EXHIBIT A

EXHIBIT A EFTA00801993 #291874/mep JEFFREY EPSTEIN, Plaintiff(s), VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG REQUEST TO PRODUCE TO .IEFPREY EPSTEIN Defendant/Counter-Plaintiff, Bradley J. EdwitAls by.and through his undersigned counsel, t requests, pursuant to Rule 1.350 of the Flo • ttle's Of Civil Procedure, that Plaintiff/Counter c A SC , Defendant, Jeffrey Epstein, produce aI 't radley J. Edwards to inspect and copy each of the following documents*: 1. All documen conytifuting, reflecting, or relating to communications between Plaintiff or any awn of Plaintiff, on the one hand, and William Scherer, or any person associate,ckiith Villliam Scherer in the practice of law, any prosecuting, law enforcement, and/or goveitiment entity which communication relates directly or indirectly to any allegation of illegal activity or tortuous conduct in which Epstein is alleged to have engaged. *"Documents" shall include, but not be limited to all non-identical copies of writings, drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data compilations from which information can be obtained, translated, if necessary, by the party to EFTA00801994 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Request to Produce to Jeffrey Epstein whom the request is directed through detection devices into reasonably usable form. "Documents" also include all electronic data as well as application metadata and system metadata. All inventories and rosters of your information technology (IT) systetns--e.g., hardware, software and data, including but not limited to network drawings, lists of computing devices (servers, PCs, laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps and security tools and protocols. It is requested that the aforesaid production be made within thirty days of service of this .request at the offices of Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida. Inspection will be made by visual observation, examination and/or copying. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Fax and U.S. Mail to all CounseIon the attached list, t ay of pril, 2t 11. r No.: 169440 enney Scarola Barnhart & Shipley Palm Beach Lakes Boulevard est Palm Beach Florida 33409 Phone: Fax: Attorneys for Bradley J. Edwards 2 EFTA00801995 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Request to Produce to Jeffrey Epstein COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. Attorney For: Jeffrey Epstein 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Pho Fax: Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL Attorney For: Jeffrey Epstein 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Pho Faxl Marc S. Nurik Law Offices of Marc S. Nurik Attorney For: Scott Rothstein One E Broward Blvd., Suite 700 , Fort Lauderdale, FL 33301 Pho Fax: Joseph L. Ackerman, Jr., Esquire Fowler White Burnett, P.A. Attorney. For: Jeffrey Epstein 901 Phillips Point West 777 S Flagler Drive West Pidm Beach, FL 33401-6170 Pho Fax: 3 EFTA00801996 EXHIBIT B EFTA00801997 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800,OOOCMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, C .._, n • To 2 n c ... <CDC --C:-"C r- - I fl C") f>..) `" r" REQUEST FOR FOR PRODUCTION TO COUNTER-DEFENDANT (PUNITIVE DAMAGES? BRADLEY J. EDWARDS, by and through his undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, hereby requests Production from JEFFREY EPSTEIN of the documents and things described below for the purpose of inspection, copying, photographing, testing or sampling and any other purposes permitted under the Florida Rules of Civil Procedure at the office of the undersigned within thirty (30) days of service of this request. DEFINITIONS AND INSTRUCTIONS: A. The term "documents" as used in this Request is defined as including, but not limited to, the original and any non-identical copy (which is different from the original because of notations on such copy or otherwise) of all correspondence, telegrams, teletype messages, contracts (including drafts, proposals and any and all exhibits thereto), draft minutes and addenda, memoranda (including inter and intra office memoranda), memoranda for file, pencil jottings, diary entries, desk calendar entries, reported recollections and other written form of _EXHIBIT EFTA00801998 Edwards adv. Epstein Case No.: 502009CA040800XJOO(MBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 2 of 12 notation of events or intentions, transcripts and recordings of conversations and telephone calls, books, records, photographs, reports, tabulations, charts, books of account, ledgers, invoices, financial statements, purchase orders, receipts, canceled checks and other documentary material not subject to attorney/client privilege, together with any documents thereto, or enclosures therewith. The term "document" shall include data stored, maintained or organized electronically or magnetically through computer equipment, translated, if necessary, by you into comprehensible form. The term "document includes the complete file or files within which any items constituting a "document" are found, including all such files within your possession, custody or control wherever located, including any branch, local or main offices, and including not only the contents of such files but also the folder, jacket, envelope or other container in which the file is kept or stored. Each draft, final document, original, reproduction, and each signed and unsigned document and every additional copy of such document where such copy contains any commentary, note, notation or other change whatsoever that does not appear on the original or on the copy of the one document produced shall be deemed and considered to constitute a separate document. B. As used herein, the following words shall have the meanings indicated: (i) "Plaintiffs" in addition to the Plaintiffs named in the full style of this action, shall include any attorney, officer, director, employee or agent of EFTA00801999 Edwards adv. Epstein Case No.: 502009CA040800)ODONBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 3 of 12 Plaintiffs or any other persons acting under Plaintiffs' control or supervision, or in concert or association with Plaintiffs. "Defendant", in addition to the Defendant named in the full style of this action, shall include any attorney, officer, director, employee or agent of the Defendant or any other persons acting under Defendant's control or supervision, or in concert or association with the Defendant. "You" shall include the person (as defined below) or party to whom this Request is addressed and additionally all of his/her/its agents, officers, directors, employees, and other persons acting or purporting to act on his/her/its behalf, and includes also, to the extent there is no actual privilege, his/her/its attorneys. (iv) "Person" means any natural individual in any capacity whatsoever or any entity entity or organization, including divisions, departments, and other units herein, and shall include, but not be limited to, public or private a t. corporations, partnerships, joint ventures, voluntary or unincorporated associations, organizations, proprietorships, trusts, estates, governmental agencies, commissions, bureaus, or departments, and the agents, servants and employees of same. (v) "Concerning" includes referring to, responding to, relating to, connected with, regarding, discussing, analyzing, showing, describing, reflecting, employing and constituting. EFTA00802000 Edwards adv. Epstein Case No.: 502009CA0401300)OOaMBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 4 of 12 (vi) "Evidencing" means having a tendency to show, prove, or disprove. (vii) "Communication" means any oral or written statement, dialogue, colloquy, discussion or conversation, and also means any transfer of thoughts or ideas between persons by means of documents and includes any transfer of data from one location to another by electronic or similar means. (viii) "Including" shall mean including hut not limited to. (ix) The words "and" and "or" as used herein shall be construed either disjunctively or conjunctively as required by the context to bring within the scope of this production request any answer that might be deemed outside its scope by another construction. (x) "Related to" or "relating to" shall mean directly or indirectly, refer to, reflect, describe, pertain to, arise out of or in connection with, or in any way legally, logically, or factually be connected with the matter discussed. C. This Request calls for production of all responsive documents in your possession, custody or control without regard to physical location of said document. Control means in your possession, custody or control or under your direction, and includes in the possession, custody or control of those under the direction of you and your employees, subordinates, counsel, accountant, consultant, expert, parent or affiliated corporation, and any person purporting to act on your behalf. EFTA00802001 Edwards adv. Epstein Case No.: 502009CA040800)OOOCMBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 5 of 12 D. All documents shall be originals unless otherwise indicated. If your original is a photocopy or other copy, then the photocopy shall be produced as the original. E. Unless another time period is specified, this Request is addressed to documents created in the past five years from the date of this Request, and ending on the date of compliance with this Request. F. If you possess no documents responsive to a paragraph in this Request, state this fact, specifying the paragraph concerned. G. If you object in part to any Request, produce the portion of the documents requested to which you do not object, and state your objections to the remainder. H. As required by Florida Rule of Civil Procedure 1.280(b)(5), if you (including your attorneys and agents) arc withholding information otherwise discoverable under these rules by claiming that it is privileged or subject to protection as trial preparation material, you (including your attorneys and agents): ' (i) Shall make the claim expressly and shall describe the nature of the documents, communications, or things not produced or disclosed in a manner that, without revealing the information itself privileged or protected, will enable the party seeking discovery through this Request to assess the applicability of the privilege or protection. (ii) Provide a brief description of the document, including (a) the date of the document; (b) number of pages, attachments and appendices; (c) the names of its author, authors, preparers and an identification by employment and title of each EFTA00802002 Edwards adv. Epstein Case No.: 502009CA040800XMCvlBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 6 of 12 such person; (d) the name of each person who has sent, shown, or blind carbon copies of the documents, or has had access to or custody of the documents, together with an identification of each such person, and (e) in the case of any document relating or referring to a meeting or conversation, an identification of such meeting or conversation. -14 I. When appropriate, the singular form of a word should be interpreted in the plural as may be necessary to bring within the scope hereof any documents which might otherwise be construed to be outside the scope hereof. CONTINUING REQUEST This is a continuing request for the production of documents to the extent allowed by Florida Rule of Civil Procedure 1.280(c). At such time as you become aware of the existence of any additional documents responsive to this Request so that your response was not complete when made, you arc hereby requested to produce such documents promptly. DESTROYED DOCUMENTS If any documents responsive to this Request were at one time in existence, but have been lost or destroyed, a list should be provided of the documents so lost or destroyed stating the following information for each such document: (a) the type of document; (b) the date on which it ceased to exist, (c) the circumstances of its loss or destruction; (d) the identity of all persons having knowledge; and (e) the identity of all persons having knowledge of its contents. EFTA00802003 Edwards adv. Epstein Case No.: 502009CA040800)OOOGvIBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 7 of 12 MANNER OF PRODUCTION Pursuant to Rule 1.350, you should produce the original documents in the form, order and manner in which they are maintained in your files or the files of other persons under your control. In this connection, and for purposes of illustration, documents are to be produced in the file folder and file cartons in which they have been maintained or stored, clipped, stapled or otherwise arranged in the same form and manner as they were found. In the alternative, you should segregate all documents according to the specifications of this Request, and should organize and label each group of documents with the appropriate specifications prior to production. If any document is responsive to more than one specification of this Request, it should be labeled to reflect each specification to which it is responsive. `~ REQUESTS FOR PRODUCTION 1. Please produce all,Financial Statements prepared for or submitted to any Lender or Investor for the past five (5) years by you personally or on your behalf or on behalf of any entity in which you hold a controlling interest. 2. Please produce the W-2's and any other documents reflecting any income (including salary, bonuses, dividends, profit distributions, and any other form of income), including all gross and net revenue received by you directly or indirectly for the past five (5) years. 3. All tax returns filed with any taxing entity during the past five (5) years by you or on your behalf, or on behalf of any entity in which you hold or held a controlling interest at the time of filing. EFTA00802004 Edwards adv. Epstein Case No.: 502009CA040800,OOOCMBAGt Request to produce to Jeffrey Epstein (Punitive Damages) Page 8 of 12 4. All bank statements or other financial statements which were prepared by or received by you, or on your behalf or by or on behalf of any entity in which you had an ownership interest of 10% or more at any time during the past five (5) years. 5. All financial statements which were prepared by you or on your behalf, or by or on behalf of any entity in which you held an ownership interest of 10% or more at any time during the past five (5) years. 6. The deeds and titles to all real property owned by you or held on your behalf either directly or indirectly at any time during the past five (5) years. 7. All passbooks with respect to all savings accounts, checking accounts and savings and loan association share accounts owned by your or on which you hold a right or have a held a right to withdraw funds at any time during the past five years. 8. All passbooks with respect to all savings accounts, checking accounts and savings loan association share accounts, owned by you in whole or in part jointly as co-partner, or joint venture, in any business enterprise, or owned by an entity in which you have or have had a controlling interest at any time during the past 5 years. 9. The most recent bank ledger sheets in your possession, or accessible by you on the Internet, with respect to all bank accounts in which you have a right to withdraw funds. 10. The most recent bank ledger sheets in your possession, or accessible by you on the interest, with respect to all bank accounts owned by you solely, or jointly as co-partner, or joint venture, in any business enterprise, or owned by any entity in which you have a controlling interest. EFTA00802005 Edwards adv. Epstein Case No.: 502009CA040800X2OCXMBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 9 of 12 11. All checkbooks for all accounts on which you were authorized to withdraw funds for the past five (5) years. 12. All corporate securities (stocks or bonds) owned by you, directly or indirectly. 13. The latest available balance sheets and other financial statements with respect to any and all business enterprises of whatever nature in which you possess any ownership interest of 10% or more, whether as partner, joint venture, stockholder, or otherwise. 14. Your accounts receivable ledger or other company records which sets forth the names and addresses of all persons or business enterprises that are indebted to you and the amounts and terms of such indebtedness. ihe 15. Copies of the partnership or corporate income Tax Returns for any partnership or corporation in which you do possess or have possessed any ownership interest of 10% or more whether as partner, joint venture, stockholder or otherwise, for the last five (5) years. 16. The title certificates, registration certificates, bills of sale, and other evidences of ownership possessed by you or held for your beneficial interest with respect to any of the following described property owned by you or held directly or indirectly for your beneficial interest: a. Motor vehicles of any type; b. Commercial, business or construction equipment of any type; and c. Boats, launches, cruisers, planes, or other vessels of any type. 17. All records pertaining to the transfer of any money or property interests or financial interests made by you in the past 5 years. EFTA00802006 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 10 of 12 18. Any and all memoranda and/or bills evidencing the amount and terms of all of your current debts and obligations. 19. All records indicating any and all income and benefits received by you from any and all sources for the past 5 years. 20. Copies of any and all brokerage account statements or securities owned by you individually, jointly with any person or entity or as trustee, guardian or custodian, for the past 5 years, including in such records date of purchase and amounts paid for such securities, and certificates of any such securities. 21. All records pertaining to the acquisition, transfer and sale of all securities by you or on your behalf for the past 5 years, such records to include any and all information relative to gains or losses realized from transactions involving such securities. 22. All policies of insurance in which you or any entity controlled by you is the owner or beneficiary. 23. Copies of any and all trust agreements in which you are the settlor or beneficiary together with such documents necessary and sufficient to identify the nature and current value of the trust res. O EFTA00802007 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 11 of 12 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 Zi day of II ‘1114‘1", 20 / JAC. OLA Fl ar No.: 169440 P E-mail: ndary E-mail(s) Searcy Denney Scarola Barnhart & Shipley, PA. 2139 Palm Beach Lakes Boulevard West Palm Beach Florida 33409 Phon Fax: Attorney for gic .1 Edwards EFTA00802008 Edwards adv. Epstein Case No.: 502009CA0401100)OOCGIBAGr Request to produce to Jeffrey Epstein (Punitive Damages) Page 12 of 12 COUNSEL LIST Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm 3401 Phon Fax: Attorneys for Jeffrey Epstein Farmer, Jaffe, Weissing, Edwards, Fistos Lehrman, FL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, 33301 Phone: Fax: Attorneys for Jeffrey Epstein Fred Haddad, One Financial Plaza, Suite 2612 Fort Lauderdale. FL 33394 Phone. Fax: Attorneys for Jeffrey Epstein Marc S. Nurik, Esquire Lave Offices of Marc S. Nurik One B Broward Blvd., Suite 700 Fort Lauderdale. FL 3 301 Phone: Fax: Attorneys for Scott Rothstein Lilly Ann Sanchez, Esquire [email protected] The L-S Law Firm 1441 Brickell Avenue, 15th Floo Miami, Pho Fax: Attorneys for Jeffrey Ep Tonja Haddad, 315 SE 7th Street, Suite 301 P e cort Lauderdale FL 33301 ho /Fax: Attorneys for Jeffrey Epstein EFTA00802009 EXHIBIT C EFTA00802010 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003COC3CMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). NOTICE OF SERVICE OF INTERROGATORIES TO COUNTERDEFENDANT 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 day 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 D ber, 2012. ar No.: E-mail: econdary E-mail(s): Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm da 33409 Phone: Fax: ( Attorney for Bradley J. Edwards EFTA00802011 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800X3004:MBAG COUNSEL LIST Jack A. Goldber er Es uire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm 33401 Pho • Fax: Attorneys for Jeffrey Epstein Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, FL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Pho c: Fax: uire • Fred Haddad, P.A. One Financial Plaza, Suite 261 Fort La der e 394 Pho : Fax: IS7 4r Attorneys for Jeffrey Epstein • (s. 2 Marc S. Nurik. Esquire Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort La 301 SA' Ph • Fax: Attorneys for Scott Rothstein) Lilly Ann Sanchez, Esquire The L-S Law Firm, 1441 Brickell Avenue, 15th Floor Miami L 3131 Phone: Fax: Attorneys for Jeffrey Epstein oda Haddad Coleman Esquire Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: Fax: Attorneys for Jeffrey Epstein EFTA00802012 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800)OCXXMIBAO NET WORTH NTERROGATORIES TO JEFFREY EPSTEIN 1. 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; 2 EFTA00802013 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG (b) The date and cost of acquisition; (c) The current fair market value of each such interest; (d) The manner in which such Vie calculated. 5. As to each income tali 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: 3 EFTA00802014 EDWARDS ADV. EPSTEIN Case No.: 502009CA04080WOCXXMBAG (a) The address, (b) The legal description of the property; (c) The assessed value of the property for tax purposes; (d) The date and price of acquisition; Whether, when, by whom, why and at what amount the property has been raised since the time of purchase; (f) Whether, when, and at what price the property has been offered for sale since the time of purchase; 4 EFTA00802015 EDWARDS ADV. EPSTEIN Case No.: 502009CA0408003OOOCMBAG (g) has been listed for sale since the time of purchase; The name and address of each real estate agent with whom the property CP (h) The cost of any improvements made to the property since purchase; 4, (i) The nature of your interest in the property. .ZCt (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; 5 EFTA00802016 EDWARDS ADV. EPSTETN Case No.: 502009CA0408003OOCXMBAG (b) The cost of acquisition; (c) 44" The current estimated fair market value; (d) The manner in which the feta value was estimated. 8. i&pet44)4" If any of the real ot onal 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: 6 EFTA00802017 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800)OOOO4BAG (a) The name and address of the business; (b) (c) 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; Li 49 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. 7 EFTA00802018 EDWARDS ADV. EPSTEIN Case No.: 502009CA0408003OOM113AG 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 (.111/4 The current estimated fair market value; CAS 7t. s- Gv • (c) (d) The means utilized to estimate the current fair market value. 8 EFTA00802019 EDWARDS ADV. EPSTEIN Case No.: 502004CA040800)COC<MBAG 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; 'SY (b) The amount of the liability at inceptiN Sc ‘ '- (c) The terms of repayment or satisfaction; Cl I‘ it'.1. ilir (d) The current outstanding balance. 9 O4z- EFTA00802020 EDWARDS ADV. EPSTEIN 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 Lie) (c) the reason for performing the calculation date; A ti: Nrd (d) the amount of net worth calculated or ated 14. What is your present net 15. As to all transfers of anythig 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); 10 EFTA00802021 EDWARDS ADV. EPSTEIN Case No.: 502009CA0408003OOOCMBAG (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; (f) the name and address of the recipient of each transferred item IA - IL 7 STATE OF COUNTY OF sic The foregoing instrument was acknowledged before me this day of , 20_, by(bit r who is personally known to me or who has produced as identification and who did did/ not take an oath. (SEAL) 4 O (Notary signature) (Notary name - print) NOTARY PUBLIC, State of Florida (Serial number, if any) 11 EFTA00802022 EXHIBIT D EFTA00802023 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually Defendant(s). REQUEST FOR ADMISSIONS TO JEFFREY EPSTEIN COMES NOW the Counter-Plaintiff, Bradley J. Edwards, by and through his undersigned counsel and propounds the following Request for Admissions pursuant to Rule 1.370 Florida Rules of Civil Procedure, requesting that Counter-Defendant, Jeffrey Epstein, admit the truth of the facts set forth as follows: 1. Admit that you have publicly been described as a billionaire. 2. Admit that press reports have described you as a billionaire. 3. Admit that you have never publicly disputed the description of you as a billionaire. 4. Admit that you have never publicly disputed any press reports describing you as a billionaire. 5. Admit that you are a billionaire. 6. Admit that you have been a billionaire sometime within the past 5 years. 7. Admit that you have been a billionaire sometime within the past 10 years. EFTA00802024 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Request for Admissions to Jeffrey Epstein 8. Admit that you have a reputation as being a billionaire. 9. Admit that your personal net worth has exceeded a billion dollars at times during the past 5 years. 10. Admit that your personal net worth has exceeded half a billion dollars at times during the past 5 years. 11. Admit that your personal net worth has exceeded a quarter of a billion dollars at times during the past 5 years. 12. Admit that you have never paid even one penny in punitive damages to any person who has alleged that you engaged in improper sexual conduct with them while that person was a minor. 13. Admit that you have never spent even one day in a state or federal prison facility (as opposed to a county jail) as punishment for any sex-related crime. Pursuant to the Rules of Civil Procedure, each fact on which admission is requested shall be deemed admitted if not denied or if no reply is received on or before March 28, 2013. 2 EFTA00802025 Edwards adv. Epstein Case No.: 502009CA0408003OOCXMBAG Request for Admissions to Jeffrey Epstein 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 day of February, 2013. Jack Sc Flori No.: 169440 Pr' E-mail: S dary E-mail(s): y Denney Scarola Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard West Palm Beach. Florida 33409 Phone: Fax: Attorneys for Bradley J. Edwards 3 EFTA00802026 Edwards adv. Epstein Case No.: 502009CA040800XJCXXMBAG Request for Admissions to Jeffrey Epstein COUNSEL LIST Jack A. Goldberger Es uire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: Fax: Attorneys for Jeffrey Epstein Braille J. Edwards Es uire staff. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, FL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: Fax: Fred Haddad Es uire MSS Fred Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: Fax: Attorneys for Jeffrey Epstein 4 Marc li i iti Es uire Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale FL 33301 Phone: Fax: Attorneys for Scott Rothstein Lill Ann Sanchez, E • uire The L-S Law Firm 1441 Brickell Avenue, 15th Floor Miami, FL 33131 Phone: Fax: Attorneys for Jeffrey Epstein Tonja Haddad Coleman, Esquire ton" on'a sagiac, 0 Wd.cony Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: Fax: Attorneys for Jeffrey Epstein EFTA00802027 EXHIBIT E EFTA00802028 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACE. COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, v. CIVIL DIVISION CASE NO. 502009CA040800)OOOCMBAG Judge David F. Crow SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF EPSTEIN'S RESPONSE TO DEFENDANT EDWARDS' REOUEST TO PRODUCE 0 I VI f. Ca) Plaintiff/Counter-Defendant, Jeffrey Epstein, by and through his undersigned counsel and pursuant to the Florida Rules of Civil Proced lei this his Response to Request to Produce served on April 15, 2011 and states as fol la. Plaintiff does not have any documents between Plaintiff or his agents and William Scherer or any person associated with William Scherer relating to any allegation of illegal activity or tortious conduct in which Epstein is alleged to have engaged; lb. Plaintiff objects to the request for documents by and between the Plaintiff or his agents and any prosecuting agency, law enforcement and/or government entity relating directly or indirectly to the allegation of illegal activity or tortious conduct in which Epstein is alleged to have engaged. The request is overbroad. The request seeks information that is irrelevant to the issues in this case. It seeks information that may infringe upon the Plaintiffs constitutional rights under the Fifth, Sixth, and Fourteenth Amendment. Further, in Jane Doe,No. 2 v. Epstein Case Number 90:08-CV-80893 (D.E. 226), the Court entered an order stating that these documents are confidential and a preliminary ruling FOWLER WHITE BURNETT PA• 901 PHILLIPS POINT WEST, 771 SOUTH FLAGLER Dave, WEST PALM BEACH, FLORIDA 23401 • (561) 802-9041 EFTA00802029 Epstein v Rothstein, Edwards, etc CASE NO. 502009CA040800XXXXMBAG Plaintiff Epstein's Response to Defendant Edwards' Request to Produce must be made before they are available for use in this proceeding. Counsel for Epstein in the criminal proceedings, have asserted objections to these records in Doe v. Epstein, above, which Epstein adopts herein. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing been furnished by U.S. Mail this f day of May, 2011 to: Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 Jack A. Goldberger, Esq. Atterbtry Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Respectfully submitted, eph L. Ackerman, Jr. Fla. Bar No. 235954 Email: FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 Soula Flagler Drive West Palm Beach Florida 33401 Telephone: Facsimile: - 2 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 EFTA00802030 EXHIBIT F EFTA00802031 Electronically Filed 07/10/2013 11:29:18 AM ET JEFFREY EPSTEIN, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN Plaintiff, AND FOR PALM BEACH COUNTY, FLORIDA vs. SCOTT ROTHSTEIN, individually, CASE NO.502009CA040800XXXXMBAG BRADLEY J, EDWARDS, Individually, and L.M., individually. Defendants. 0 / co Plaintiff Jeffrey Epstein, by and through his undersigned ounsel and pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, hereby certifies that the original amended JEFFREY EPSTEIN'S NOTICE OF SERVING UNVERIFIED AMENDED ANSWERS TO DEFENDANT BRADLEY EDWARDS'S INTERROGATORIES answers to Defendant's Interrogatories was served upon Defendant via electronic service this July 10, 2013. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TOUR HADDAD, PA 315 SE 7" Street Suite 301 Fort Lauderdale, Florida 33301 facsimile EFTA00802032 JEFFREY EPSTEIN, Plaintiff, VS. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA SCOTT ROTHSTEIN, individually, CASE NO.502009CA040800XXXXMBAG BRADLEY J, EDWARDS, Individually, and L.M., individually. Defendants. JEFFREY EPSTEIN'S NOTICE OF SERVING UNVERIFIED AMENDED ANSWERS TO DEFENDANT BRADLEY EDWARDS'S INTERROGATORIES Plaintiff Jeffrey Epstein, by and through his undersigned counsel and pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, hereby certifies that the original amended answers to Defendant's Interrogatories was served upon Defendant via electronic service this July 10, 2013. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 facsimile EFTA00802033 JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: CROW PLAINTIFF/COUNTER-DEFENDANT EPSTEIN'S AMENDED RESPONSES TO NET WORTH INTERROGATORIES TO JEFFREY EPSTEIN Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein'), by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure hereby files his amended responses to Defendant/Counter-Plaintiff Bradley Edward's Net Worth Interrogatories to Jeffrey Epstein: 1. What is your full name? ANSWER: Jeffrey Edward Epstein 2. How are you currently employed? ANSWER: Self-employed and Philanthropist. 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 3 years including bonuses, allowances, pension and profit sharing participations, stock options, deferred compensation, insurance benefits and other prerequisites of your employment including dollar amount or dollar value of each. Answer: Objection. This Interrogatory requires the provision of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). 1 have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffinan v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. EFTA00802034 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; 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. Answer: Objection. This Interrogatory requires the provision of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 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. Answer: Objection. This Interrogatory requires the provision of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). 1 have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffinan v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 6. For each parcel of real property in which you hold any interest: state: a. The address; b. The legal description of the property; c. The assecced value of the property for tax purposes; d. The date and price of acquisition; 2 EFTA00802035 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; 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 mariner in which that value was calculated. Answer: Objection. This Interrogatory requires the provision of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). 1 cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 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; b. The cost of acquisition; c. The current estimated fair market value; d. The manner in which the fair market value was estimated. Answer: Objection. This Interrogatory requires the provision of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, 3 EFTA00802036 Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 8. If any of the real or personal property owned by you, either individually, jointly or otherwise, is encumbered by a real estate mortgage, chattel mortgage, or any other type of lien, then for each 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. Answer: Objection. This Interrogatory requires the provision of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 9. If you have an ownership interest in any businesses, for each business state: 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 fair market value was calculated. Answer Objection. This Interrogatory requires the provision of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 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. Answer: Objection. This Interrogatory requires the provision of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 4 EFTA00802037 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. II. Identify all other assets of a value in access 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. Answer: Objection. This Interrogatory requires the provision of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 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 arise; b. The amount of the liability at inception; c. The terms of repayment or satisfaction; d. The current outstanding balance. Answer: Objection. This Interrogatory requires the provision of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). 1 cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, 5 EFTA00802038 Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 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. Answer: Objection. This Interrogatory requires the provision of detailed financial information which communicates statements of fact. Fisher v. United States, 425 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). 1 cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 14. What is your present net worth? Answer: I have already indicated my willingness to stipulate to a net worth in excess of one hundred million dollars. 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; a. The value of the item(s) transferred at the time of transfer; d. The date and cost of your acquisition of the item(s); 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; f. The name and address of the recipient of each transferred item. 6 EFTA00802039 Answer: Objection. This Interrogatory requires the provision of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. [THIS PORTION INTENTIONALLY LEFT BLANK] 7 EFTA00802040 EXHIBIT G EFTA00802041 JEFFREY EPSTEIN, Plaintiff, vs. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA SCOTT ROTHSTEIN, individually, CASE NO.: 502009CA040800XXXXMBAG and BRADLEY I. EDWARDS, individually. JUDGE: CROW Defendants. PLAINTIFF/COUNTER-DEFENDANT EPSTEIN'S AMENDED RESPONSES TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S REQUEST FOR PRODUCTION TO COUNTER-DEFENDANT (PUNITIVE DAMAGES) Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby files this amended response to Defendant/Counter-Plaintiff Bradley Edward's Request for Production to Counter-Defendant (Punitive Damages), and answers as follows: I. Please produce all Financial Statements prepared for or submitted to any Lender or Investor for the past five (5) years by you personally or on your behalf or on behalf of any entity in which you hold a controlling interest. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "'Mlle act of production itself may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000).1 have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 2. Please produce the W-2's and any other documents reflecting any income (including salary, bonuses, profit distributions, and any other form of income), including all gross and net revenue received by you directly or indirectly for the past five (5) years. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher EFTA00802042 v. United States, 425 U.S. 391, 410 (1976). "'[T]he act of production itself may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United Slates, 341 U.S. 479, 486 (1951). 1 cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 3. All tax returns filed with any taxing entity during the past five (5) years by you or on your behalf, or on behalf of any entity in which you hold or held a controlling interest at the time of filing. ANSWER: Copies of my personal Individual Income Tax Returns on Form 1040 for the years 2010 and 2011 were provided with our prior response. 4. All bank statements or other financial statements which were prepared by or received by you, or on your behalf or by or on behalf of any entity in which you had an ownership interest of 10% or more at any time during the past five (5) years. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "'Mite act of production itself may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 5. All financial statements which were prepared by you or on your behalf, or by or on behalf of any entity in which you held an ownership interest of 10% or more at any time during the past five (5) years. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed fmancial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "Thhe act of production itself may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to 2 EFTA00802043 questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 6. The deeds and titles to all real property owned by you or held on your behalf either directly or indirectly at any time during the past five (5) years. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). I"[TJhe act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffinan v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 7. All passbooks with respect to savings accounts, checking accounts and savings and loan association share accounts owned by you or on which you hold a right or have a held a right to withdraw funds at any time during the past five years. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "`[Tlhe act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 8. All passbooks with respect to all savings accounts, checking accounts and savings loan association share accounts, owned by you in whole or in part jointly as co-partner, or joint venture, in any business enterprise, or owned by an entity in which you have or have had a controlling interest at any time during the past 5 years. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). mfTjhe act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). 1 have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth 3 EFTA00802044 and Fourteenth Amendment rights as guaranteed by the United States Constitution. 9. The most recent bank ledger sheets in your possession, or accessible by you on the intemet, with respect to all bank accounts in which you have a right to withdraw funds. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "[T]he act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffinan v. United States, 341 U.S. 479, 486 (1951).1 cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 10. The most recent bank ledger sheets in your possession, or accessible by you on the intemet, with respect to all bank accounts owned by you solely, or jointly as co-partner, or joint venture, in any business enterprise, or owned by any entity to which you have a controlling interest. ANSWER: Objection. This Request for Production requires the identi cation of the existence of detailed financial information which communicates statements f fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "' [T]he act of production itself' ay implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that arc testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 11. All checkbooks for all accounts on which you were authorized to withdraw funds in the past five (5) years. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). ""[T]he act of production itself' may implicitly communicate "statements of fact" that arc testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth 4 EFTA00802045 and Fourteenth Amendment rights as guaranteed by the United States Constitution. 12. All corporate securities (stocks or bonds) owned by you, directly or indirectly. ANSWER: This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "Thhe act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 13. The latest available balance sheets and other financial statements with respect to any and all business enterprises of whatever nature in which you possess any ownership interest of 10% or more, whether as partner, joint venture, stockholder, or otherwise. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "[The act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 14. Your accounts receivable ledger or other company records which sets forth the names and addresses of all persons or business enterprises that are indebted to you and the amounts and terms of such indebtedness. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "'Mlle act of production itself may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 5 EFTA00802046 15. Copies of the partnership or corporate Income Tax Returns for any partnership or corporation in which you do possess or have possessed any ownership interest of 10% or more whether as partner, joint venture, stockholder or otherwise, for the last five (5) years. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "‘ [The act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my fmancial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 16. The title certificates, registration certificates, bills of sale, and other evidences of ownership possessed by you or held for your beneficial interest with respect to any of the following described property owned by you or held directly or indirectly for your beneficial interest: a. Motor vehicles of any type; b. Commercial, business or construction equipment of any type; and c. Boats, launches, cruisers, planes, or other vessels of any type. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). ".[T]he act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that thcsc statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Ho fan v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 17. All records pertaining to the transfer of any money or property interests or financial interests made by you in the past 5 years. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "IT]he act of production itself may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See 6 EFTA00802047 Hoffman v. United States, 341 U.S. 479, 486 (1951). 1 cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 18. Any and all memoranda and/or bills evidencing the amount and terms of all of your current debts and obligations. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "'[T]he act of production itself may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 19. All records indicating any and all income and benefits received by you from any and all sources for the past 5 years. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "'[T]he act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 20. Copies of any and all brokerage account statements or securities owned by you individually, jointly with any person or entity or as trustee, guardian or custodian, for the past 5 years, including in such records date of purchase and amounts paid for such securities, and certificates of any such securities. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "'[T]he act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to 7 EFTA00802048 questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 21. All records pertaining to the acquisition, transfer and sale of all securities by you or on your behalf for the past 5 years, such records to include any and all information relative to gains or losses realized from transactions involving such securities. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "IT]he act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 22. All policies of insurance in which you or any entity controlled by you is the owner or beneficiary. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "'Mho act of production itself may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951).1 cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 23. Copies of any and all trust agreements in which you are the senior or beneficiary together with such documents necessary and sufficient to identify the nature and current value of the trust res. ANSWER: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "c[T]he act of production itself may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See 8 EFTA00802049 Hoffman v. United States, 341 U.S. 479, 486 (1951). 1 cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. WE IIEREBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this July 9, 2013. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 facsimile 9 EFTA00802050 Electronic Service List Jack Scarola, Esq. Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Esq. 1 Financial Plaza Suite 2612 Fort Lauderdal FL 33301 10 EFTA00802051 EXHIBIT H EFTA00802052 JEFFREY EPSTEIN, Plaintiff, vs. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA SCOTT ROTHSTEIN, individually, CASE NO.: 502009CA040800XXXXMBAG and BRADLEY J. EDWARDS, individually. JUDGE: CROW Defendants. PLAINTIFF/COUNTER-DEFENDANT EPSTEIN'S RESPONSES TO DEFENDANT/COUNTER-PLAINTIFF'S REQUESTS FOR ADMISSIONS Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure hereby files his responses to Defendant/Counter-Plaintiff Bradley Edward's Requests for Admissions to Jeffrey Epstein as follows: 1. Admitted. 2. Admitted. 3. Objection. This Request for Admission requires a response which communicates statements of fact. Fisher v. United Stales, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. EFTA00802053 4. Objection. This Request for Admission requires a response which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 5. Objection. This Request for Admission requires a response which communicates statements of fact. Fisher v. United Slates, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hqffman v. United Stales, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 6. Objection. This Request for Admission requires a response which communicates statements of fact. Fisher v. United Stales, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United Stales. 341 U.S. 479, 486 (1951). I cannot provide answers/responscs to questions relating to my financial history 2 EFTA00802054 and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 7. Objection. This Request for Admission requires a response which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffinan v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 8. Objection. This Request for Admission requires a response which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 9. Objection. This Request for Admission requires a response which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 3 EFTA00802055 (1951). 1 cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 10. Objection. This Request for Admission requires a response which communicates statements of fact. Fisher v. United Slates, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 11. Objection. This Request for Admission requires a response which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). 1 have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 12. Objection. This Request for Admission requires a response which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to 4 EFTA00802056 prosecute me in criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). 1 cannot provide answers/responses to questions relating to my financial information without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. 13. I admit that I was sentenced by a State Court Judge to the Palm Beach County Jail for the charges to which I plead. WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon Jack Scarola, Esq., and Bradley J. Edwards, Esq., via Electronic Service, this March 27, 2013. Tonja Haddad Coleman, Esq. , Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 facsimile 5 EFTA00802057 EXHIBIT I EFTA00802058 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY CIVIL DIVISION JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, etc., et al., Defendant(s). CASE NO.: 502009CA0408005OOaMBAG ' ar ORDER ON COUNTER-PLAINTIFF BRADLEY ED S' MOTION TO DETERMINE STATUS OF PUNITIVE DA AND APPLICABILITY OF ADVERSE INP CE THIS CAUSE came before the Court u unter-Plaintiff, BRADLEY era C) C-sr GEDISCOVERY. EDWARDS' Motion to Determine Status of Pun' age Discovery. The Court beard argument of counsel, has reviewed the s d is otherwise fully advised in the premises. At hearing, counsel for ED D dvised the Court that certain "net worth" discovery in regard to the puniti tI e count against EPSTEIN had been objected to on the basis of the constitut* ege against self-incrimination. All other objections to such discovery had been mwn. As such, EDWARDS now seeks a ruling from the Court in regard to an rse inference (presumption) jury instruction and evidence preclusion at e of trial. Based upon the foregoing, it is ! SIDERED, ORDERED A140.ADJUDGED as follows: To the extent that the issue of amount of punitive damages is submitted to the jury at the bifurcated trial of this matter, the Court rules as follows: 1. The Counter-Plaintiff EDWARDS' request for jury instruction adverse inference instruction is deferred until the time of trial. At the time of trial, upon specific analysis of the specific question and answers, including those propounded in disdovery, obeilin ..f the Court will determine whether an adverse ihatruction will, or will not, be given and the EFTA00802059 Epstein a Rothstein Case No. 502009CA04080O,O00CM73AG Order Page 2 specific instruction, if any, that will be given. trial to propose such jury instructions. Counsel for the parties shall be prepared at I 1 2. The Motion to Preclude Evidence is also deferred until the " efitt al. At time ‘,.. . the of trial, this Court will determine whether certain testimony y cuments c i will be precluded based upon non-compliance with this Court's Ten i• der and/or a Binger analysis conducted by the Court at the time of trial. ) 3. Nothing in this Order shall be construe/in d of itself as precluding the use of any answers submitted by EPSTEIN &gin discovery at trial if they are otherwise admissible. DONE AND ORDERED this • • Palm Beach County, Florida. Copy furnished: See attached list. Cosies 'V. 013 at • - 'ahn Beach, DAVID F. CROW CIRCUIT COURT JUDGE • .crzt 4. EFTA00802060 Edwards adv. Epstein Case No.: 59200KA040800XXXXMBAC COUNSEL LIST • Jack Scarola Esquire Searcy Denney Scarola Barnhart & Shipley PA 2139 Palm Beach Lakes Boulevard West Palm Beach FL 33409. Phone: Fax: Attorneys for Bradley J. Edwards William Chester Brewer, Esquire 250 S Australian Avenue, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-655-4777 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Jack A. Goldberger, Esquire smahon Atterbury, Goldberger & Weiss 250 Australian Avenue Sou West Palm Beach FL 33401 Pho Fax: Attorneys for Jeff ey E Bradley J. CAM Farmer, .e issing, Edwards, Fistos & Lehman, FL 425-1,111T)AJidrews Avenue, Suite 2 Fort Liuderdale FL 33301 Phone: Fax: Fred Haddad, Esquire Fred Haddad, P.A. One Financial Plaza, Suite 2612 2 EFTA00802061 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG . . Fort Lauderdale, FL 33394 Phone: Fax: Attorneys for Jeffrey Epstein Marc S..Nurik, Esquire Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale FL 33301 Phone: Fax: Attorneys for Scott Rothstein Tonja Haddad Coleman, Esquire , onja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale FL 33301 Phone: Fax: Attorneys for Jeffrey Epstein EFTA00802062 EXHIBIT J EFTA00802063 hrg091613epstein.txt 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 2 IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009C4040800Xxxxms4G 3 4 5 JEFFREY EPSTEIN, 6 7 plaintiff, -vs- 8 SCOTT ROTHSTEIN, individually, 9 BRADLEY J. EDWARDS, individually, and L.M, individually, 10 11 Defendants. 12 .4, \1/4 13 HEARING HELDABfFORE, THE HONORABLE DAVICS.CROW 14 4%. t'4\- , 15 \"tv 16 monsiay, September 16, 2013 17 140- p.m. - 4:05 p.m. 18 19 20 \,"7.7 205 North Dixie Highway West Palm Beach, FL 33401 21 22 Tctir- Reported By: Pamela Pittman Gunn, FPR 25 Notary public, State of Florida 2 1 APPEARANCES: 2 on behalf of the Plaintiff: Page 1 EFTA00802064 hrg091613epstein.txt 3 TONJA HADDAD COLEMAN, ESQ. TONJA HADDAD, P.A. 4 315 SE 7th street, Suite 301 Fort L 33301 5 6 7 On behalf of the Defendant Bradley J. Edwards: 9 SEARCY, SCAROLA DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 8 JACK , ESQ. 11 12 C O AS 2139 Palm Beach Lakes Blvd. 10 west Pa 33409 13 1 • 14 5 4 4 .4" 16 17 18 19 20 21 22 Cot 7 23 lid::! 3 24 25 PROCEEDINGS - - 3 Hearing taken before Pamela Pittman Gunn, Court 4 Reporter and Notary Public in and for the State of 5 Florida at Large, in the above cause. 6 Page 2 EFTA00802065 hrg091613epstein.txt 7 THE COURT: Okay, this is the Epstein 8 versus Rothstein case. It's the plaintiff -- 9 excuse me, counter plaintiff's motion to 10 determine entitlement to adverse inferences and 11 also prohibit the induction of evidence. 12 read the response. I read the motion and 13 response. Counsel just hand delivered 14 something to me today that evidentially I have 15 never seen before. It was a supplemental 16 memorandum I received. 17 MS. COLEMAN: Your Honor, Mr. Scaro 18 filed it at 10:30 this morning. 19 a chance to review it. I was 20 another matter. I haven't it either. 21 THE COURT: Let me q stion before 22 we begin so I get my ive back again. I 23 entered an order sOmer~im ago in this case and 24 I guess deali ome of the privileged 25 objections 1 recall that? 1 2 7 8 9 10 11 :,) 1!! Or COLEMAN: Yes. HE COURT: And 1 think i asked for some nd of privilege log. Is there anything I'm supposed be doing or is that on appeal? MR. SCAROLA: I believe there are outstanding privileges as you said, Your Honor, that is still not yet determined. THE COURT: okay, because I didn't know that. I thought I was waiting for something from you guys. MR. SCAROLA: I don't think so. Page 3 't had 4 EFTA00802066 hr9091613epstein.txt 12 THE COURT: I'm going to have to have a 13 status conference and figure everything because 14 I went back and looked at it and something's 15 wrong. Okay. Good enough. 16 MR. SCAROLA: To put that in context, Your 17 Honor. 18 THE COURT: what is that, ma'am? 19 MS. COLEMAN: I'm sorry? 20 THE COURT: what did you say? 21 22 MS. COLEMAN: Nothing, Judge. I waC s o l 23 speaking -- 1 was just coming up At yar of it. 24 THE COURT: Go ahead. 25 MR. SCAROLA: vour r recall that 5 1 there have been lti privileges asserted 2 with regard ety of issues. And we 3 have ovepe.t rse of these proceedings been 4 attemp g 5p narrow valid privileged S a ertions and distinguish them from invalid 6 pri ged assertions. That primarily means 7 that while we have acknowledged that r. Epstein has a valid Fifth Amendment 4-3 privilege because he does clearly remain in jeopardy with regard to the underlying criminal activity that resulted in both a state 12 prosecution and a Federal non-prosecution 13 agreement. 14 we believe that other privileges were 15 invalid. And the practical implications of Page 4 EFTA00802067 5 6 7 8 9 10 11 12 16 17 18 19 20 hrg091613epstein.txt 16 making that distinction are that we cannot draw 17 an adverse inference from the assertion of, for 18 example, an attorney/client privilege. But we 19 are under the case law clearly permitted to 20 draw an adverse inference from the assertion 21 of the Fifth Amendment, the right to remain 22 silent. 23 so we need to eliminate the invalid 24 assertion, assertions of privilege from our 25 perspective. Leave in place the valid 1 assertion of privilege, which 2 to draw an adverse from th 3 privilege. Your Honor 4 some of those challe That's by way of question. It_d have today's mo Be aus C e ay's motion those c Am/stances where the only privilege as by Mr. Epstein is a Fifth Amendment pri lege, his right to remain silent pursuant Ac , e its us ssertions of eF consideration ileged assertions. to Your Honor's anything to do with relates only to the Fifth, Sixth and Fourteenth Amendments of the uS Constitution that have been repeatedly asserted by him throughout the discovery in this case and in response to request to production and in response to interrogatories. And dozens and dozens and dozens of times in response to questions posed during the course of his deposition. what we are seeking today, by way of what Page 5 6 EFTA00802068 hrg091613epstein.txt 21 really is a motion in limine is, in fact, a 22 determination that where the only privilege 23 asserted by mr. Epstein is, the only valid 24 privilege asserted by Mr. Epstein, is a Fifth 25 Amendment privilege assertion. That we are 1 2 3 entitled to a jury instruction that will info S the jury that the assertion of that privi allows them to draw an adverse inference That 4 is that had an answer been given, t answers 5 would be unfavorable to Mr. Eps n. have 6 not laid out the precise wor n at jury 7 y at this 8 point. ing for a 9 confirmation of th asi rincipal. 10 The second t o this motion is that as 11 to those mat four years that, almost four 0 which mr. Epstein has 12 over thec 13 years t th t is case has been prosecuted, 14 co istently asserted a Fifth Amendment 15 pri je. me is not going to be able to get 16 up t 17 is position and suddenly begin testifying about matters in which he has consistently refused to provide information in pretrial discovery. 21 So those are two parts. That's what we're 22 asking for. we don't want to be surprised by 23 Mr. Epstein coming and attempting to take the 24 witness stand and to give testimony that he has Page 6 instruction But we are si during the course of trial and change EFTA00802069 hrg091613epstein.txt 25 consistently withheld. 8 1 THE COURT: Is this matter set for trial? 2 MR. SCAROLA: we are set for trial, yes, 3 sir. we're getting to the point now where 4 THE CouRT: when is it set? 1 18 for the trial commencing ik:S‘S; 5 ms. COLEMAN: we're on calendar call, 6 Judge, October 7 October 28th. 8 THE COURT: Yeah, that sounds right 9 okay. 10 MR. SCAROLA: Now the pri sponse 11 that we have gotten to thi t is that the 12 Baxter (phonetics) case h e have cited in 13 support of our posi case that arose in 14 a context where a i vidual took the witness 15 stand and asse s Fifth Amendment 16 privilege h esence of the jury. 17 A tention in the 18 counte f ndant's response is we would be 19 re to call Mr. Epstein to the witness 20 sta . He would be obliged to assert his Fifth 21 mendment privilege in the presence of the jury before we would be entitled to any adverse implication instruction. That simply is wrong. And it's wrong because Rule 1.330(a) renders 25 that distinction meaningless. Rule 1.330(a) is 1 2 the rule of civil procedure that talks about the use of depositions at trial. And it Page 7 9 EFTA00802070 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 hrg091613epstein.txt provides expressly that at trial a deposition may be used, in this case, against an opposing party as though the witness were then present and testified. So we already have the basis upon which to draw the adverse inference. xt isn't necessary that either we or Mr. Epstein -- call Mr. Epstein to the witness stand and have him repeat what he has already consistently sa' and that is that he refuses to answer th e : i questions. so the distinction that attempt to draw that this is pro premature because he has not the stand in front of the jury red moot by virtue of Florida Rule vi Procedure which requires that s sition testimony be treated in the sae ma r as trial testimony would be. Honor. THECOT. Okay. res. MS. COLEMAN: Good afternoon, Judge. To ically our position, your add the issues with which Mr. Scarola has disc ssed I would point out the following to 10 the Court. First, this motion is premature at best for several reasons. First of which is 3 Mr. Epstein is now set for deposition by 4 counter plaintiff on october 21st and x presume 5 will be asked further questions to which he may 6 or may not assert the Fifth Amendment. So to Page 8 EFTA00802071 hrg091613epstein.txt 7 preemptively presume that he will assert it or 8 not assert it and make a ruling based on an 9 adverse inference on something that hasn't yet 10 happened is inapplicable. 11 Second, Judge, with respect to discovery 12 that has gone on in this case over the past 13 four years there are many, many, many questions 14 sadly which are not spelled out in the bulk of 15 this motion. Questions that have been posed 16 Mr. Epstein that irrefutably have absolu 17 nothing to do with this case. All that i 18 evident from everything that has bled in 19 this case, that the parties, t 20 plaintiff, would like to r e the cases 21 that were being prosecu h m against 22 Mr. Epstein several This is a 23 simple abuse of pr nd malicious 24 prosecution ca e. So with respect to 25 the negati erse inference to which CI) 1 co laintiff may or may not be entitled, 2 this .court needs to conduct a far more detailed alysis into those questions and answers other than the blanket assertion made by this motion. Judge, for example, to be entitled to a negative inference, the party seeking it must 7 prove that the information cannot be benefited 8 or received from obtaining -- I'm sorry, let me 9 start that sentence over. The inference may 10 not be drawn unless there's a substantial need 11 for the information and there is not another Page 9 11 EFTA00802072 hrg091613epstein.txt 12 less burdensome way of obtaining that 13 information. That's the first step. And I 14 appreciate this is not fully -- this is like I 15 received their memo this morning and I was 16 under the misguided conception we were arguing 17 the two cases he cited but I will lay this out 18 for the court anyway since we're here. The Court has discretion -- 19 20 MR. SCAROLA: I don't mean to interr 21 but that's all I have argued. I have no 22 argued the supplemental memo at all 23 MS. COLEMAN: The rule to 't 24 referred is not cited in his fil th 25 respect to the use of the`~ 'y on. But what 1 this court has o b ore it can determine -- 2 THE COO : me ask a basic question. 3 ms. Yes, you can. 4 TM : There is bunch of cases where 5 so eone has waived Fifth Amendment and it 6 hap all the time in DUI cases and then in 7 jcivi lawsuits. I've never had anybody ask me spoliation case. what they do is they ask the question, the person denies it or -- excuse me, or an actual jury instruction like you do in a they take the Fifth Amendment. And says 12 weren't you drunk on the night of the accident, 13 and they answer I refuse on the basis of 14 incrimination. Then they argue to the jury, he 15 admitted it and -- Page 10 12 EFTA00802073 hrg091613epstein.txt 16 ms. COLEMAN: That's exactly my point, 17 Judge. 18 THE COURT: I've never seen a case where 19 it says you're entitled to an actual 20 instruction. In the cases you cited, the two 21 cases cited, at least I didn't see that in the 22 case you cited. Is there actually a case in 23 Florida where if you take the Fifth Amendment, 24 you're entitled to an adverse inference 25 instruction like a spoliation case where 1 2 3 4 5 6 7 8 9 10 11 12 16 17 13 there's specific instruction a Cv y the Fourth District? MS. COLEMAN: It's, A0.oiYon, Judge, but -- THE COURT: see anything like that. mS. C No, I didn't see anything C either t ag my understanding is, as I said, a -thl cases to which counter plaintiff re clearly states that the witness is avai ble, he's coming. He's listed on both tness lists. He's the defendant. He'll be here. He'll be testifying. In every case that I've read, state and Federal, indicates that it occurs at trial. we don't know what questions are going to be asked. we don't know what's going to happen. 18 THE COURT: The jury can draw an adverse 19 inference since nobody is pleading the Fifth 20 Amendment and -- Page 11 EFTA00802074 hrg091613epstein.txt 21 MS. COLEMAN: Only if you base your 22 findings on a particular set of information 23 delineated. For example, should Mr. Epstein 24 I'm hypothetically speaking -- take the stand 2S and answer a question to which he's previously 4 1 asserted the Fifth, you can strike that answe 2 And then, and only then, would the issue o iglie 3 negative inference become applicable. A thi 4 point we respectfully feel the plai ' f s 5 the cart before the horse becau not at 6 trial. I don't think even M la can 7 determine what evidence i o come out at 8 trial. I've never se a 7y7 instruction 9 drafted before dis 10 He's taken Mr. A 11 THE CO 12 sorry to t you. I've never given a 13 written neji the context of the Fifth 14 Am ndment. It's always been in the context of 15 di ry violations or failure to comply with 16 dis overy requests or spoliation issues. And 0 17 '!hen we drafted instructions under -- I can't remember the name of the case. ry" even finished. deposition. time I have ever done -- MS. COLEMAN: It's Rule 1.380. THE COURT: Actually, a case where you 21 approve a specific, it's not a presumption, 22 it's an inference. YOU give the presumption 23 it's irrelevant, not to say stupid, something 24 like that. I'm not really sure what you want Page 12 EFTA00802075 hrg091613epstein.txt 25 me to rule to be honest with you. 15 1 MR. SCAROLA: There are two things I want 2 you to rule, your Honor. I want you first to 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 Nov n't tell vour Honor that I have at 19 ha lorida case that approves a specific 20 form f instruction. But the law is quite 21 ear that we are entitled to jury instructions that support our theory of the case. And it is a proper statement of the law, that a statement -- excuse me -- that an assertion of privilege 25 in the context of a civil case may be used by fter 1 2 rule that Mr. Epstein will not be permitted to give testimony or to produce evidence that he, himself, has withheld as a consequence of his consistent assertion of the Fifth Amendment privilege during the course of the four that this matter has been in pretrial discovery. He should not be perm having refused to give that ev pretrial discovery, to prey trial. That's part one Part two, we sh instruction after deposition tes has refuse silence evidence at ntitled to an ish Mr. o the jury er questions, eld against him. Epstein's in which he that his the jury to draw an adverse inference, inference against the person who refuses to Page 13 16 EFTA00802076 hrg091613epstein.txt 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 4 S 6 testify. Now the common experiences of jurors who watch TV and read magazines and read books is that you may not hold an individual's right to remain silent against him. Because jurors are generally educated about such matters in the context of criminal proceedings. So to disabuse jurors who may believe that it is improper to hold an assertion of Fifth Amendment privilege against someone, we be entitled to an instruction that saitc what the law is. And the law is that you the assertion of the righ in silent in who is making that strong statemen in the cases t t Includi has talk .., t the ed as ertion of a right AlSorti the context of a civil s ed hold ainst the person ert . There are very port of that position ave cited to Your Honor. States supreme Court that probative value of an to remain silent in the con of civil cases. So it is on that basis that we are asking the Court to do those two things. -tell us right now that since Mr. Epstein's refused to give evidence pretrial, he's not going to be permitted to recede from that. And secondly. tell us that the jury will be informed of the basic legal principle that the assertion of the Page 14 17 EFTA00802077 hcg091613epstein.txt 7 right to remain silent in the context of a 8 civil case can be used against the person 9 asserting that right to remain silent. 10 THE COURT: Okay, you get the last word. 11 MS. COLEMAN: Thank you, Judge. I was 12 13 14 15 trial. First, Judge, I would submit that we 16 had filed weeks ago our trial exhibit li 17 witness list. And if there's specific i 18 contained on our exhibit list in 19 Mr. Scarola takes issue, he sh g it up 20 at the proper time and obj o , which 21 we're required to do pur t your court 22 order. If there is listed on our 23 exhibit list that i to what he's asking 24 for, that's th time to raise it. 25 Furth udge, your order unable to address section two or Mr. scarola's motion in which he be precluded at offering certain part two of asks that we evidence at 18 1 sp ' 'tally delineates, I believe in paragraph 2 H, t if we haven't provided it to opposing nsel, we can't use it. It's that simple. Obviously, if we tried to submit evidence that we have not provided to the plaintiff in this case, we wouldn't be permitted to use it. 7 THE COURT: So there's a difference under 8 the Winger analysis. There's two different 9 things there. one I can -- certainly 1 don't 10 have to do Singer analysis and the sanction. 11 want to know what I haven't done, okay. Page 15 j e • • • EFTA00802078 hrg091613epstein.txt 12 Because I've evidentially missed something 13 along the way. Because I entered an order 14 basically saying I required you to file 15 privilege logs which identify each document, 16 what the privilege is to that document and so I 18 I have to look at. I don't recall. Did I get 19 AS" that? 17 can look at them and determine which ones more 20 MS. COLEMAN: No, what happened, ludg 21 what we did we amended our answers to -- 22 THE COURT: / must be losing m d. 23 MS. COLEMAN: we amended ou to 24 all that discovery and only a he Fifth 25 Amendment to those that w serting a 1 privilege. So (4e°i !!: other privilege 2 raised. 3 THE hat am I supposed to be ) 4 ruling 5 MS. COLEMAN: Right now? HiS motion. 6 COURT: NO. No, I thought -- again, (C I'm I'm sorry, guys I'm confused. I thought there 8 t 0 as things out -- Mr. Scarola said there are things outstanding. MS. COLEMAN: But there's still our issue with the privilege log filed by Mr. Edwards 12 with respect to our discovery requests as well. 13 THE COURT: I'm talking about with regard 14 to Mr. Epstein. Is there anything I need to 15 rule on with him? Page 16 19 EFTA00802079 hrg091613epstein.txt 16 MS. COLEMAN: No. 17 MR. SCAROLA: That wasn't my understanding 18 but quite frankly, Your Honor, I didn't 19 specifically review that for purposes of 20 responding to that question. 21 THE COURT: I'm sorry for interrupting 22 you. The only reason I did that is to prepare 23 for today's hearing. I looked at the file and 24 one of the last things I did was that order 25 entered on where I determined that I wil 20 1 require you to file the detail r eged log 2 so I can determine based on ola's 3 argument on the Fifth t ou can't get 4 but the other stuff, , can be 5 sanctionable. / t was kind of waiting 6 because I did anything. You're telling 7 me there i rivileged log out there or 8 there i one t I need to rule on? 9 MS. ,OLImAN: No, your order said that you 10 ne be able to rule on the other 11 non- fth amendment privilege which we raised. 12 ery other privilege we raised has now been 13 withdrawn and all the discovery has been amended. Anywhere we asserted a privilege, we asserted the Fifth along with other privileges. 16 All the other privileges were taken out. So 17 it's only the Fifth Amendment. So there's 18 nothing to review. 19 THE COURT: Some of the case law I read in 20 Federal court says even the Fifth Amendment Page 17 EFTA00802080 hrg091613epstein.txt 21 sometimes the court can look at in-camera to 22 determine if it's -- 23 MS. COLEMAN: If you would like us to 24 do 25 THE COURT: No, I never asked for 1 in-camera inspection if / don't need to do t 1? 2 I'm just asking what it is I need to do 4( 41 3 haven't done in regards to the privileg og 4 regard to Mr. Epstein. we're just jibing with 5 this. 6 MR. scAROLA: I will ac Coleman's 7 representation on the recut all of the 8 discovery that has bee ld has been 9 withheld solely on s of the Fifth ‘ 10 Amendment privi A 11 THE COU e's been a privilege log 12 filed or 13 MS COI N: No. Judge. The answer it's 14 al net-worth discovery. The discovery that 15 was ssue is the net-worth discovery for the ri 16 puni ive damages. THE COURT: This is probably unfair to you I17 guys. I'm asking questions because it concerns me if there's something out there I'm supposed to be ruling on and I might have to do that. 21 Is there something pending on me that I'm 22 supposed to rule on? 23 MR. SCAROLA: Not if the only privilege 24 that's being asserted is a Fifth Amendment Page 18 EFTA00802081 hrg091613epstein.txt 25 privilege. Your Honor may recall that what you 22 1 did talk about at the time of that last hearing 2 was that some of the financial information that 3 was requested was corporate financial 4 information. And you correctly observed a 5 6 So I don't know Your Honor asks the 7 rhetorical question. I don't know how y .g) -- 8 be asserting a Fifth Amendment privilege 9 regard to the corporate records. 10 THE COURT: It has to be s i 1 even 11 if it's an individual. x r b at. 12 MR. SCAROLA: Corre n those were the 13 concerns that Your H x ssed. And it was 14 my understanding tN a shifted the burden 15 back to the co rt77 endant to provide 16 something t tp our Honor with regard to 17 those m ters 18 positi . f.)he 19 ev ing that has been withheld in discovery 20 has en withheld on the basis of the Fifth 21 a endment privilege, I'll accept that 0 22 representation. corporation 4 i v has no Fifth Amendment privilege. iut I will repeat, if the counter defendant is that THE COURT: I'm asking you. I don't want to get -- 25 Hs. COLEMAN: That is not what I said, 23 1 Judge. 2 THE COURT: Hang on. I'm going to set a Page 19 EFTA00802082 hrg091613epstein.txt 3 status conference. You guys can talk about 4 this. see what the status of discovery is at. 5 what I need you to do is I need that fairly 6 quickly. Probably next week or so you all are 7 coming up on trial here. And see what I need 8 to get done before you all walk into the 9 courtroom. You said there's also stuff and so 10 are you waiting for me to rule on 11 MS. COLEMAN: Judge, you were 12 was quite a while back. That 13 with respect to the privileged log by 14 Mr. Edwards first from (inaudibl from 15 Farmer Jaffe. There is some s that 16 were alleged by them to b ntial, just 17 communications, such ication with the 18 press and the gover nt t have not yet been 19 ruled on. The ing as supposed to be 20 continued. 21 THE don't recall. I have 22 nothing byre, at least that I know, that 23 24 25 ha t been ruled on. 1 , Ilir COLEMAN: Judge. we taking had a m ion (5) refile the motion, 24 THE COURT: or reschedule it or whatever. don't have any in-camera that I haven't done 3 so far. 4 MS. COLEMAN: If you're not making a 5 ruling right now on this motion, we would like 6 to be afforded the opportunity to respond to Page 20 EFTA00802083 hrg091613epstein.txt 7 the thirteen-page memorandum that Barnhart, 8 Scarola provided a couple of hours ago. 9 THE COURT: HOW quickly can you respond? 10 MS. COLEMAN: Judge, the hearing was set 11 -- he set this hearing on July 17th and it was 12 13 14 15 16 17 18 19 20 21 front of you again on thi 22 THE COURT: You 23 apologize, guys. 24 MS. COLE ' unfair for a five-day 25 requiremen given to me today. A week? THE COURT: You think you can do it a little early? Can you have it by Friday? MS. COLEMAN: No, Judge, I have to be i Tavernier and Marathon on Thursday and Fr ay. THE COURT: Do you know who would 1 be in the Keys? MS. COLEMAN: Not on this I'm back here at 8:45 tumor 25 1 . SCAROLA: I have no problem. 2 S. COLEMAN: Five day. THE COURT: Next week. How about next Monday, next Tuesday? MS. COLEMAN: Next Tuesday would be good. THE COURT: Next Tuesday by 5 p.m. Tell you what I want you to do to make it easy. 8 call my JA or have someone call my JA and get 9 an address. You can e-mail, maybe emailing it 10 to me and the same to Mr. scarola so I get it 11 on Tuesday. can you do that? Page 21 EFTA00802084 hrg091613epstein.txt 12 MS. COLEMAN: Yes. 13 MR. SCAROLA: Will it be necessary for me 14 to resubmit what I hand delivered? 15 THE COURT: No, I'll take what I got and 16 wait for her. okay, I'll get an order out as 17 soon as I receive a response. 18 MR. SCAROLA: Thank you very much. 19 20 and talk about what you need to do. THE COURT: I want you guys to sit down I'm 21 to schedule a conference to see what ne 22 be done. I got an easy feeling tha in g 23 need to be done before this Octo Thank 24 you. 25 (The hearing was concl :05 p.m.) 1 CER X11 F ATE 2 3 STATE OF FLORA 4 COUNTY OF PA BE, 5 6 7 8 to c if I, P mela Pittman Gunn, Court Reporter, State F ida at large, certify that I was authorized 9 and did stenographically report the foregoing hearing, pages 1-25; proceedings were held on September 16, 2013 and that the transcript is a true 12 and complete record of my transcription. 13 oated this 23rd day of October, 2013. 14 15 Page 22 26 EFTA00802085 16 17 18 19 20 21 22 23 24 25 hrg091613epstein.txt Pamela Pittman Gunn, Court Reporter Page 23 EFTA00802086