Prosecution count had been on appeal since that tiine but this Court again had this matter set for trial in the fall Pursuant to that Order Setting Trial Epstein filed hisTrial Witness List and Exhibit List which was nearly identical to the one he filed in June on August After Epstein served his August Trial Witness List and Exhibit List Edwards served Interrogatories upon Epstein to which Epstein objected on two grounds first as exceeding the permitted number permitted by law without leave of court and second as impermissible as a matter of law On May Ed,vards filed a Motion to Expand Interrogatories and attached thereto two sets of Interrogatories alleging therein that the use of written interrogatories is the least burdensome least expensive and niost expeditious discovery means available to the Defendant by which to obtain necessary information arid narrow trial issues and that the Plaintiff will not be prejudiced through the granting of this motion See Edwards Motion and Exhibits attached hereto as Exhibit A As demonstrated in detail below permitting Edwards to expand his Interrogatories is impermissible and objectionable and Edwards motion should be denied MEMORANDUM OF LAW It is well settled that the scope and limitation of discovery falls within the broad discretion of the trial court Cordis Corp OShea So 2d Fla 4th DCA However interrogatories are not intended to be used for exploring all minute details ofa controversy Cabrera Evans So 2d Fia 3d DCA Most importantly it is axiomatic that"one party is not entitled to prepare his case By filing this Opposition Epstein does not waive any right to assert any legal objections to the substance of the Interrogatories or request an ord.er of protection as to any oft.he discovery requested should the Court pennit same Tonja Haddad P.A SE th Street Fort Lauderdale i I I I through the investigative work product of his adversary when the same or similar information is available through ordinary investigative techniques and discovery procedures Dodson Persell So.2d Fla See also Bishop by through Adult Comprehensive Protective Services Inc Pol/es So 2d Fla 2d DCA interrogatory asking plaintiffs to identify each document or item they might offer as evidence at trial was overbroad and improperly sought information protected by work-product privilege The case at bench has been pending since and the parties have engaged iri exhaustive discovery throughout that time Nevertheless Edwards now seeks permission from the court to require Epstein to do his job for h.im Specifically Edwards is asking this Court to permit him to serve Epstein with the following Interrogatories 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 A detailed description of the testimony expected to be presented at trial by the witness as to each contested factual issue A description of the TrialExhibit List number of each exhibhexpected to be introduced into evidence by thewitness A description of the Trial Exhibh 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 See Exhibit A First Additional Set oflnt rrogatories atfached to Edwardss Motion As this Court is aware Edwards list of trial witnesses improperly identifies Tonja Haddad P:A I 5_ SE th Street Fort Lauderdale FL I I I I intended witnesses by categories rather.than providing specific witnesses identified by their proper names The vague and deliberately uninformative categories Edwards uses in his witness list include anyone named in any deposition or discovery responses all victims identified in the local state and federal investigations all attorneys who have prosecuted claims against Jeffrey Epstein on behalf of other victims all other named victims all persons referenced in.Edwards Motion for Summary Judgment Epstein on the other hand filed a witness Hst separately and specifically identifying seventy-four individual witnesses by name Although Edwards does not specify any subparts to his interrogatories and on the face of them he only appears to make four requests Edwards is in fact making these four,separate detailed requests about each of Epsteins seventy-four named witnesses Edwards has known the identity these witnesses sirice at least when Epstein filed his first witness list and accordingly this request is impermissible See Slatnick Leadership HousingSystenis of Florida Inc So Fla 4thDCA stating in responseto one interrogatory that this question alone relative to condominium buildings might take a week to am;wer It is difficult to imagine how the author of these particular interrogatories ould have possibly conjured up a more oppressive and burdensome collection Greyhound Lines Inc Jackson So 2d Fla.-4th DCA Next Edwardss Interrogatories undeniably seek Epsteins protected work product In Swf Drugs Inc Vermette So 2d Fla the Florida Supreme Edwards list of trial witnesses fails to comporfwith the applicable Rules as well as the Courts Order in that it fails to identify names or addresses of any of the alleged witnesses in the vague witness categories provided by Edwards and despite specific requests by Epstein for Edwards to do so Edwards has failed to rectify this issue since This violation is the subject of a separate Motion that is still pending before this Court Tonja Haddad P.A SE th Street Fort Lauderdale FL Court provided this general definition of what constitutes work product personal views of the attorney as to how and when to present evidence his evaluation of its relative importance his knowledge of which witness will give certain testimony come within the general category ofwork product Id at emphasis added See also FLA R.Ctv Southern Bell Tel Tel Co Deason So 2d Fla In his Interrogatories Edwards requests that Epstein provide for each of Epsteins separately named witnesses a detailed description of the testimony expected to be presented at trial by the witness as to each contested factual issue a description of the Trial Exhibit List number of each exhibit expected to be introduced into evidence by the witness 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 See Exhibit A These Interrogatories are unquestionably demanding protected work product as defined by the Florida Supreme Court Vermette So 2d at The rationale supporting the work product doctrine is that one party is not entitled to prepare his case through the investigative work product of his adversary where the same or similar information is available through ordinary investigative techniques and discovery procedures lvfillardAlall Servs Inc Bolda So Fla 4th DCA citing S.BeHTel Tel Co Deason So 2d Fla emphasis added Finally the second set of Interrogatories attached to Edwardss Motion impermissibly seek Net Worth Discovery from Epstein discovery about which the parties have already extensively litigated and to which Epstein already provided Tonja Haddad P.A SE th Street Fort Lauderdale FL I I responses on Jtily A true and correct copy of the Interrogatories as well as the certificate ofservice for ihe answers to same is attached hereto as composite Exhibit Consequently and for an of the reasons set forth above Edwards Motion is improper and shotild be denied WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below via Electronic Service this June Isl Tonja Haddad Coleman Tonja Haddad Coleman Esq 267Fla.Bar No LAW OFFICES OF TONJA HADDAD PA SE Street Suite Fort Lauderdale Florida facsimile Efiling tonjahaddad.coin Tonja tonjahaddad.com Epstein does not waive any right to assert any substantive legal objections or request an order of protection as to any of the discovery requested should the Court permit same Tonja Haddad P.A SE th Street Fort Lauderdale FL I i I SERVICE LIST CASE NO Jack Scarola Esq jsx searcylaw.com mep searcylaw.com Searcy Denney.Scarola et al Palm BeachLakesBIVd West Palm Beach FL Jack Goldberger Esq jgoldberger agwpa.com sinahoney 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 FarmerJaffe Weissing Edwards Fistos Lehrman Andrews Avenue Si.lite Fort Lauderdale Florida Fred Haddadi Esq _Dee FredHaddadLaw.com SE th Street Suite I Fort Lauderdale FL I Tonja Haddad Coleman Esqilire Tonja tonjahaddad.com;efiling tonjahaddad.com LawOffices ofTonja Haddad P.A SE 7th Street Suite I Fort Lauderdale FL Attorneys for Jeffrey Epstein Chester Brewer Jr One Clearlake Center Suite Australian Avenue South West Paln1 Beach Florida I wcblaw aol.com wcbcg aol.com Tonja Haddad P.A SE th Street Fort Lauderdale FL 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 description of the witness expected testimony regarding each exhibit ANSWER EXHIBITA I I I I I i I i Edwards adv Epstein Case No Bradley Edwards Fact Witness Interogs to Epstein 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 I i 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 A.s to each federal income tax return filed by you or on your behalf for the years ll 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 of real property in which you hold any interest state a The address Case No Notice ofServing 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 ofpurchase Whether when and at what price the property has been offered for sale since the time of purchase I I I i I I i I I I i i 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 267ofthat document Ifyou have ari ownership interest in any businesses for each business state a the name and address of the business i I I I 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 I I I 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 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 riot previously identified and as to each state I i I Case No Notice of Serving Net Worth Interrogatories a The date the 267liability 267arose The amountofthe liability at inception The t,erms of repayment or satisfactfon 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 __ COUNTYOF _J 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 JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEYJ EDWARDS Individually and L.M individually Defendants I IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE JEFFREY EPSTEINS NOTICE OF SERVING UNVERIFIED AMENDED ANSWERS TO DEFENDANT BRADLEY EDW ARDSS INTERROGATORIES Plaintiff Jeffrey Epstein by and through his undersigned counsel and pursuant to Rule of the Florida Rules of Civil Procedure hereby certifies that the original amended answers to Defe dants Interrogatories was served upon Defendant via electronic service thisJuly Isl Tonja Haddad Coleman Tonja Haddad Coleman Esq Ffa.BarNo LAW OFFICES OF TONJA HADDAD PA SE 7m Street Suite Fort LaiJderdaie Florida facsimile Tonja tonjahaddad.com 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 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