this time See Russell Stardust Cruisers Inc So 2d Fla 5th DCA Russell Stardust Cruisers Inc So 2d Fla 5th DCA When any objection is Edwards failed to file a proper Notice of Production from Non-Party as required by Rule of the Florida Rules of Civil Procedure See also Form of the Florida Rules of Civil Procedure EXHIBITB filed Rule ceases to be available ABC Liquors Inc Berkey So 2d Fla 5th DCA see also Rule If the person upon whom the subpoena is served objects at any time before the production of the documents or things the documents or things shall not be produced under this rule and relief may be obtained pursuant to the rule governing depositions Morgan Colling Gilbert P.A Pope So 2d Fla 2d DCA WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via electronic service to all parties on the attached service list this September Tonja Haddad Coleman Tonja Haddad Coleman Esq Florida Bar No Tonja Haddad PA SE th Street Suite Fort Lauderdale Florida facsimile Attorneys for Epstein SERVICE LIST CASE NO Jack Scarola Esq jsx searcylaw.com mep searcylaw.com Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach FL Jack Goldberger Esq jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss PA Australian Ave South Suite West Palm Beach FL Marc Nurik Esq East Broward Blvd Suite Fort Lauderdale FL Bradley Edwards Esq brad pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman Andrews A venue Suite Fort Lauderdale Florida Fred Haddad Esq Dee FredHaddadLaw.com Financial Plaza Suite Fort Lauderdale FL Tonja Haddad Coleman Esquire Tonja tonjahaddad.com efiling tonjahaddad.com Law Offices of Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Attorneys for Jeffrey Epstein
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