Case File
efta-efta01141955DOJ Data Set 9OtherIN THE CIRCUIT COURT OF THE
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Unknown
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DOJ Data Set 9
Reference
efta-efta01141955
Pages
4
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0
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IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502009CA0408003OOOGABAG
JEFFREY EPSTEIN,
Plaintiff(s),
vs.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
L.M., individually,
Defendant(s).
NOTICE OF SERVICE OF INTERROGATORY TO JEFFREY EPSTEIN
Bradley J. Edwards, hereby gives notice pursuant to Rule 1.340(e), Florida Rules of Civil
Procedure, that an Interrogatory has been directed to Jeffrey Epstein, this Olay of August,
2013.
It is requested that the aforesaid answers be served within thirty (30) days at the offices of
Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West
Palm Beach, Florida, 33409.
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
daiiifykugust, 2013.
JACKS AR LA
Flori
ar o.: 169440
Prim
mail:
E-m
s :
S
y Denney Scaro a
art & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone:
Fax:
Attorneys for Bradley J. Edwards
EFTA01141955
Edwards adv. Epstein
Notice of Service of Interrogatory to Jeffrey Epstein
Case No.: 502009CA040800300DCMBAG
COUNSEL LIST
Jack A. Goldber
Attorneys for Jeffrey Epstein
Bradley J. Edwards, Esquire
larn
ing
ards, Fistos &
Lehrman FL
Fort Lauderdale, FL 33301
Pho
Fax:
Fred Haddad, Esquire
Fred
Sc
'al
Had
.
Fort Lauderdale, FL 33394
Pho
Fax:11.
Attorneys for Jeffrey Epstein
Marc S. Nurik Es uire
w
ices o
arc . urik
Fort Lauderdale, FL 33301
Phon
Fax:(
Attorneys for Scott Rothstein
Tonja Haddad Coleman, Esquire
nranvormitir,
FIITMAtinelle
I
ort
Phone
Fax: (
Attorneys for Jeffrey Epstein
EFTA01141956
Edwards adv. Epstein
Notice of Service of Interrogatory to Jeffrey Epstein
Case No.: 502009CA040800)OCOCMBAG
INTERROGATORY TO JEFFREY EPSTEIN
(If answering for another person or entity, answer with respect to
that person or entity, unless otherwise stated.)
A. With regard to all communications that occurred at any time prior to the filing of your
civil lawsuit against Bradley Edwards in which communication you expressed the
position that Bradley Edwards was a knowing participant in the efforts of Scott
Rothstein to defraud investors (the Scott Rothstein Ponzi scheme) or that Bradley
Edwards engaged in any misconduct relating to the Scott Rothstein Ponzi scheme,
state the following:
1. a detailed description of the contents of the communication;
2. all participants in and parties to the communication;
3. the date, time, place and circumstances of the communication including how the
communication was made;
4. whether, when, how and why the contents of the communication were ever subsequently
related to any other person;
5. whether and how the contents of the communication were ever memorialized in any
manner and, if so, the identity of everyone having custody of such memorialization.
B. With regard to any request, direction, or authorization to sue Bradley Edwards
communicated by you at any time prior to the filing of your civil lawsuit against
Bradley Edwards, state the following:
1. a detailed description of the contents of the communication;
2. all participants in and parties to the communication;
2
EFTA01141957
Edwards adv. Epstein
Notice of Service of Interrogatory to Jeffrey Epstein
Case No.: 502009CA040800)OOOCMBAG
3. the date, time, place and circumstances of the communication including how the
communication was made;
4. whether, when, how and why the contents of the communication were ever subsequently
related to any other person;
5. whether and how the contents of the communication were ever memorialized in any
manner and, if so, the identity of everyone having custody of such memorialization.
In the event that you claim that any responsive information sought by these
interrogatories is privileged, identify every privilege pursuant to which you claim protection.
STATE OF
COUNTY OF
The foregoing instrument was acknowledged before me this
day of
20_, by
, who is personally known to
me or who has produced
as identification and who did/did
not take an oath.
(SEAL)
(Notary signature)
(Notary name - print)
NOTARY PUBLIC, State of Florida
(Serial number, if any)
3
EFTA01141958
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10. 11. 12. l3. 14. 16. 17. l8. 19. Jeffrey Epstein v. Bradley J. Edwards, et Case No.: 50 2009 CA Attachments to Statement of Undisputed Facts Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564?67, 568) Deposition of LM. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition ofE.W. taken May 6, 2010 (1 15, 1.16, 255, 205, 215?216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Eps
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