Case No Edwards Opposition to Epsteins Motion for Summary Judgment Page of socialized press reports of Rothsteins known illegal activities the use of ridiculously inflammatory language and arguments in court But as the evidence submitted in opposition to Epsteins original Motion for Summary Judgment reflects Epstein filed his claims and continued to pursue claims despite his knowledge that his claims could never be successful because they were both false and unsupported by any reasonable belief that they were true All of that previously submitted evidence is incorporated by reference in this response Epstein knew that he had in fact molested each of the minors represented by Brad Edwards He also knew that each litigation decision by Brad Edwards was grounded in proper litigation judgment about the need to pursue effective discovery against Epstein particularly in the face of Epsteins stonewalling tactics Epstein also knew that he suffered no legally cognizable injury proximately caused by the falsely alleged wrongdoing on the part of Edwards Moreover Epstein had no intention of waiving his Fifth Amendment privilege against self-incrimination in order to avoid providing relevant and material discovery that Epstein would be obliged to provide in the course of prosecuting his claims and to which Edwards was entitled in defending those claims Epstein knew that his prosecution of his claims would be baiTed by the sword-shield doctrine Most significantly the evidence submitted in the supporting papers would compel a fact finder to determine that Epstein had no basis in law or in fact to pursue his claims against Edwards and that Epstein was motivated by a single ulterior motive to attempt to intimidate Edwards and his clients and others into abandoning or settling their legitimate claims for less than their just and reasonable value The evidence demonstrates that Epstein did not file these claims for the purpose of collecting money damages since he knew that he never suffered any damage as a consequence of any alleged wrongdoing by Edwards Rather he filed the claim to require Edwards to expend time energy and resources on Case No Edwards Opposition to Epsteins Motion for Summary Judgment Page of his own defense to embarrass Edwards and impugn his integrity and deter others with legitimate claims against Epstein from pursuing those claims Indeed the evidence demonstrates that Epstein continued to pursue his claims by filing the Second Amended Complaint alleging abuse of process against Edwards even after he had paid significant sums in settlement of the claims instituted by Mr Edwards clients against Mr Epstein The record reflects that on the eve of the hearing of Edwards Motion for Summary Judgment directed to the Second Amended Complaint and in light of the compelling evidence of the lack of any wrongdoing on the part of Mr Edwards the sole remaining abuse of process claim was dismissed by Epstein As discussed in_fi"a each of the grounds asserted by Epstein in this Motion for Summary Judgment must be rejected on the basis of the evidence submitted by Edwards which supports each of the elements of the claims asserted by Edwards against Epstein which are identified in Epsteins Motion Response to Epsteins Statement of Undisputed Facts The evidence marshalled by Edwards in support of his claims against Epstein which are referenced in footnote mandates the conclusion that at a minimum disputed facts exist with Attached Answers to Epsteins Inte1TOgatories to which Edwards was obliged to respond under oath reflect that Epstein paid a total of million dollars to settle the claims of3 victims represented by Edwards The evidence marshalled in support of these assertions is set forth in the previously filed documents in this Court Those documents include Exhibit A Edwards Statement of Undisputed Facts Exhibit Edwards Renewed Motion for Summary Judgment Exhibit Edwards October Second Renewed Motion for Leave to Asse1t Claim for Punitive Damages Exhibit Edwards Notice of Filing of Transcript of Telephone Interview of Virginia Roberts in Support of Motion for Leave to Amend to Assert Punitive Damages Exhibit Transcript of Deposition of Jeffrey Epstein dated January Exhibit Deposition of Bradley Edwards dated March Exhibit Deposition of Scott Rothstein dated June I I Exhibit Order of Judge Crow dated March Exhibit I Deposition of Bradley Edwards dated October Exhibit Deposition of Bradley Edwards dated May Case No Edwards Opposition to Epsteins Motion for Summary Judgment Page of respect to the elements of each claim addressed by Epstein in his Motion The facts presented in the various papers would allow the jury to make a determination that Epstein knew that Brad Edwards properly exercised his legitimate judgment regarding the need to pursue proper and effective discovery against him to support the claims which Epstein knew were legitimate and which by way of three huge settlements he admitted were legitimate That evidence referenced herein further demonstrated that Epstein filed his claims without probable cause and further that there was a bonafide termination in favor of Edwards The following additional comments are directed at some of the key purported undisputed material facts asserted by Epstein especially those referenced in his Memorandum of Law Also set forth are key evidentiary matters which undermine Epsteins contentions and which support the proposition that material issues of fact exist which compel the denial of the Motion for Summary Judgment None of the public materials identified by Epstein in his Motion make reference to any wrongdoing by Brad Edwards Rather Epstein seeks to pyramid one impermissible inference upon another from his citation to these materials to support his otherwise unsubstantiated and non verifiable conclusion that he had sufficient evidence to proceed with claims of wrongdoing against Edwards In truth as reflected in Edwards deposition and his supplemental affidavit he has no involvement in any fraud perpetrated by Rothstein Edwards deposition of March at Edwards Affidavit attached to Statement of Undisputed Facts as Exhibit at paragraphs paragraph paragraphs Exhibit Deposition of Scott Rothstein at pp and Therefore any allegations relating to Rothsteins activities simply have no bearing on the legitimacy of any of the claims against Edwards Edwards could not have Case No Edwards Opposition to Epsteins Motion for Summary Judgment Page of possibly pumped cases to investors when he never participated in or even had knowledge of any communications with investors Rather Edwards had a duty to his clients to zealously pursue discovery to achieve a maximum recovery against Epstein Edwards cannot be liable for taking appropriate action that his ethical duties as an attorney required The evidence also reflects that Edwards filed all three of his cases almost a year before he was hired by RRA or even knew Scott Rothstein Edwards Affidavit Exhibit attached to Statement of Undisputed Facts The language set forth in his Complaints remains virtually unchanged from the first filing in and as the evidence shows the claims asserted against Epstein from the outset were true The citation to public documents is a convenient ruse Epstein was not only liable for the molestation of the clients of Brad Edwards he was also a serial molester of dozens of other minors even as young as twelve years of age Exhibit A Edwards Statement of Undisputed Material Facts paragraphs Exhibit Statement of Virginia Roberts pp Epstein entered a plea of guilty to felony charges involving prostitution and the solicitation of a minor for the purposes of prostitution Exhibit Deposition of Jeffrey Epstein March pp Epstein also entered into an agreement with the United States Attorneys Office acknowledging that approximately other young girls could receive payments from him under the Federal Statute providing for compensation to victims of child abuse Exhibit A Edwards Statement of Undisputed Material Facts paragraphs On July Epstein ultimately paid to settle all three of the cases Edwards had filed against him Exhibit A Edwards Statement of Undisputed Material Facts paragraphs At Epsteins request the terms of the settlement were kept confidential until Epstein requested their disclosure in Interrogatories Epstein chose to make these multi-million dollar payments as Case No Edwards Opposition to Epsteins Motion for Summary Judgment Page of a result of a Federal Comi ordered mediation process which he himself sought Epstein entered into the settlements in July more than seven months after he filed his lawsuit against Edwards and before he filed his Second Amended Complaint alleging abuse of process on August The payments were obviously made with full knowledge of all of the wrongdoing on the part of Rothstein alleged in Epsteins pleadings Further Epstein could not have been the victim of any scheme to pump the cases against him because he never paid to settle the cases until well after Edwards had left RRA and severed all connection with Rothstein in December Edwards Affidavit attached to Statement of Undisputed Facts as Exhibit paragraph Moreover Epstein could not have suffered any damage as a result of the perpetration of the Ponzi scheme by Rothstein because he was not an investor in the scheme Perhaps the most significant evidence presented in opposition to Epsteins Motion for Summary Judgment is the telephone interview of Virginia Roberts submitted in Support of Edwards Motion for Punitive Damages Exhibit In addition to the specious claims against Edwards relating to his alleged involvement in a Ponzi scheme Epstein in asserting his claims primarily relied upon the pursuit by Edwards of testimony from his close friends and associates See Second Amended Complaint paragraph pp Reliance on these asse1iions is also threaded through Epsteins Motion for Summary Judgment in his citation to the public documents referencing the pursuit of such discovery But as set forth in detail in Edwards Motion for Final Summary Judgment Exhibit at pages that discovery was entirely appropriate and Epstein knew it Specifically as reflected in the statement of undisputed facts submitted by Mr Edwards in supp01i of his Motion for Summary Judgment Edwards had a sound legal basis for Case No Edwards Opposition to Epsteins Motion for Summary Judgment Page of believing that Donald Trump Allen Dershowitz Bill Clinton Tommy Matto la David Copperfield and Governor Bill Richardson had relevant and discoverable information Exhibit A Edwards Statement of Undisputed Facts paragraphs That belief was reinforced by the testimony of Virginia Roberts Exhibit pp Epsteins assertion of impropriety in the pursuit of this discovery clearly evidences his bad faith attempts to attribute wrongdoing to Edwards when he knew in fact that the pursuit of that discovery was entirely appropriate under the circumstances of this case Finally any attempt by Epstein to rely upon what he claims are undisputed facts to supp01i his Motion for Summary Judgment are undermined by his refusal to provide any testimony on the key issues and evidence which would demonstrate the validity and strength of each of the claims brought against him by Brad Edwards Epsteins depositions of March and January were replete with refusals of Epstein to testify based upon his Fifth Amendment privilege Questions that Epstein refused to answer in his depositions and the reasonable inferences that a fact finder would draw and which would otherwise bear on the arguments submitted by Epstein in support of his Motion for Summary Judgment are as follows Question not answered I want to know whether you have any knowledge of evidence that Bradley Edwards personally ever participated in devising a plan through which were sold purported confidential assignments of a structured payout settlement Reasonable inference No knowledge that Brad Edwards ever participated in the Ponzi scheme Question not answered Specifically what are the allegations against you which you contend Mr Edwards ginned up Reasonable inference No allegations against Epstein were ginned up See further details regarding Epsteins privilege assertions and the consequences of those assertions in Edwards Motion to Strike Epsteins Affidavit in Support of Motion for Summary Judgment Case No Edwards Opposition to Epsteins Motion for Summary Judgment Page of Question not answered Well which of Mr Edwards cases do you contend were fabricated Reasonable inference No cases filed by Edwards against Epstein were fabricated Question not answered Did sexual assaults ever take place on a private airplane on which you were a passenger Reasonable inference Epstein was on a private airplane while sexual assaults were taking place Question not answered How many minors have you procured for prostitution Reasonable inference Epstein has procured multiple minors for prostitution Question not answered Is there anything in L.M Complaint that was filed against you in September which you contend to be false Reasonable inference Nothing in L.M.s complaint filed in September was false i.e as alleged in L.M complaint Epstein repeatedly sexually assaulted her while she was a minor and she was entitled to substantial compensatory and punitive damages as a result Question not answered I would like to know whether you ever had any physical contact with the person referred to as Jane Doe in that federal complaint Reasonable inference Epstein had physical contact with minor Jane Doe as alleged in her federal complaint Question not answered Did you ever have any physical contact with E.W Reasonable inference Epstein had physical contact with minor E.W as alleged in her complaint Question not answered What is the actual value that you contend the claim of E.W against you has Reasonable inference E.W.s claim against Epstein had substantial actual value See Exhibit A Edwards Statement of Undisputed Material Facts paragraphs for page references A jury could conclude therefore from the adverse inferences drawn against Epstein that he was liable for the claims brought by Brad Edwards and that he had no basis for suing Edwards except as an effort to intimidate and extort Edwards and his clients to relinquish or cheaply compromise their claims Case No Edwards Opposition to Epsteins Motion for Summary Judgment Page of There are Disputed Issues of Fact Precluding Summarv Judgment on the Claim of Malicious Prosecution Here Epsteins voluntary dismissal of his abuse of process claims against Edwards amounted to a bona fide ten11ination of the proceedings He knew his allegations were unsupp011ed by evidence See discussion above at pages Knowing he lacked any verifiable evidence against Edwards on the eve of the summary judgment hearing Epstein effectively conceded that fact by voluntarily dismissing his claims Hence it is evident that Epstein took voluntary dismissal of his claims because he knew he did not have probable cause or an evidentiary basis to support the allegations See Cohen Corwin So 2d at citing Union Oil of California Amsco Division Watson So 2d at stating that where a dismissal is taken because ofinsufficiency of the evidence the requirement of a favorable termination is met Accordingly the manner of termination reflects on the merits of the case and there was a bona fide termination of Epsteins civil proceeding against Edwards See Judge Crows Order of March denying Motion to Dismiss re Issue of Bonafide Ten11ination attached as Exhibit Epsteins only other issue with Edwards counterclaim for malicious prosecution is that he did not lack probable cause in pursing his claims against Edwards As established by the record Epstein did in fact lack probable cause to assert his claims against Edwards See discussion above Epsteins purported reliance on public filings including the Scherer Complaint against Rothstein is unavailing As discussed above the evidence warrants the finding that Epstein knew that Edwards was legitimately pursuing the claims on behalf of his clients which included the effort to secure testimony from Epsteins close confidants Therefore Epstein cannot rely upon the Case No Edwards Opposition to Epsteins Motion for Summary Judgment Page of referenced public documents to suppo1i his claims against Edwards given that he knows that information to be untrue and he refuses to answer questions about the veracity of the information See Exh at pgs Consequently Epstein had no good faith basis to rely on such information Epsteins Complaint Lacked A Good Faith Basis Because It Was Barred By The Absolute Immunity Afforded To Edwards By The Litigation Privilege Absolute immunity must be afforded any act occurring during course of judicial proceeding regardless of whether the act involves defamatory statements or other t01iious behavior such as tortious interference with business relationship so long as act has some relationship to the proceeding See Levin Middlebrooks Mabie Thomas Mayes Mitchell P.A US Fire Ins Co So 2d Fla The well-established protection of the litigation privilege independently doomed Epsteins claims against Edwards because Epstein knew the claims brought by his victims were well founded and all conduct occurring in the prosecution of those legitimate claims could not legally form the basis of a separate cause of action against the lawyer prosecuting those legitimate claims The evidence and law described herein provide not only a reasonable basis but a compelling and unrebutted foundation supporting the conclusion that Epstein never had legitimate grounds to sue Bradley Edwards Every one of his now dismissed claims was factually baseless and legally barred Case No Edwards Opposition to Epsteins Motion for Summary Judgment Page of Epsteins Assertion of his Fifth Amendment Privilege Gives Rise to Adverse Inferences Pertinent to His Motion for Summary Judgment and Precludes His Reliance on Purported Undisputed Facts As discussed above Epsteins multiple invocations of his Fifth Amendment Privilege results in adverse inferences which directly impact the issues advanced in his Motion for Summary Judgment It is well settled that the Fifth Amendment does not forbid adverse inferences against parties to civil actions when they refuse to testify in response to probative evidence offered against them Baxter Palmigiano U.S Accord Vasquez State So 2d Fla at The reason for this rule is both logical and utilitarian A party may not trample upon the rights of others and then escape the consequences by invoking a constitutional privilege at least not in a civil setting Fraser Security and INV Corp So 2d Fla th DCA The adverse inferences drawn from Epsteins assertion of the Fifth Amendment undercut his claim of justifiable reliance based upon the purported undisputed material facts to support his Motion for Summary Judgment Moreover because Epstein elected to hide behind the shield of his right against self incrimination to preclude his disclosing any relevant information about the criminal activity at the center of his claims he was effectively barred from prosecuting his claim against Edwards Similarly Epstein should be barred from utilizing the Fifth Amendment privilege to secure summary judgment based upon assertions of fundamental facts when Epstein refused to testify on essential issues pertinent to the arguments advanced in support of his Motion for Summary Judgment Under the well-established sword and shield doctrine Epstein could not seek damages from Edwards while at the same time asserting a Fifth Amendment privilege to block relevant discovery See Exhs Bat Cat at The Case No Edwards Opposition to Epsteins Motion for Summary Judgment Page of COUNSEL LIST William Chester Brewer Esquire wcblaw aol.com wcbcg aol.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 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 fredhaddadlaw.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 efiling tonj ahaddad com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein JEFFREY EPSTEIN Plaintiff vs IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant I NOTICE OF SERVING UNVERIFIED ANSWERS TO INTERROGATORIES Bradley Edwards by and through his undersigned counsel hereby files this Notice of Serving Unverified Answers to Inten-ogatories with the Court propounded by Jeffrey Epstein on September and said Answers to Interrogatories have been furnished to the attorneys for Jeffrey Epstein I HEREBY CERTIFY that a true and c01Tect copy of the foregoing was sent via E-Serve to all Counsel on the attached list this to ey E-Mail jsx searcylaw.com and ccann searcylaw.com rimary E-Mail _scarolateam 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 Notice of Serving Answers to Interrogatories William Chester Brewer Esquire wcblaw aol.com wcblawasst gmail.com Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian Avenue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Bradley Edwards Esquire staff.efile pathtojustice.com Frumer Jaffe Weissing Edwards Fistos Lehrman P.L Andrews Avenue 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 267for Jeffrey Epstein Tonja Haddad Coleman Esquire tonja tonjahaddad.com efiling tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire rnarc nuriklaw.com One Broward Blvd Suite F01i Lauderdale FL Phone Fax Attorneys for Scott Rothstein Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories DAMAGES INTERROGATORIES TO BRADLEY EDWARDS State the full name address telephone number and description of business for each of your employers including as an independent contractor if applicable at any time during the period in question and for each employer provide the dates of employment nature of work title position salary and description of your duties for such employer as well as any changes in title position or duties during your employment during the period in question any termination thereof and the reasons for such change RESPONSE Objection The info1mation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The inte1rngatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Inten-ogatories Reference to the period in question is vague and ambiguous Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Couit State the full name address telephone number type of entity including without limitation corporation partnership limited partnership limited liability corporation sole proprietorship or other entity and description of the business conducted of each business enterprise with which you have been affiliated as a principal including as an owner officer director partner manager member shareholder or in any similar capacity at any time during the period in question as well as the dates of such affiliation the nature of such affiliation any changes during the period in question in the nature of such affiliation and the reasons for such changes as well as any income profits distributions salary commission or bonus paid in connection with such affiliation RESPONSE Objection The info1mation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Reference to the period in question is vague and ambiguous Counter-Plaintiff fuither objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number pennitted without leave of Couit Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories State the full name address and telephone number of all corporations limited liability companies partnerships limited partnerships limited liability corporations sole proprietorships other entities or business enterprises for which you have served at any time during the period in question as a member of the Board of Directors a member of the Board of Trustees a committee member an advisory board member a member of senior management or in some similar capacity state the dates of service describe the capacity in which you served state the full name address email address and telephone number of each person to whom you reported in such capacity and if any payment compensation fee honorarium other remuneration or other consideration was received for such service state the nature whether cash or other consideration frequency dates and amounts thereof and state the dates such service te1minated if applicable and any reasons therefor RESPONSE Objection The information sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The inteITogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants InteITogatories Reference to the period in question is vague and ambiguous Counter-Plaintiff further objects on the grounds that the number of inte1rngatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number pe1mitted without leave of Court Identify each person or entity for whom you performed services for a fee amounting to or more or on a contingency basis or under some other financial airnngement during the period in question and provide the dates of service the nature of the services pe1fonned the tenns of the business arrangement with respect to the pe1fonnance of such services the dates of any payments for such services and the amounts paid or the amounts owed for such services and identify the person or persons to whom or which such amounts were paid or such amounts are owed If you perfonned such services through a law firm state the name of the law finn through which you perfo1med such services in addition to the other info1mation requested herein RESPONSE Objection The infonnation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Inte1rngatories Reference to the period in question is vague and ambiguous Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number pennitted without leave of Comi In addition this Interrogatory seeks to invade the attorney-client and work product privileges Edwards adv Epstein Case No Notice of Serving Answers to InteJTogatories At any time during the period in question did you have any interest of five percent or more in a corporation partnership limited partnership limited liability company ttust or other entity including without limitation professional service entities If so state the name and address of each such entity the dates on which you held your interest the dates on which you disposed of such interest if applicable all amounts and other consideration you paid to acquire such interest and all amounts and consideration received directly or indirectly in connection with holding such interest and in connection with the disposition of such interest and include the names addresses and telephone numbers of all other controlling shareholders partners members officers directors managers settlors trust protectors trustees and beneficiaries of such entity See definition no above in preparing the response to this interrogatory with respect to any such interest acquired at any time on or after December or any such interest in which there was a change in the ownership thereof at any time on or after December RESPONSE Objection The infonnation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extt 267aordinarily broad scope of Definition of Counter-Defendants Interrogatories Reference to the period in question is vague and ambiguous Counter-Plaintiff fmther objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court With respect to the provision by you of legal services at any time during the period in question for each distinct arrangement through which you provided legal services describe in detail how you provided legal services whether as an individual as a sole proprietor through a professional corporation a professional partnership a professional limited liability company a professional association or similar entity or through a combination of any of the foregoing and for each entity through which you provided such legal services describe in detail all agreed whether or not followed and de facto business airnngements with respect to your provision oflegal services through such entity including without limitation cost sharing fee splitting fee percentage profit sharing and/or profit paiticipation If any such business arrangement was memorialized pursuant to an agreement describe the agreement all amendments modifications and supplements thereto the dates of the same and all patties thereto and identify and state the names addresses email addresses and telephone numbers of all persons in possession or control of embodiments of such agreement whether written oral or in electronic fonnat including without limitation in emails texts or other digital or electronic format If the actual business arrangement with respect to your provision of legal services through such entity differed from any memorialized business arrangement describe the difference and the reasons therefor RESPONSE Objection The information sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The inte1TOgatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Reference to the period in question is vague and ambiguous Edwards adv Epstein Case No Notice of Serving Answers to Inte1rngatories Counter-Plaintiff further objects on the grounds that the number of inte1rogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number pe1mitted without leave of Court In addition this Inten-ogatory seeks to invade the attorney-client and work product privileges Identify by name address and telephone number each and every domestic and foreign bank brokerage and/or other financial institution in which there was an account maintained in your name or over which you have had signatory authority or other such control during the period in question and provide the account number the type of account stmting date on which you had opened such account or had signatory authority or other such control over it For each such account provide the account balance if any at March I October I December I and August I and the account balance if any at the present date If the starting date of the account was a date between any two of the foregoing dates provide the opening account balance at the starting date See definition no above in preparing the response to this inten-ogatory for all such accounts opened at any time ori or after December RESPONSE Objection The info1mation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The inten-ogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Reference to the period in question is vague and ambiguous Counter-Plaintiff fu1ther objects on the grounds that the number of inte1TOgatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number pe1itted without leave of Comt Furnish the following financial information with respect to you as of March October I December and August and as of the present date Assets Cost Fair Market Value Cash Cash sun-ender value of insurance Accounts receivable Notes receivable Real estate including fractional interests Motor Vehicles Boats and other watercraft including fractional interests Aircraft including fractional interests Club Memberships Interests in Trusts Pmtnership Interests Limited Liability Company Interests Stocks bonds options financial contracts or other securities Edwards adv Epstein Case No Notice of Serving Answers to Inten-ogatories Interests in Commodities Pensions or annuities Precious and semi-precious stones Jewelry Artwork Antiques Watches Gold Silver Musical Instruments Other collections coins stamps pens memorabilia etc Contracts or Agreements Liabilities Loans on insurance Accounts payable Credit balances payable Leases payable Notes payable Mortgages Accrued real estate taxes Liens payable Judgments Reserves Face Amount Fair Market Value See definition no above in preparing the response to this inte1rngatory with respect to assets and liabilities rep01ted at December August and the present date Provide separate assets and liabilities tables for each distinct form of ownership described in clauses a and of definition no and for each separate assets and liability table identify the owner thereof RESPONSE Objection The information sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Inte1rngatories Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number pe11nitted without leave of Court Provide the following infonnation relating to your insurance policies in force as at each of March October December and August and as now in force Policy No and Description Insurer Policy Amount Cash Surrender Value Accumulated Dividends Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories Policy Loan No and Description Date Made Automatic Premium Payments Date Made See definition no above in preparing the response to this interrogatory at December and August and as now in force and for each such reporting date provide separate tables for each distinct form of ownership described in clauses a and of definition no and for each separate table identify the owner thereof RESPONSE Objection The info1mation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The inte1TOgatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court As at each of March October December and August and as at the present date identify each account receivable and note receivable held by you and in connection therewith set forth the name address and telephone number of the debtor identify the payee of each such account receivable and note receivable and provide the amount then outstanding of each such account receivable and note receivable See definition no above in preparing the response to this interrogatory at December and August and as at the present date RESPONSE Objection The information sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Com1 Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories At any time during the period in question did you own claim an interest in or possess or control whether directly or indirectly in your own name through ownership by entities in which you hold an interest or control or through trusts in which you are granters trustees or beneficiaries any real property If your answer to this interrogatory is in the affirmative state or identify a the dates of acquisition and disposition the propertys address the type of prope11y i.e house condominium commercial building investment property etc the cost of the property at the time purchased fair market value of the prope11y as at each of March October December and August and at the present date if the prope11y was disposed of or acquired in different name between any two of foregoing dates also provide the fair market value at the time of disposition or acquisition if not still owned the value of all consideration received directly or indirectly in connection with the disposition of the property the transferee of the property and your relationship to the transferee any mortgages or other encumbrances against the property and the balance if any of such mortgages or other encumbrances as at each of March I October I December I and August and at the present date provide the dates and amounts of all increases in any such mortgages or other encumbrances at any time on or after December I state the amounts and dates of all mo11gage payments made at any time on or after December I by any person or entity other than the mortgagor how you titled the property upon its purchase or acquisition i in the event of any changes in the titleholder on or after December in connection with which you retained beneficial ownership or effective control of the property provide the date of such change state the amount of any consideration paid in connection with the change identify the new titleholder and the relationship of the new titleholder to you i identify the cmTent titleholder and the relationship of the cmTent titleholder to you specifically identify and state all transfers of the prope1ty at any time on or after December I as a result of which title was held a in the name of Edwards spouse for the benefit of Edwards spouse in a trust under which Edwards spouse is a trustee or beneficiary or in the name of any other person in circumstances under which Edwards spouse has the use enjoyment or benefit of the same or can exercise effective control over the same or in the name of a dependent child of Edwards for the benefit of a dependent child of Edwards in trust under which Edwards dependent child is a beneficiary or in the name of any other person in circumstances under which Edwards dependent child has the use enjoyment or benefit of the same or in trust under which Edwards is a trustee or beneficiary or in the name of any other person in circumstances under which Edwards has the use enjoyment or benefit of the same or can exercise effective control over the same state the date of the transfer identify the new title holder describe the amount and form of all consideration exchanged in connection with the transfer and identify the payor and the payee of all such consideration exchanged See definition no above in preparing the response to this interrogatory with respect to all property which at any time on or after December I was acquired or disposed of or as to which at any time on or after December I title was transferred to a holder described in any of clauses a and of definition no RESPONSE Objection The information sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Reference to the period in question is vague and ambiguous Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories Counter-Plaintiff further objects on the grounds that the number of inte1Togatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Comt If at any time during the period in question you did not own the property that was occupied by your family whether full-time or part-time or if you do not own the property cmTently occupied by your family whether full-time or part-time set fo1th the name address email address and telephone number of the person who owned or own the property the arrnngement pursuant to which your family occupied or occupies the property e.g lease sub-lease other ammgement how such an-angement was memorialized the amount paid for such occupancy and the frequency of such payment the commencement date and termination date of that an-angement and the name address email address and telephone number of each of the patties to that ammgement including without limitation the payor of any payment made in connection with that an-angement whether or not the payor is an actual named pmty to that ammgement RESPONSE Objection The info1mation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Reference to the period in question is vague and ambiguous Counter-Plaintiff fmther objects on the grounds that the number of inte1Togatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number pe1mitted without leave of Comt As at each of March October December and August and as at the present date provide the following information with respect to each motor vehicle boat water craft or aircraft owned or used by you as at such date including without limitation in connection with any fractional ownership of any of the foregoing Descriptions A Motor Vehicles specify make model VIN year Cost Boats and watercraft specify make model SN Date Acquired Amount of Indebtedness Date if Pledged Pledged Owner Edwards adv Epstein Case No Notice of Serving Answers to Inten-ogatories yeaiJ Aircraft specify make model SN year Fractional Ownership Interests specify company description of fractional interest make model SN year Specifically identify and state all transfers of the foregoing prope1ty at any time on or after December as a result of which title was held a in the name of Edwards spouse for the benefit of Edwards spouse in a trust under which Edwards spouse is a trustee or beneficiary or in the name of any other person in circumstances under which Edwards spouse has the use enjoyment or benefit of the same or can exercise effective control over the same or in the name of a dependent child of Edwards for the benefit of a dependent child of Edwards in trust under which Edwards dependent child is a beneficiary or in the name of any other person in circumstances under which Edwards dependent child has the use enjoyment or benefit of the same or in trust under which Edwards is a trustee or beneficiary or in the name of any other person in circumstances under which Edwards has the use enjoyment or benefit of the same or can exercise effective control over the same state the date of the transfer identify the new title holder describe the amount and fonn of all consideration exchanged in connection with the transfer and identify the payor and the payee of all such consideration exchanged See definition no in preparing the response to this interrogatory at December and August and at the present date RESPONSE Objection The information sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The inte1rngatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Counter-Plaintiff further objects on the grounds that the number of inte1TOgatories propounded by the Counter-Defendant including subpaits substantially exceeds the maximum number permitted without leave of Court Set forth the following information regarding all stocks bonds options other securities and other financial instruments including but not limited to any interest in money markets and mutual funds and commodities directly or indirectly owned by you or held on your behalf at each of March October December August and the present date Amount of Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories Record Number of Date Description Issuer Owner Units Acquired Indebted Cost If Pledged Specifically identify and state all transfers of the foregoing prope1ty at any time on or after December as a result of which record title was held a in the name of Edwards spouse for the benefit of Edwards spouse in a trust under which Edwards spouse is a trustee or beneficiary or in the name of any other person in circumstances under which Edwards spouse has the use enjoyment or benefit of the same or can exercise effective contra I over the same or in the name of a dependent child of Edwards for the benefit of a dependent child of Edwards in trust under which Edwards dependent child is a beneficiary or in the name of any other person in circumstances under which Edwards dependent child has the use enjoyment or benefit of the same or in trust under which Edwards is a trustee or beneficiary or in the name of any other person in circumstances under which Edwards has the use enjoyment or benefit of the same or can exercise effective control over the same state the date of the transfer identify the new record title holder describe the amount and fonn of all consideration exchanged in connection with the transfer and identify the payor and the payee of all such consideration exchanged See definition no in preparing the response to this interrogatory RESPONSE Objection The info11nation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Counter-Plaintifmther objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Comt Identify separately for each pay or the amounts and dates of all sources of income paid to or for the benefit of you whether directly or indirectly for each and every year from January through the present date a salaries wages or commissions honoraria lecture fees board membership committee membership advisory board membership and other management related compensation including stock options and stock awards dividends interest income from businesses/professional activities partnership income i limited liability membership income income from other investments capital gains I annuities and pensions Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories rents and royalties income from estates and trusts disposition of commodities disposition of personal assets contracts or agreements See definition no in preparing the response to this interrogatory and report such items separately for each distinct form of ownership in clauses a and of definition no and for each separate report identify the owner RESPONSE Objection The information sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Counter-Plaintiff fmther objects on the grounds that the number of inte1TOgatories propounded by the Counter-Defendant including subpmts substantially exceeds the maximum number pennitted without leave of Court With respect to each of the items set forth in the preceding interrogatory state the name address email address and telephone number of the source from which the income was received and where applicable provide the account numbers of the accounts in the financial institutions in which such amounts were received by or for the benefit of you RESPONSE Objection The info1mation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Counter-Plaintiff further objects on the grounds that the number of inte1TOgatories propounded by the Counter-Defendant including subpmts substantially exceeds the maximum number permitted without leave of Court For each direct or indirect transfer conveyance or other disposition by or for the benefit of you whether for or without consideration at any time from March through the present date of any cash assets or other items of value with a fair market value of in excess of provide a description of the property or asset transferred the date of transfer the fair market value on the date of transfer the amount and nature of the full consideration received if any whether directly or indirectly to whom the consideration was paid and the full name address email address telephone number and the relationship to you of the transferee See definition no above in preparing your response to this interrogatory and include in your response transfers at any time on or after December by or to any of the persons listed in clauses a and of definition no RESPONSE Objection The infonnation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories of Counter-Defendants Interrogatories Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Comt At each of March October December and August and at the present date identify each interest directly or indirectly held by you or for your benefit in any Individual Retirement Accounts Stock Option Plans pension or profit sharing plans or any other savings or retirement plans other than those listed in response to previous interrogatories and include in the response to this interrogatory a description of the type amount and fair market value of the assets held as at such date RESPONSE Objection The info1mation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Counter-Plaintiff fmther objects on the grounds that the number ofinte1wgatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number pe1mitted without leave of Comt Has a financial statement credit application loan application lease application financing application or other financial affidavit or questionnaire for you been prepared at any time during the period from March through the present date If so state a the name address email address and telephone number of the person or entity to whom the same was given the reason the same was prepared the date the same was prepared and submitted and the name address email address and telephone number of each person to whom the same was delivered and/or who currently has a copy of the same See definition no above in preparing your response to this inte1Togatory and include in your response financial statements credit applications loan applications lease applications financing applications or other financial affidavits or questionnaires prepared at any time on or after December for any of the persons listed in clauses a and of definition no RESPONSE Objection The info1mation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The inte1rngatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Comt Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories Identify every legal action including without limitation alternative dispute resolution proceedings in which you have been a paiticipant including but not limited to as a patty or as legal counsel at any time during the period in question including but not limited to the title of the action the name of the court the case or index number the presiding judge arbitrator or other officiant the date the action was filed a brief description of the nature of the action and the result of the legal action e.g judgment for or against of a ce1tain amount If you participated as counsel in such legal action state the amount of all remuneration you have received or which you are entitled to receive in connection with such participation or if your remuneration is contingent on the outcome of such legal action or is subject to any similar airnngement and there has been no final disposition of such legal action state in detail the tenns of all agreements understandings and other an-angements relating to any remuneration you may be entitled to receive in connection with your pa1ticipation in such legal action RESPONSE Objection The information sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The inte1rngatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinaiily broad scope of Definition of Counter-Defendants Interrogatories Reference to the period in question is vague and ambiguous Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court In addition this Interrogatory seeks to invade the attorney-client and work product privileges As at each of March I October I December I and August and at the present date identify every loan and advance extended to and outstanding from you and in such identification include without limitation the name address email address and telephone number of the lender or identify the source of the advance provide the date of the loan or the advance the due dates of any installment payments the maturity date the principal amount the rate of interest the collateral or Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories security interest given by you your purpose in bmrnwing funds and the date and amount of each repayment If any such loan or advance was memorialized pursuant to one or more agreements promissory notes or other instruments describe each of the same all amendments modifications and supplements thereto the dates of the same and all patties thereto and identify and state the names addresses email addresses and telephone numbers of all persons in possession or control of any and all embodiments of such agreements promissory notes other instruments amendments modifications and supplements whether written oral or in electronic format including without limitation in emails texts or other digital or electronic format Specifically provide the dates and amounts of all increases in the outstanding principal of any such loans or advances at any time on or after December and the dates and amounts of all loan and advance repayments made at any time on or after December by any person or entity other than the original borrower thereunder See definition no above in preparing your response to this interrogatory with respect to each such loan or advance each such increase in the principal amount thereof and each such repayment made at any time on or after December RESPONSE Objection The information sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatmy seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number pennitted without leave of Comt At each of March October December and August and at the present date identify all credit debit and/or automatic teller ATM cards used by you or controlled by you regardless of whether such cards are titled in your name at any time during the period in question and for each such card identify state or describe the name and address of the financial institution that issued the card i.e VISA MasterCard American Express bank etc the name of the person to whom the card was issued i.e the name printed on the card the card number printed on such card the account number assigned by the financial institution for such card the account debtor for such card and all outstanding account balances in excess of as of such date See definition no above in preparing your response to this interrogatory and include in your response all credit debit and A TM cards issued at any time on or after December to any of the persons listed in clauses a and of definition no For each such account that is open as of any time on or after December specifically provide the dates and amounts of all increases in account balances in excess of at any time on or after December and the dates and amounts of all account repayments in excess of made at any time on or after December by any person or entity other than Bradley Edwards his spouse or the account debtor RESPONSE Objection The infonnation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatmy seeks to invade the economic privacy of the Counter-Plaintiff and all 267others encompassed within the extraordinarily broad scope of Definition Edwards adv Epstein Case No Notice of Serving Answers to Inte1rngatories of Counter-Defendants Inten-ogatories Counter-Plaintiff further objects on the grounds that the number of inten-ogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court State whether at any time during the period December I through the present date a trust was established by you whether directly or indirectly as granter or settlor a for any purpose in whole or in part relating to or having any effect of i protecting the wealth assets income profits investments or other revenue of you or your spouse from legal claims or litigation ii limiting the ability to quantify the actual value of and reducing the amounts of the personal wealth assets income profits investments or other revenue of you or your spouse i diverting assets income profits investments or other revenue away from you or your spouse and to any of the persons listed in clauses a and of definition no or iv otherwise dive1ting future assets income profits investments and other revenue away from you or your spouse while retaining effective control and or beneficial ownership or use thereof for yourself or herself or for the benefit of your family and state describe or identify a all instruments governing the fonnation and administration of.the trust including the original trust agreement therefor and all amendments modifications and supplements thereto the situs of the trust the names addresses email addresses and telephone numbers of the settlors or grantors the trustees the trust protectors and the beneficiaries of the trust the assets of the trust the locations of such assets and the fair market value of the same at the time of creation and at each of December I August I and the present date the location and persons in possession or control all documents that suppo1t your answer to this interrogatory RESPONSE Objection The information sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Counter-Plaintifmther objects on the grounds that the number of inte1rngatories propounded by the Counter-Defendant including subpaits substantially exceeds the maximum number pennitted without leave of Comt Edwards adv Epstein Case No Notice of Serving Answers to Inten-ogatories Identify all federal state local and foreign income tax returns filed by or for you and any businesses corporations partnerships trusts limited liability companies or other entities owned or controlled by you for any calendar or fiscal year falling within the period include in such identification without limitation a description of the return the identity of the taxpayer for whom the return was filed the date the return was filed the government agency with which the return was filed including the location service center and address of the government agency with which such return was filed the period for which the return was filed the names addresses email addresses and telephone numbers of all persons to whom a copy of the return was delivered and/or who cmTently hold a copy of the return and for each such return identify each of source of all reported income in such return and the separate amounts derived from each such source RESPONSE Objection The information sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Counter-Plaintifmther objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subpaits substantially exceeds the maximum number pennitted without leave ofComt State identify and describe with particularity all promises contracts agreements understandings and airnngements whether written oral or in electronic fonnat including without limitation in emails texts or other digital or electronic fmmat that you and/or your law finn have had with any and all attorneys investigators paraprofessionals and other contractors or individuals including witnesses for services provided to or for the benefit of LM EW Jane Doe and/or Virginia Giuffre nee Robe1ts at any time during the period in question including without limitation engagement letters retainer letters fee sharing airnngements common interest or joint defense agreements Include in your response the fonnat in which any such promises contracts agreements understandings and arrangements are embodied the names addresses email addresses and telephone numbers of all persons to whom such embodiments have been delivered or transmitted the dates of such delivery or transmission and whether to your knowledge such embodiments are in the possession or control of such persons RESPONSE Objection The infonnation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Inte1TOgatories Counter-Plaintifmther objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subpaits substantially exceeds the maximum number permitted without leave of Comt State identify and describe with paiticularity all promises contracts agreements understandings and atTangements whether written oral or in electronic format including without limitation in emails texts or other digital or electronic fo1mat that you and/or your law firm have or at any time during the period in question had with any and all attorneys investigators paraprofessionals and other Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories contractors or individuals including without limitation witnesses for services provided to or for the benefit of you LM EW Jane Doe and/or Virginia Giuffre nee Roberts in connection with this Action or any other matters pe11aining to or involving Jeffrey Epstein Include in your response the fonnat in which any such promises contracts agreements understandings and arrangements are embodied the names addresses email addresses and telephone numbers of all persons to whom such embodiments have been delivered or transmitted the dates of such delivery or transmission and whether to your knowledge such embodiments are in the possession or control of such persons RESPONSE Objection The inf01mation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Counter-Plaintifm1her objects on the grounds that the number of inte1rngatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Com1 State identify and describe with pai1icularity all promises contracts agreements understandings and arrangements at any time during the period in question whether written oral or in electronic fonnat including without limitation in emails texts or other digital or electronic format between Jack Scarola Searcy Denney Scarola Barnhai1 Shipley PA or Boies Schiller Flexner LLP and/or any and all attorneys investigators paraprofessionals and other contractors or individuals including without limitation witnesses for services provided to or for the benefit of you in connection with this Action or any other matters pe11aining to Jeffrey Epstein Include in your response the fonnat in which any such promises contracts agreements understandings and arrangements are embodied the names addresses email addresses and telephone numbers of all persons to whom such embodiments have been delivered or transmitted the dates of such delivery or transmission and whether to your knowledge such embodiments are in the possession or control of such persons RESPONSE Objection The info1mation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The inte1rngatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Counter-Plaintifm1her objects on the grounds that the number of inte1rngatories propounded by the Counter-Defendant including subpai1s substantially exceeds the maximum number permitted without leave of Com1 Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories State identify and describe with paiticularity all promises contracts agreements understandings and arrangements whether written oral or in electronic format including without limitation in emails texts or other digital or electronic fo1mat that you Farmer Jaffe Weissing Edwards Fistos Lehrman PL and/or any other law firm through which you have provided legal services and/or any other lawyer and/or law finn have or at any time during the period in question have had with LM EW Jane Doe or Virginia Giuffre nee Robe11s which in any way relates to allegations by LM EW Jane Doe or Virginia Giuffre nee Robe1ts against Jeffrey Epstein including without limitation engagement letters retainer letters fee sharing affangements common interest or joint defense agreements royalty agreements publishing agreements literary rights agreements any other agreements relating to media rights film rights television rights publishing rights book rights photograph rights story rights agency or similar matters relating to allegations concerning Jeffrey Epstein Include in your response the format in which any such promises contracts agreements understandings and mrnngements are embodied the names addresses email addresses and telephone numbers of all persons to whom such embodiments have been delivered or transmitted the dates of such delivery or transmission and whether to your knowledge such embodiments are in the possession or control of such persons RESPONSE Objection The info1mation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The inte1TOgatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Reference to the period in question is vague and ambiguous Counter-Plaintiff fu1ther objects on the grounds that the number of inte1TOgatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number pe1mitted without leave of Court State identify and describe with particularity all promises contracts agreements understandings and arrangements whether written oral or in electronic format including without limitation in emails texts or other digital or electronic format that LM EW Jane Doe or Virginia Giuffre nee Roberts have or at any time during the period in question have had with publicity agents public relations finns book publishers authors literary agents syndicators newspaper publishers film or television producers news agencies television networks entities engaged in similar business which in any way relates to allegations by LM EW Jane Doe or Virginia Giuffre nee Roberts against Jeffrey Epstein including without limitation engagement letters retainer letters royalty agreements publishing agreements literary rights agreements agency agreements management agreements any other agreements relating to media rights film rights television rights publishing rights book rights photograph rights stmy rights agency or similar matters relating to allegations concerning Jeffrey Epstein Include in your response the format in which any such promises contracts agreements understandings and mrnngements are embodied the names addresses email addresses and telephone numbers of all persons to whom such embodiments have been delivered or transmitted the dates of such delivery or transmission and whether to your knowledge such embodiments are in the possession or control of such persons RESPONSE Objection The information sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Reference to the period in question is vague and ambiguous Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Comt In addition this InterTOgatory seeks to invade the attorney-client and work product privileges Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories For each payment or distribution made by you and/or your law fom any entity with which you are affiliated or pursuant to a joint agreement regarding the proceeds of settlement paid by Jeffrey Epstein in connection with the settlement of claims of LM EW and Jane Doe against Jeffrey Epstein state identify and describe the amount of payment the date of payment the payee and any promises contracts agreements understandings and mrnngements regarding said payment and all amendments modifications and supplements of the same pursuant to which such payment was made Include in your response the aggregate amount of such proceeds of settlement for each of LM EW and Jarie Doe retained by you and/or your law firm the amount of such retained proceeds allocated to the reimbursement of expenses the amount of such retained proceeds retained by your law firm as its share of any contingency fee and the amount of such retained proceeds allocated to you as distinguished from your law firm whether or not paid to you as your share of the fee payable RESPONSE Objection The info1mation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Reference to the period in question is vague and ambiguous Counter-Plaintiff fu1ther objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number pennitted without leave of Court In addition this Interrogatory seeks to invade the attorney-client and work product privileges Notwithstanding the foregoing objections Counter-Plaintiff acknowledges that the following sums were paid by Jeffrey Epstein to voluntarily settle the claims of sexual molestation asserted against Jeffrey Epstein by each of the following L.M E.W Jane Doe million million million State identify and describe with pa1ticularity any and all trust arrangements guardian arrangements custodial mrnngements or similar arrangements including accounts established by and/or for the benefit of each of LM EW and Jane D0e regarding the receipt administration and/or payment or distribution of the proceeds of settlement of claims by LM EW or Jane Doe against Jeffrey Epstein Include in your response a description of the agreements contracts and instruments and all amendments Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories modifications and supplements thereto pursuant to which such arrangements were established the dates of the same the names addresses email addresses and telephone numbers of all settlers granters trustees guardians custodians other fiduciaries and beneficiaries including without limitation contingent beneficiaries of such aiTangements the names of the account holders the names of the authorized signatories the account numbers and the names addresses telephone numbers of individual contacts of the financial institutions for all accounts established to receive and hold such proceeds of settlement RESPONSE Objection The infonnation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Reference to the period in question is vague and ambiguous Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number permitted without leave of Court In addition this Interrogatory seeks to invade the attorney-client and work product privileges Notwithstanding the foregoing objections Counter-Plaintiff acknowledges that the following sums were paid by Jeffrey Epstein to voluntarily settle the claims of sexual molestation asserted against Jeffrey Epstein by each of the following L.M E.W Jane Doe million million million Please describe in detail quantify and explain the financial loss including the amount that you contend to have suffered as described in your Fourth Amended Counterclaim to wit a injmy to your reputation mental anguish embarrassment and anxiety fear of physical injury to you and members of your family the loss of the value of your time required to be dive1ted from your professional responsibilities the cost of defending against Epsteins claims Edwards adv Epstein Case No Notice of Serving Answe1:s to Inten-ogatories RESPONSE Each of the listed elements of damage is presently unliquidated and will be established by the verdict of the jury empaneled to hear this case and entrusted with the responsibility to render a verdict that fully and fairly compensates Bradley Edwards for every element of damage sustained by him in the past and continues to be sustained by him in the future As the jury will be instructed there is no exact measure for such damages but their verdict is required to take all evidence presented to them under consideration and to be fair just and reasonable under the circumstances as they find them to exist Please identify with specificity the manner by which you determined that any perceived injury to your reputation mental anguish embarwssment and anxiety fear of injury and any other damage you allege to have suffered by Epsteins filing suit against you in December was attributable to the lawsuit and not to being partners with Scott Rothstein/a partner at RRA RESPONSE Bradley Edwards was never partners with Scott Rothstein/a partner at RRA and consequently could not have sustained any injury attributable to a circumstance that never existed Please describe in detail and identify with specificity eve1y social media outlet website blog printed materials seminar materials or any other printed or published media on which you your law firm or any association with which you are affiliated has ever adve1tised references or otherwise places the name of Jeffrey Epstein and include a detailed description and the date of each and eve1y such reference adve1tisement placement publication dissemination or promotion identify the persons or groups of persons to whom the same was made and state the locations where made and state whether or not the materials used in connection with such reference adve1tisement placement publication dissemination or promotion are in your possession or control or are still available on line or in print and identify the persons or website from whom such materials may be obtained RESPONSE Objection The infonnation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Reference to the period in question is vague and ambiguous Counter-Plaintiff fmther objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number pe1mitted without leave of Comt In addition this Interrogatory seeks to invade the attorney-client and work product privileges Edwards adv Epstein Case No Notice of Serving Answers to Inten-ogatories Please describe with particularity any and all evidence circumstances and events upon which you rely in asserting that your reputation was damaged as alleged in your Counterclaim including without limitation specifically describing how that damage is attributable to Epsteins lawsuit against you RESPONSE The allegations of Epsteins maliciously filed Complaint are defamatory per se Please explain in detail the amount of time required to be diverted from your professional responsibilities including but not limited to the time lost each date on which the time was lost the case/matter on which you would have otherwise spent the time your billable hourly rate if any you allege to have lost and for each case/matter identified please provide the amount of income derived by you your firm or any entity acting on your behalf in that matter Please detail all other evidence methods and calculations on which you intend to rely to quantify the damages you claim are attributable to time diverted from your professional responsibilities as alleged in your Counterclaim RESPONSE Time dive11ed from Bradley Edwards professional responsibilities is reflected in previously produced time records and will be updated prior to the expiration of discovery Counter Plaintiff however objects to this interrogatory on the grounds that the number of interrogatories propounded by the Counter-Defendant including subpai1s substantially exceeds the maximum number pe1mitted without leave of com1 For each payment or distribution made by you Rothstein Rosenfeldt Alder Farmer Jaffe Weissing Edwards Fistos Lehnnan PL and/or any other law finn through which you have provided legal services and/or any other lawyer and/or law firm to Beth Williamson in connection with any claims asserted against Jeffrey Epstein state identify and describe the amount of the payment the date of payment the source of the payment proceeds the reasons for the payment and any promises contracts agreements understandings and airangements regarding said payment and all amendments modifications and supplements of the same pursuant to which such payment was made RESPONSE Objection The infonnation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Reference to the period in question is vague and ambiguous Edwards adv Epstein Case No Notice of Serving Answers to Inten-ogatories Counter-Plaintiff further objects on the grounds that the number of inte1rngatories propounded by the Counter-Defendant including subpaiis substantially exceeds the maximum number pennitted without leave of Court In addition this Interrogatory seeks to invade the attorney-client and work product privileges For each payment or distribution made by you Rothstein Rosenfeldt Adler Fanner Jaffe Weissing Edwards Fistos Lehnnan PL and/or any other law fom through which you have provided legal services and/or any other lawyer and/or law firm to L.M E.W Jane Doe any other purp01ied victims any investigators paraprofessionals other attorneys other contractors or il1dividuals including without limitation witnesses and any publicity agents public relations finns book publishers authors journalists bloggers rep01iers literary agents syndicators newspaper publishers film or television producers news agencies television networks or entities engaged in similar business which payment in any way relates to claims against Jeffrey Epstein state identify and describe the amount of payment the date of payment the source of the payment proceeds the reasons for the payment and any promises contracts agreements understandings and airnngements regarding said payment and all amendments modifications and supplements of the same pursuant to which such payment was made RESPONSE Objection The infonnation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic ptivacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Reference to the period in question is vague and ambiguous Counter-Plaintiff fu11her objects on the grounds that the number of inteffogatories propounded by the Counter-Defendant including subpaiis substantially exceeds the maximum number pe1mitted without leave of Comi In addition this Interrogatory seeks to invade the attorney-client and work product privileges For each receivable due at any time during the relevant period to you Rothstein Rosenfeldt Adler Farmer Jaffe Weissing Edwards Fistos Lehnnan PL and/or any other law finn through which you have provided legal services from any other lawyer and/or law finn L.M E.W Jane Doe any other purported victims any investigators paraprofessionals any other contractors and any publicity agents public relations finns book publishers authors,journalists bloggers repo1iers literary agents syndicators newspaper publishers film or television producers news agencies television networks or entities engaged in similar business which receivable in any way relates to Edwards adv Epstein Case No Notice of Serving Answers to Interrogatories the instant case or any other case against Jeffrey Epstein or any other claims against Jeffrey Epstein state identify and describe the amount of payment the date of payment the source of the payment proceeds the reasons for the payment and any promises contracts agreements understandings and arrangem nts regarding said payment and all amendments modifications and supplements of the same pursuant to which such payment was made RESPONSE Objection The infonnation sought is not relevant material or reasonably calculated to lead to the discovery of admissible evidence The interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all others encompassed within the extraordinarily broad scope of Definition of Counter-Defendants Interrogatories Reference to the period in question is vague and ambiguous Counter-Plaintiff fmther objects on the grounds that the number of interrogatories propounded by the Counter-Defendant including subparts substantially exceeds the maximum number pe1mitted without ve of Court In addition this Interrogatory seeks to invade the attorney-client and work product privileges Notwithstanding the foregoing objections Counter-Plaintiff acknowledges that the following sums were paid by Jeffrey Epstein to voluntarily settle the claims of sexual molestation asserted against Jeffrey Epstein by each of the following Edwards adv Epstein Case No Notice of Serving Answers to Inten-ogatories L.M E.W Jane Doe Signature of Answering Party 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 type of identification as identification and who did/did not take an oath Notary Public State of Florida at Large My Commission expires Commission No U?vO?OP?F3O G?M?tI?OO?G0 W?ii?W8x??I7 I K?K A o(o3oBz 4K 30KCb 2e p2t 2A A Q?8F JK TZ N?M?r NEeD?M rq A WS?nY?GE mR?d YBWY xy?u?u i hSKI YjnU?zy?h ZF?gj?_?Ґ y:1y E?ak?2 g6 EeD T?J Lf Kf??w k?հ ngq 31Fs_g d6 TZ 5_ jz qr A..AA?A..AA g6 X?a M?N q?M 10Cy J?tZ m?E9q6t ORA?豕ar A i A i A i A I 1z I q?M CTX qY CTX qr a nd blWF uq??Ԑgg?8 9A A I 0b qr h:?WB p?c O?H lOK8 A Og I M?q qr un i W!k CTX yN?hY W?Qsyzo KMu?m M??N q?M CTX Y10Cy شl a GF3IW O?ljcప H?X?D?S G5 G5 CTX qr q0T3 o3z I_ 3j i jh3 A 0b l??9Lڱ?lVy 1x vff?516SP?ml V?rL?k?Nfq??yasZ??l OiwvO4h/??F zWH9j شl Ƨw??ơ ByMY?YA_ eݷ?y?j Na?x?wV g6 AA..AA,/AB..AA A..AA..A B..AA..B g6 jz AA..AA gq 1:K6Bg AA 31Fs_g CTX A W?n?jZ qq 1M bWd aHA?A AB..AA qy R0 1SJq?xXkI?h?A/.AA./A a?F A?A A?V?E XP R_ A ABB3B OR1BA OA3 B?B Rg I?I I UV N?M?N 10Cy DK7 0GHFHEH It K7I H:Ct J8L l6L uA I Ӷ??t t:Z M?LM DGn??sCY KMqP;G 8I q?x HA8?j hqSEEn OtŐX?OX dBN CTX I O!Y rY b?UU 0Z g6 4D J4W 2P O3 P:c 0v sz B5 A4 CF4 B5 L_ E5 a qCX 10Cy rq Fa?3U M3 J?c _9??NºdPtq??V e?U wf Mw xO?T A I dc rM?N rqM??q 10Cy rq v현?y T?H I ac qr rM 10Cy rq 3V M3 2?Zs 5g t4 RU T0 t?(c AZ kP d6 ac qr UO ED Eej Ko?5OJ Vg lg _Y 6x P6p6 C1 I5d rM qr 10Cy a d6 a a Nqr qqr E1S lg z??g 10Cy qr E1S C?t z?i 6BT v0y5z6 PE CTX ED 9q 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 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 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
