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CASE NO.: 502009CA040800XXXXMBAG
Plaintiff,
VS.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
L.M., individually,
Defendant,
Bradley J. Edwards, by and through the undersigned counsel, moves this Honorable
Court pursuant to the provisions of Rule I.340(a), Florida Rules of Civil Procedure, to increase
the number of initial interrogatories permitted herein so as to allow for the filing of two sets of
additional interrogatories in accordance with those attached, and in support of this motion,
Bradley J. Edwards would show:
I.
The Supreme Court has not approved a form of interrogatories for this type of
action.
2.
The elements of the claims asserted and the nature and complexity of the factual
circumstances giving rise to the claims are not susceptible to being adequately covered within the
twenty-five (25) interrogatory limit.
3.
The elements of defenses asserted or expected to be asserted are not susceptible to
being adequately covered within the twenty-five (25) interrogatory limit. Two sets of additional
interrogatories are attached.
EFTA00613719
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Edwards' Motion to Expand Interrogatories
Page 2 of 3
4.
The use of written interrogatories is the least burdensome, least expensive and
most expeditious discovery means available to the Defendant by which to obtain necessary
information and narrow trial issues.
5.
The Plaintiff will not be prejudiced through the granting of this motion.
6.
The foregoing factors and others to be presented upon hearing of this Motion
constitute good cause for increasing the number of interrogatories permitted herein.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
U.S. Mail to all counsel on the attached list, thi
day of May, 2017.
a
ar No.: 169440
Denney Scarola Barnhart & Shipley, P.A.
9 Palm Beach Lakes Boulevard
West Palm Beach Florida 33409
Phone:
Fax:
Attorneys for Defendant
EFTA00613720
Edwards adv. Epstein
Case No.: 502009CA040800)C<XXMBAG
Edwards' Motion to Expand Interrogatories
Page 3 of 3
COUNSEL LIST
William Chester Brewer, Esquire
250 S Australian Avenue, Suite 1400
West Palm Beach, FL 33401
Pho
Fax:
Attorneys for Jeffrey Epstein
Jack A. Goldberger, Esquire
Atterbury Goldberger & Weiss, P.A.
250 Australian Avenue S, Suite 1400
West Palm Beach, FL 33401
Pho
Fax:
Attorneys for Jeffrey Epstein
Bradle J. Edwards, Es uire
Farmer Jaffe Weissing Edwards Fistos &
Lehrman, P.L.
425 N Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301
Pho
Fax:
Fred Haddad, Esquire
Fred Haddad,
One Financial Plaza. Suite 2612
Fort Lauderdale, FL 33394
Phon
Fax:
Attorneys for Jeffrey Epstein
Tonja Haddad Coleman, Esquire
Tonja Haddad, P.A.
315 SE 7th Street, Suite 301
Fort Lauderdale, FL 33301
Phon
Fax:
Attorneys for Jeffrey Epstein
Marc S.1‘
il
urilc,
re
One E Broward Blvd., Suite 700
Fort Lauderdale, FL 33301
Pho
Fax:
Attomeys for Scott Rothstein
EFTA00613721
As to every individual identified on Jeffrey Epstein's List of Trial Witnesses, state the
following:
1. Each contested
factual
issue
expected
to
be
addressed
by the witness;
ANSWER:
2. A detailed description of the testimony expected to be presented at trial by the witness as
to each contested factual issue;
ANSWER:
3. A description of the Trial Exhibit List number of each exhibit expected to be introduced
into evidence by the witness;
ANSWER:
4. A description of the Trial Exhibit List number of each exhibit introduced through other
means which the witness is expected to testify about, together with a description of the
witness' expected testimony regarding each exhibit;
ANSWER:
EFTA00613722
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Bradley J. Edwards Fact Wimess Interogs to Epstein
Page 2 of 5
STATE OF
COUNTY OF
The foregoing instrument was acknowledged before me this
day of
, 20
, by
, who is personally known to
me or who has produced
as identification and who did/did not
take an oath.
(SEAL)
(Notary signature)
(Notary name - print)
NOTARY PUBLIC, State of Florida
(Serial number, if any)
2
EFTA00613723
EFTA00613724
1.
What is your full name?
2.
How are you currently employed?
3.
State the amount of your current salary and describe all additional benefits of
employment including bonuses, allowances, pension and profit sharing participations, stock
options, deferred compensation, insurance benefits and other prerequisites of your employment
including the dollar amount or dollar value of each during the twelve months preceding your
receipt of these interrogatories.
4.
If you own or have any beneficial interest in any stocks, bonds, mutual funds, or
other securities of any class in any government, governmental organization, company, firm or
corporation, whether foreign or domestic, please state:
(a)
The name and address of the entity in which you own or have any beneficial
propriety or security interest of any sort;
EFTA00613725
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
(b)
The serial number of each bond, share, stock certificate or other evidence
of ownership or security;
(c)
The current fair market value of each such interest;
(d)
The manner in which such value was calculated.
5.
As to each federal income tax return filed by you or on your behalf for the years
2011 through and including 2016, identify as specifically as identified in your tax return the source
of all reported income and the separate amounts derived from each source
6.
For each parcel of real property in which you hold any interest, state:
(a)
The address,
2
EFTA00613726
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
(b)
The legal description of the property;
(c)
The assessed value of the property for tax purposes;
(d)
The date and price of acquisition;
(e)
Whether, when, and at what amount the property has been appraised since
the time of purchase;
(0
Whether, when, and at what price the property has been offered for sale
since the time of purchase;
3
EFTA00613727
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
(g)
The name and address of each real estate agent with whom the property has
been listed for sale since the time of purchase;
(h)
The cost of any improvements made to the property since purchase;
(i)
The nature of your interest in the property.
7.
List each item and state the estimated value of all personal property in which you
have an interest which personal property was acquired at a cost in excess of $5,000 or which
personal property has an estimated present value in excess of $5,000, and as to each state:
(a)
The date of acquisition;
(b)
The cost of acquisition;
4
EFTA00613728
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
(c)
The current estimated fair market value;
(d)
The manner in which the fair market value was estimated.
8.
If any of the real or personal property owned by you, either individually, jointly or
otherwise, is encumbered by either a real estate mortgage, chattel mortgage, or any other type of
lien, then for each item of property, state a description of the nature and amount of the
encumbrance, the date the encumbrance arose, whether the encumbrance is evidenced by any
written document and, if so, a description of that document.
9.
If you have an ownership interest in any businesses, for each business state:
(a)
The name and address of the business;
5
EFTA00613729
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
(b)
The present book value and the present market value of your interest in the
business, and its percentage of the total value of the business;
(c)
A description of the manner in which the stated fair market value was
calculated.
10.
Identify all banks, credit union and savings and loan accounts, in which you have
an interest or right of withdrawal and for each account state:
(a)
Where the account is located;
(b)
The highest and lowest balance in the account during the 40 day period
immediately preceding your receipt of these interrogatories.
6
EFTA00613730
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
11.
Identify all other assets of a value in excess of $5,000 which assets were not
previously identified and as to each state:
(a)
The date of acquisition;
(b)
The cost of acquisition;
(c)
The current estimated fair market value;
(d)
The means utilized to estimate the current fair market value.
12.
Identify all other liabilities not previously identified and as to each state:
7
EFTA00613731
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
(a)
The date the liability arose;
(b)
The amount of the liability at inception;
(c)
The terms of repayment or satisfaction;
(d)
The current outstanding balance.
13.
State your year end net worth for each of the past 5 years and your best estimate of
your present net worth.
8
EFTA00613732
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
STATE OF
)
COUNTY OF
)
The foregoing instrument was acknowledged before me this
day of
, 20
, by
, who is personally known to
me or who has produced
as identification and who did did/
not take an oath.
(SEAL)
(Notary signature)
(Notary name - print)
NOTARY PUBLIC, State of Florida
(Serial number, if any)
9
EFTA00613733