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CASE NO.: 502009CA0408003OOOGABAG
Plaintiff(s),
vs.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
L.M., individually,
Defendant(s).
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.
y l enney
art & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
3409
Attorneys for Bradley J. Edwards
EFTA01142065
Edwards adv. Epstein
Notice of Service of Interrogatory to Jeffrey Epstein
Case No.: 502009CA040800300C(MBAG
Jack A. Goldberger, Esquire
Atterbury, Goldberger & Weiss, P.A.
250 Australian Avenue South, Suite 1400
West Palm Beach FL 33401
Attorneys for Jeffrey Epstein
armer, Jaffe, Weissing,
Lehrman, FL
425 North Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301
s, Fistos &
Fred Haddad, P.A.
One Financial Plaza, Suite 2612
COUNSEL LIST
Fort Lauderdale, FL 33394
Attorneys for Jeffrey Epstein
w
ces o
arc . un k
One E Broward Blvd., Suite 700
Fort Lauderdale, FL 33301
Attorneys for Scott Rothstein
Tonja Haddad, P.A.
315 SE 7th Street, Suite 301
Fort Lauderdale, FL 33301
Attorneys for Jeffrey Epstein
EFTA01142066
Edwards adv. Epstein
Notice of Service of Interrogatory to Jeffrey Epstein
Case No.: 502009CA040800)OCOCMBAG
(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
EFTA01142067
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
EFTA01142068