EFTA00588976.pdf

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408007OOOCMBAG 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: I. Admitted. 2. Admitted. 3. 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 EFTA00588976 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. 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 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 Hojfinan 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 EFTA00588977 6. 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. 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 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. 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 3 EFTA00588978 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 (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. 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 Hojfinan 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. 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 Hojfinan v. United States, 341 U.S. 479, 486 4 EFTA00588979 (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 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 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 7'h Street Suite 301 Fort Lauderdale, Florida 33301 5 EFTA00588980 n EFTA00588981