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CASE NO.: 502009CA040800XXXXIVIBAG
Plaintiff(s),
VS.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
M., individually,
Defendant(s).
Counterplaintiff, Bradley J. Edwards, hereby gives notice that pursuant to Rule 1.340(e),
Florida Rules of Civil Procedure, that Net Worth Interrogatories numbered 1 through 13 have
been directed to Counterdefendant, JEFFREY EPSTEIN, this ti A clay of December, 2012.
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
to all Counsel on the attached list, this 0( Wday of I
ber, 2012.
Jack9
Flo
ar No.: 169440
E-mail:
ndary E-mail(s):
Searcy Denney Scarola
art
p ey, .A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone: (561) 686-6300
Fax:
(561) 383-9451
Attorney for Bradley J. Edwards
EFTA00788596
Case No.: 502009CA040800XXXXMI3AG
COUNSEL LIST
Jack A. Gold
Marc S. Nurik,l uire
Atterbury, Goldberger & Weiss, P.A.
250 Australian Avenue South, Suite 1400
West Palm Beach, FL 33401
Phone: (561)-659-8300
Fax: (561)-835-8691
Attorneys for Jeffrey Epstein
Farmer, Jaffe, Weissing, Edwards, Fistos &
Lehrman, FL
425 North Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301
Phone: (954) 524-2820
Fax: (954) 524-2822
Fred Haddad Es uire
Fred Haddad, P.A.
One Financial Plaza, Suite 2612
Fort Lauderdale, FL 33394
Phone: (954)-467-6767
Fax: (954)467-3599
Attorneys for Jeffrey Epstein
2
Law Offices of Marc S. Nurik
One E Broward Blvd., Suite 700
Fort Lauderdale, FL 33301
Phone: (954)-745-5849
Fax: (954)-745-3556
Attorneys for Scott Rothstein
Lill Ann Sancti
Esquire
e
w um
1441 Brickell Avenue, 15th Floor
Miami, FL 33131
Phone: (305)-503-5503
Fax: (305)-503-6801
Attorneys for Jeffrey Epstein
Tonja Haddad Coleman, Esquire
Tonja Haddad, P.A.
315 SE 7th Street, Suite 301
Fort Lauderdale, FL 33301
Phone: (954)-467-1223
Fax: (954)-337-3716
Attorneys for Jeffrey Epstein
EFTA00788597
Caen No.: 502009CA040800XXXXMI3AG
What is your full name?
2.
How are you currently employed?
3.
State the amount of your current annual income from all sources for each of the
past 3 years and describe all additional benefits received by you or payable to you for each of the
past 3y ears 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.
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 property or security interest of any sort;
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Case No • 502009CA0408003OOOCMBAG
(b)
The date and cost of acquisition;
(c)
The current fair market value of each such interest;
(d)
The manner in which such value was calculated.
5.
As to each income tax return filed by you or on your behalf with any taxing
authority for the years 2009 through 2012, 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:
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(a)
The address,
(b)
The legal description of the property;
(c)
The ass sled value of the property for tax purposes;
(d)
The date and price of acquisition;
(e)
Whether, when, by whom, why and at what amount the property has been
appraised since the time of purchase;
(f)
Whether, when, and at what price the property has been offered for sale
since the time of purchase;
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Case No.: 502009CA040800)OOOCMBAG
(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.
(j)
The current fair market value of the property and a description of the
manner in which that value was calculated
7.
List each item and state the estimated value of all personal tangible, and
intangible property in which you have an interest which personal property was acquired at a cost
in excess of $10,000 or which personal property has an estimated present value in excess of
$10,000, and as to each state:
(a)
The date of acquisition;
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Case No.: 502009CA040800XXXXMBAG
(b)
The cost of acquisition;
(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:
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Case No.: 502009CA040800XXXXMBAG
(a)
The name and address of the business;
(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 365 day period
immediately preceding your receipt of these interrogatories.
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Case No.: 502009CA040800)COOCMBAG
11.
Identify all other assets of a value in excess of $10,000 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.
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Case No.: 502009CA040800)OOOCMBAG
12.
Identify all other liabilities of an amount in excess of $10,000 not previously
identified and as to each state:
(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.
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Case No.: 502009CA040800XXXXMBAG
13.
As to any calculation or estimate of your net worth at any time in the five years
immediately preceding your receipt of these interrogatories, state:
(a)
the date of the calculation or estimate;
(b)
the name and address of the person or entity responsible for performing
the work
(c)
the reason for performing the calculation or estimate;
(d)
the amount of net worth calculated or estimated
14.
What is your present net worth?
15.
As to all transfers of anything of a value in excess of $10,000 made by you or on
your behalf within the past 5 years, state:
(a)
a description of the transferred property;
(b)
the reason for the transfer;
(c)
the value of the item(s) transferred at the time of transfer;
(d)
the date and cost of your acquisition of the item(s);
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(e)
whether you received anything of value in exchange for the transferred
item(s) and, if so, a description of what you received and the dollar value of what
you received;
(I)
the name and address of the recipient of each transferred item
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)
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