Edwards adv Epstein Case No Edwards Motion to Expand Interrogatories Page of3 The use of written interrogatories is the least burdensome least expensive and most expeditious discovery means available to the Defendant by which to obtain necessary information and narrow trial issues The Plaintiff will not be prejudiced through the granting of this motion The foregoing factors and others to be presented upon hearing of this Motion constitute good cause for increasing the number of interrogatories permitted herein I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by u.s Mail to all counsel on the attached list day of May Jack SC fa1a Flqrid ar No Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Defendant Edwards adv Epstein Case No Edwards Motion to Expand Interrogatories Page of3 COUNSEL LIST William Chester Brewer Esquire wcblaw aol.com wcblawasst gmail.com Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Bradley Edwards Esquire staff.efile pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman P.L Andrews A venue Suite Fort Lauderdale FL Phone Fax Fred Haddad Esquire Dee FredHaddadLaw.com Fred FredHaddadLaw.com Fred Haddad P.A One Financial Plaza Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Tonja Haddad Coleman Esquire tonja tonjahaddad.com efiling tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein FACT WITNESS INTERROGATORIES TO JEFFREY EPSTEIN As to every individual identified on Jeffrey Epsteins List of Trial Witnesses state the following Each contested factual issue expected to be addressed by the witness ANSWER A detailed description of the testimony expected to be presented at trial by the witness as to each contested factual issue ANSWER A description of the Trial Exhibit List number of each exhibit expected to be introduced into evidence by the witness ANSWER A description of the Trial Exhibit List number of each exhibit introduced through other means which the witness is expected to testify about together with a description of the witness expected testimony regarding each exhibit ANSWER Edwards adv Epstein Case No Bradley Edwards Fact Witness Interogs to Epstein Page of5 STATE OF COUNTY OF The foregoing instrument was acknowledged before me this day of by who is personally known to me or who has produced as identification and who did/did not take an oath SEAL Notary signature Notary name print NOTARY PUBLIC State of Florida Serial number if any Case No Notice of Serving Net Worth Interrogatories The serial number of each bond share stock certificate or other evidence of ownership or security The current fair market value of each such interest The manner in which such value was calculated As to each federal income tax return filed by you or on your behalf for the years through and including identify as specifically as identified in your tax return the source of all reported income and the separate amounts derived from each source For each parcel ofreal property in which you hold any interest state a The address Case No Notice of Serving Net Worth Interrogatories The legal description of the property The assessed value of the property for tax purposes The date and price of acquisition Whether when and at what amount the property has been appraised since the time of purchase Whether when and at what price the property has been offered for sale since the time of purchase Case No Notice of Serving Net Worth Interrogatories The name and address of each real estate agent with whom the property has been listed for sale since the time of purchase The cost of any improvements made to the property since purchase i The nature of your interest in the property List each item and state the estimated value of all personal property in which you have an interest which personal property was acquired at a cost in excess of or which personal property has an estimated present value in excess of and as to each state a The date of acquisition The cost of acquisition Case No Notice of Serving Net Worth Interrogatories The current estimated fair market value The manner in which the fair market value was estimated If any of the real or personal property owned by you either individually jointly or otherwise is encumbered by either a real estate mortgage chattel mortgage or any other type of lien then for each item of property state a description of the nature and amount of the encumbrance the date the encumbrance arose whether the encumbrance is evidenced by any written document and if so a description of that document If you have an ownership interest in any businesses for each business state a The name and address of the business Case No Notice of Serving Net Worth Interrogatories The present book value and the present market value of your interest in the business and its percentage of the total value of the business A description of the manner in which the stated fair market value was calculated Identify all banks credit union and savings and loan accounts in which you have an interest or right of withdrawal and for each account state a Where the account is located The highest and lowest balance in the account during the day period immediately preceding your receipt of these interrogatories Case No Notice of Serving Net Worth Interrogatories Identify all other assets of a value in excess of which assets were not previously identified and as to each state a The date of acquisition The cost of acquisition The current estimated fair market value The means utilized to estimate the current fair market value Identify all other liabilities not previously identified and as to each state Case No Notice of Serving Net Worth Interrogatories a The date the liability arose The amount of the liability at inception The terms of repayment or satisfaction The current outstanding balance State your year end net worth for each of the past years and your best estimate of your present net worth Case No Notice of Serving Net Worth Interrogatories STATE OF COUNTY OF The foregoing instrument was acknowledged before me this day of by who is personally known to me or who has produced as identification and who did did not take an oath SEAL Notary signature Notary name print NOTARY PUBLIC State of Florida Serial number if any m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 qrM?r?qr?r9 q?10Cy rCX qr l1 X?l 3K fm?Q Z2f CX CX gT L??T 2E Cy 3P EM3 J4T L?h??M q?ᡚ?Y r??O?rJt CTX X0T1i k3v Jh/e0h1 H(K W/Q0 CTX j?!k 5B r2 CTX A A A 4v z"p A A A0A?A AK CTX A A?!k CX qCX YCX i!d A fi8 l8 yuZ 6L pH m?c sP;0 6ZR Ni P0 0Q X(P0s s(s p0 Pp CTX qq dR B/J Va A GH FT I CTX U3 U3 U3 U3 S6 E"L I I I5K7C:I 9O U3 Cn qrr qr q??r?q 9qr CTX G5 qr CX rC l0 WS zN pf1 ODV8L?m jC1DxV CTX CTX A qr 10Cy rYY Ң??P?V CTX C"C rqM?rq?q?qr qr CTX YY Jb?C.y CTX CTX GG4 A A G5 C.C M??r 10Cy rq YY C?J?yO c/XE?lgF GM??H p?ݡG Dp9Oh CTX CTX CJ4 I J6 CJ4 CK qrrM?q qq 9/CX?o CX qYqr rC dd?Z c6S ttcx A CTX CTX 10Cy rq rqYY X?qiX:4 3J Db ZH uD-8 1g?BH I vS 7Oo7u E?K?O J6 UJP U0 UT??ʴ UT UT UT O(p U(u UF1 iZ qr?r CX CX Yr zKW:E A K5M P-M UW VW L1J KJ56 N/Q SQ rC 6J ߵl ߵl 5TZ w8ĥDG oj?K _4 N)?Y Hp pRqc?W26 vz?WBrz?ZB??3X H4 CTX A CTX X4 U5 P8 5D qr qr 10Cy qr YY Mo?ANp D01jJ 9F bzEV 4O 8V CTX O!o CTX KK AA qr A C5 qr rYY 1A?CC V9 a c?F CTX A G5 qr EeD?M CTX 9?rY 10Cy rq qY ȠX1 a f??B CTX 9F I CTX 6D N?qr rrqq qC O?J RmA??b"0 M?.F q?D B?G CTX CTX F4 d6P A F4 qr rYY 4G AV8 CTX UY UL0 U0 U0 U0 UF UF UFAGA UA UA UAL UL UL UL UL UL UL U7 U7 U7 U7 U7 U7 U7 2EH GTU U/U OUoU UV G1 CTX TUV 1G 7A UA UAL X7 U7 U7 U77XL UL UL ULLYX KTX 8Y GJ A UMAT UD 7M GVW GF10 MWA LL MPM M?M 4M XY qr qr qr NEeD 10Cy qYY E2 GH l1 Pd h3V g?KIq V5kL O65S d_xKKU vV 5H p1 Z6 CTX U0 U1 CTX U0 U1 A0 1D qr qr 10Cy YY K??Kl 1B AMwv 1K F1 KV yW Gd T?H CTX CTX I CK M?qr K?SK?PQZ I IRZX 8YCX 10Cy qr CX kv zg S5kB??a iG wA CTX U2 6Y CTX U2 6Y I K,,j j,s 6Y P!p qr 10Cy qr YY G?O 9K mSd X0 9r?yal 1d bY0 XNf??qN D?J CTX P!Z b!o C,C qrM 10Cy qr8 I fX2 9R lO KV CTX Oo CTX A qr r?qr rq YY Lsy7H4 C,6E IL CTX U3 CTX J,O3_3xx qrM?r q?CX Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8
