EFTA00595377.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, - Vs- SCOTT ROTHSTEIN, INDIVIDUALLY, BRADLEY J. EDWARDS, INDIVIDUALLY, AND III., INDIVIDUALLY, Defendants. HEARING BEFORE THE HONORABLE DAVID CROW Monday, March 11, 2013 9:05 - 9:17 =. PALM BEACH COUNTY COURTHOUSE, COURTROOM 9C 205 North Dixie Highway West Palm Beach, Florida Stenographically Reported By: Paula McGuirk, RPR, FPR Registered Professional Reporter Florida Professional Reporter 561-835-0220 EFTA00595377 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 APPEARANCES: On behalf of the Plaintiff: LAW OFFICES OF TONJA HADDAD COLEMAN, Ill 315 Southeast Seventh Street Suites 301 Fort Lauderdale, Florida 33301 954.467.1223 BY: TONJA HADDAD COLEMAN, ESQUIRE On behalf of the Defendants: SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, Ill. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 561.686.6300 BY: JACK SCAROLA, ESQUIRE 561-835-0220 EFTA00595378 1 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROCEEDINGS THE CLERK: Epstein vs. Rothstein. MR. SCAROLA: Good morning. Jack Scarola on behalf of Bradley Edwards. THE COURT: Give me one second, please. MR. SCAROLA: Absolutely. THE COURT: Okay, what do we have? MR. SCAROLA: Your Honor, this is the Counter-Plaintiff, Bradley Edwards, motion to strikf untimely objections, and if I may approach the Court , I have a time line that / hope will be of help to Your Honor. THE COURT: Okay. MR. SCAROLA: Your Honor, this motion relates to net worth interrogatories propounded after Your Honor permitted the amendment of this complaint to assert a claim for punitive damages. We served discovery relating to Mr. Epstein's financial circumstances on December 21, '12 following that order, and pursuant to the provision of Rule 1.340 and the 1.350 responses to both of those, discovery requests were due within 30 days. Within 30 days rather than filing responses, what we received was a motion for protective order. 561-835-0220 EFTA00595379 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 The motion for protective order raised a variety of objections to the discovery. included among those objections was that the discovery was propounded for purposes of harassment, oppression and embarrassment Your Honor considered that motion and entered an order on January 29th denying the motion for protective order. That particular order included ni time for the provision of the discovery, and we brought that matter -- that is i, on behalf of Mr. Edwards, brought that matter to the Court's attention, and Your Honor entered an order on February 4th compelling responses to the discovery within 20 days. Within 20 days, rather than receiving discovery responses, what we received from the opposing party were more objections. In fact, there is nothing but objections to the discovery, and there is not -- apart from Mr. Epstein's name -- there is not a single substantive response to any of the questions that were asked with regard to his financial circumstances. It is our position that all of the objections that were raised after the initial 30 days for filing of objections or responses to the interrogatories are untimely, and that those objections need not be 561-835-0220 EFTA00595380 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 addressed substantively. We are not before Your Honor this morning to ask the Court to consider the substance of the objections, but to strike all objections, except fo: the Fifth Amendment privilege assertion, on the basis that those objections are untimely. The significance of striking all of the objections, other than the Fifth Amendment privilege objection, is that other objections cannot be commented upon in the presence of the jury. /f there are valid legal objections tc not providing the information, obviously we cannot draw adverse inferences from those other objections, nor can we comment upon those other objections. However, the Defendant's failure to respond to this financial discovery on the basis of the Fifth Amendment privilege assertion is obviously something that can be raised in the presence of the jury, and we can draw adverse inferences from his refusal to provide any financial information whatsoever. That's the purpose of this motion. THE COURT: Yes. MS. COLEMAN: Good morning, Judge. Tonja Haddad Coleman on behalf of Mr. Epstein. First, IMO really not quite sure how to respond to this since Mr. Scarola has yet, again, filed a motion that 561-835-0220 EFTA00595381 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 contains not one rule or case on which he's relying. So, I'll address each allegation in turn. First, all he states is that our objections arc untimely. This Court ordered that we respond. Not answer, but respond to the discovery requests within 20 days of the order. The order was entered February 4th. As such, our response was due on or before Monday, February 25th, since February 24th was a Sunday. We timely responded to all discovery requests on Friday, February 22nd, actually, making them early. Furthermore, with respect to the motion for protective order, the law is very clear that the issues that you must raise in a protective order, and the only issues we raised in our motion for protective order were on the grounds of annoyance, embarrassment, oppression, undue burden. We've only raised issues as delineated in Rule 1.380. However, within our responses to the discovery we did raise many objections, including privilege, and I have a case right on point for the Court, and which I've taken the time to actually highlight the relevant portions, if I may approach. I have a Fourth DCA case in which it says, "A timely obje,L on is not required to claims to be privileged when one 561-835-0220 EFTA00595382 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 is raising a motion for protective order because, and I quote, 'This follows from the fact that Rule 1.280(c) refers to issuance of protective order only to protect a party or person from annoyance, embarrassment, oppression or undue burden or expense.'" It does not refer to privilege. We think the omission was intentional and, therefore, the word objectionable in Rule 1.380(d), therefore, should be construed as referring only to items which are within the scope of discovery; that is, not privileged. As such, Judge, once you denied our motion for protective order, we were still well within our legal rights -- our client's legal rights -- to raise any objections that were not raised in the motion for protective order. This case supports that position. We timely filed our objection. THE COURT: As I understand it, he is not asking me to rule on privilege objections. MS. COLEMAN: Those are all the objections. There are various -- THE COURT: You got overbroad, burdensome, not calculated to lead to admissible evidence. MS. COLEMAN: Judge, I don't know because he didn't provide, as one does, the copies of the 561-835-0220 EFTA00595383 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 answers to which he is objecting. He's asking you to strike all of them. I don't know which ones he wants stricken. We raised the privileges. THE COURT: Okay. III just listening to what he said. He said he wants me to strike everything except the privilege objections. MS. COLEMAN: Well, they're not here. The rules -- my understanding of the rules -- THE COURT: Excuse me. What's not here? III sorry. MS. COLEMAN: The discovery. There's no copy of the request in the objections. He wants you to strike everything. What is everything? THE COURT: He just gave me a copy of it here. MS. COLEMAN: Well, he didn't give me a copy. THE COURT: Well, it's your responses. MS. COLEMAN: I know it's my responses, Judge. It wasn't attached to his motion, and it wasn't provided to us. THE COURT: Okay. MS. COLEMAN: His motion doesn't say anything. THE COURT: For example, the first one says please produce financial statements to any lender within the past five years. You have your privilegf objection, and then you say vague, unartfully 561-835-0220 EFTA00595384 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 drafted, unable to file a response. I don't know how it would be work product. The accountant privilege would not be applicable. So your position is that you have not waived any -- certainly not waived any privilege objections. I understand that. Your claim is that you have not waived any objections? MS. COLEMAN: Yes, Your Honor, we never raised any issue of overly burdensome. We raised the three grounds one can raise in a protective order. We did not raise, in our objection to his discovery requests, any grounds that you had already ruled upon in your motion for protective order. As such, they're timely objections. THE COURT: I honestly don't remember what I ruled or didn't rule. MS. COLEMAN: I have a copy of your order right here. It's attached to our response to his motion. THE COURT: It says -- you've got here overbroad. MR. SCAROLA: Would Your Honor like a copy of the order? THE COURT: Yes. I don't have the motions, so I don't know what you raised in the motions, but, okay, yes, sir, you want to respond? MR. SCAROLA: I would like to respond, Your 561-835-0220 EFTA00595385 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Honor. The Fourth OCA case, which opposing counsel handed me when she handed it to the Court, specifically addresses attorney/client privilege, and says that attorney/client privilege objections are not waived as a consequence of having raised a motion for protective order. The motion expressly states that we are not seeking this Court's ruling on the assertion of Fifth Amendment privilege. We are seeking to strike all other objections as untimely, and it seems strange that the law would develop to a point where no objection is raised substantively. With regard to these requests for financial information, a motion for protective order is filed. It raises substantial grounds, including harassing, oppressive, embarrassing, and, as counsel has said in her argument, overbroad, and then serially permit other objections to be raised far after the 30-day deadline for response has passed. We would ask the Court to grant this motion, strike all objections, except those as to privilege, and with regard to any privilege objection, other than attorney/client privilege, we will raise that by separate motion. THE COURT: Okay, going to have to take a look at this. The responses are 17 pages long, and 561-835-0220 EFTA00595386 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 will have to look at it today. By the way, is your father an attorney, or is that your brother that's an attorney? MS. COLEMAN: Me? THE COURT: Yeah, Haddad. MS. COLEMAN: Yes. THE COURT: Are you related? MS. COLEMAN: related to a lot of attorneys. I don't know which Haddad you're referring. THE COURT: No, Ill sorry, I -- MR. SCAROLA: Mr. Haddad has actually entered an appearance in this case, Your Honor. THE COURT: Is he related to you? MS. COLEMAN: Yes, he is. THE COURT: Oh, okay. I just wondered. It's interesting. Do you have a relative that works in the Court? We have a clerk, an attorney. THE CLERK: Monica. THE COURT: Monica Haddad. Is she related? MS. COLEMAN: No. THE COURT: Because that's not unusual. I mean, it's kind of like a Smith, Jones kind of -- MS. COLEMAN: Which is why for the last decade: I've tried using my married name, but it doesn't seem 561-835-0220 EFTA00595387 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to take. THE COURT: Okay. I don't mean to -- you know, I was just interested because it's a MS. COLEMAN: Yes. THE COURT: Okay, thank you. MR. SCAROLA: Thank you very much, Your Honor. THE COURT: And did I see something come back from the Fourth? Y'all filed something against me, right? MR. SCAROLA: Yes, they filed a petition for writ of certiorari challenging Your Honor's granting of leave to amend to assert a claim for punitive damages. THE COURT: Well, I thought there was something like somebody tried to recuse -- not recuse -- in fact, the reason I thought it was because I saw it come through, Mr. Haddad, somebody tried to get him kicked off the case. Didn't the Appellate Court say I actually did it right? Am I wrong? MS. COLEMAN: Yes, we didn't appeal that, Judge, because -- MR. SCAROLA: That was not appealed. THE COURT: Oh, okay. MR. SCAROLA: No, the issue that was appealed was the propriety of Your Honor's order granting 561-835-0220 EFTA00595388 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 leave to assert a claim for punitive damages. Th- petition for writ of certiori was denied as to that matter. THE COURT: Okay. MR. SCAROLA: There was a recent opinion tha related to an effort to recuse Attorney Keitel that was just addressed by the Fourth DCA in another matter, so that may have been what Your Honor was seeing. THE COURT: Okay, thank you, guys. MR. SCAROLA: Thank you, Your Honor. MS. COLEMAN: Thank you, Judge. (The hearing concluded at 9:16 III.) 561-835-0220 EFTA00595389 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CERTIFICATE OF REPORTER - - - I, Paula McGuirk, Registered Professional Reporter, Florida Professional Reporter, certify that was authorized to and did stenographically report the foregoing proceedings and that the transcript, pages 1 through 13, is a true and complete record of my stenographic notes. Dated this 13th day of March, 2013. icgl Paula McGui Registered Professional Reporter Florida Professional Reporter 561-835-0220 EFTA00595390 Page 1 A Absolutely 3:7 accountant 9:2 address 6:2 addressed 5:1 13:7 addresses 10:3 admissible 7:23 adverse 5:12,18 allegation 6:2 amend 12:12 amendment 3:17 5:5,8 5:16 10:8 annoyance 6:16 7:4 answer 6:5 answers 8:1 apart 4:18 appeal 12:20 appealed 12:22,24 appearance 11:13 APPEARANCES 2:1 Appellate 12:18 applicable 9:3 approach 3: I I 6:23 argument 10:16 asked 4:20 asking 7:19 8:1 assert 3:18 12:12 13:1 assertion 5:5,16 10:8 attached 8:18 9:17 attention 4:11 attorney 11:2,3,18 13:6 attorneys 11:9 attorney/client 10:3,4 10:22 authorized 14:5 1:16,16 13:13 B back 12:7 BARNHART 2:8 basis 5:5,15 Beach 1:1,17,18 2:8,9 behalf 2:2,7 3:5 4:9 5:23 Boulevard 2:8 Bradley 1:8 3:5,10 brother 11:2 brought 4:9,10 burden 6:17 7:5 burdensome 7:22 9:8 C calculated 7:23 case 1:2 6:1,21,24 7:16 10:1 11:13 12:18 certainly 9:4 CERTIFICATE 14:1 certify 14:4 certiorari 12:11 certiori 13:2 challenging 12:11 CIRCUIT 1:1,1 circumstances 3:20 4:21 claim 3:18 9:5 12:12 13:1 claims 6:25 clear 6:13 clerk 3:3 11:18,19 client's 7:14 Coleman 2:3,6 5:22,23 7:20,24 8:7,11,15,17 8:21 9:7,16 11:4,6,8 11:15,21,24 12:4,20 13:12 come 12:7,17 comment 5:13 commented 5:9 compelling 4:12 complaint 3:17 complete 14:7 concluded 13:13 consequence 10:5 consider 5:3 considered 4:5 construed 7:9 contains 6:1 copies 7:25 copy 8:11,14,15 9:16,20 counsel 10:1,15 Counter-Plaintiff 3:10 COUNTY 1.1,17 Court 1:1 3:6,8,11,14 5:3,21 6:4,21 7:18,22 8:4,9,14,16,20,22 9:14 9:18,22 10:2,19,24 11:5,7,11,14,16,18,20 11:22 12:2,5,7,14,18 12:23 13:4,10 COURTHOUSE 1:17 COURTROOM 1:17 Court's 4:10 10:7 CROW 1:13 D damages 3:18 12:13 13:1 Dated 14:10 DAVID 1:13 day 14:10 days 3:23,24 4:13,14,23 6:6 DCA 6:24 10:1 13:7 deadline 10:18 decade 11:24 December 3:20 Defendants 1:9 2:7 Defendant's 5:14 delineated 6:18 denied 7:12 13:2 DENNEY 2:8 denying 4:6 develop 10:10 discovery 3:19,22 4:2,3 4:8,12,14,17 5:15 6:5 6:9,19 7:10 8:11 9:10 Dixie 1:17 drafted 9:1 draw 5:12,18 due 3:23 6:7 E early 6:11 Edwards 1:8 3:5,10 4:10 effort 13:6 embarrassing 10:15 embarrassment 4:4 6:17 7:5 entered 4:5,11 6:6 11.12 Epstein 1:4 3:3 5:23 Epstein's 3:19 4:18 ESQUIRE 2:6,10 evidence 7:23 example 8:22 Excuse 8:9 expense 7:6 expressly 10:6 F fact 4:16 7:2 12:16 failure 5:14 far 10:17 father 11:2 February 4:12 6:7,8,8 6:10 FIFTEENTH 1:1 Fifth 5:5,8,15 10:8 file 9:1 filed 5:25 7:17 10:13 12:8,10 filing 3:24 4:23 financial 3:19 4:20 5:15 5:19 8:23 10:12 first 5:23 6:3 8:22 five 8:24 Florida 1:1,18,25 2:4,9 14:4,17 following 3:20 follows 7:2 foregoing 14:6 Fort 2:4 Fourth 6:24 10:1 12:8 13:7 FPR 1:23 Friday 6:10 Furthermore 6:12 G give 3:6 8:15 going 10:24 Good 3:4 5:22 grant 10:19 granting 12:11,25 grounds 6:16 9:9,11 10:14 guys 13:10 H Haddad 2:3,6 5:23 11:5 11:9,12,20 12:17 handed 10:2,2 harassing 10:14 harassment 4:4 hearing 1:13 13:13 help 3:12 highlight 6:22 Highway 1:17 honestly 9:14 561-835-0220 EFTA00595391 Page 2 Honor 3:9,13,15,17 4:5 4:11 5:2 9:7,20 10:1 11:13 12:6 13:8,11 HONORABLE 1:13 Honor's 12:11,25 hope 3:12 I included 4:2,7 including 6:20 10:14 INDIVIDUALLY 1:7,8 1:8 inferences 5:12,18 information 5:11,19 10:13 initial 4:23 intentional 7:7 interested 12:3 interesting 11:17 interrogatories 3:16 4:24 issuance 7:3 issue 9:8 12:24 issues 6:14,15,18 items 7:10 J J 1:8 Jack 2:10 3:4 January 4:6 JEFFREY 1:4 Jones 11:23 2:10 Judge 5:22 7:12,24 8:17 12:21 13:12 JUDICIAL 1:1 jury 5:10,17 K Keitel 13:6 kicked 12:18 kind 11:23,23 know 7:24 8:2,17 9:1 9:23 11:9 12:2 L Lakes 2:8 Lauderdale 2:4 law 2:3 6:13 10:10 lead 7:23 leave 12:12 13:1 legal 5:10 7:13,14 lender 8:23 line 3:12 listening 8:4 long 10:25 look 10:25 11:1 lot 11:8 1:8 making 6:10 March 1:15 14:10 married 11:25 matter 4:9,10 13:3,8 McGuirk 1:23 14:3,16 mean 11:23 12:2 Monday 1:15 6:8 Monica 11:19,20 morning 3:4 5:2,22 motion 3:10,15,25 4:1,5 4:6 5:20,25 6:12,15 7:1,12,15 8:18,21 9:12,17 10:5,6,13,19 10:23 motions 9:22,23 N name 4:18 11:25 need 4:25 net 3:16 never 9:7 North 1:17 notes 14:8 0 objecting 8:1 objection 5:8 6:24 7:17 8:25 9:10 10:11,21 objectionable 7:8 objections 3:11 4:2,3 4:16,17,22,24,25 5:4,4 5:6,7,9,10,12,13 6:3 6:20 7:15,19,20 8:6 8:12 9:5,6,13 10:4,9 10:17,20 obviously 5:11,16 OFFICES 2:3 Oh 11:16 12:23 okay 3:8,14 8:4,20 9:24 10:24 11:16 12:2,5,23 13:4,10 omission 7:7 once 7:12 ones 8:2 opinion 13:5 opposing 4:15 10:1 oppression 4:4 6:17 7:5 oppressive 10:15 order 3:21,25 4:1,6,7,7 4:11 6:6,6,13,14,16 7:1,3,13,16 9:9,12,16 9:21 10:6,13 12:25 ordered 6:4 overbroad 7:22 9:19 10:16 overly 9:8 P pages 10:25 14:6 Palm 1:1,17,18 2:8,9 particular 4:7 party 4:15 7:4 passed 10:18 Paula 1:23 14:3,16 permit 10:16 permitted 3:17 person 7:4 petition 12:10 13:2 Plaintiff 1:5 2:2 please 3:6 8:23 point 6:21 10:11 portions 6:23 position 4:22 7:16 9:3 presence 5:9,17 privilege 5:5,8,16 6:20 7:6,19 8:6,24 9:2,5 10:3,4,8,20,21,22 privileged 6:25 7:11 privileges 8:3 proceedings 3:1 14:6 produce 8:23 product 9:2 Professional 1:24,25 14:3,4,17,17 propounded 3:16 4:3 propriety 12:25 protect 7:4 protective 3:25 4:1,7 6:13,14,16 7:1,3,13,16 9:9,12 10:6,13 provide 5:19 7:25 provided 8:19 providing 5:11 provision 3:21 4:8 punitive 3:18 12:12 13:1 purpose 5:20 purposes 4:4 pursuant 3:21 X2:3,8 questions 4:19 quite 5:24 quote 7:2 R raise 6:14,20 7:14 9:9 9:10 10:22 raised 4:1,23 5:17 6:15 6:18 7:15 8:3 9:7,8,23 10:5,11,17 raises 10:14 raising 7:1 really 5:24 reason 12:16 received 3:25 4:15 receiving 4:14 record 14:7 recuse 12:15,15 13:6 refer 7:6 referring 7:9 11:10 refers 7:3 refusal 5:18 regard 4:20 10:12,21 Registered 1:24 14:3,17 related I I :7,8,14,20 13:6 relates 3:15 relating 3:19 relative 11:17 relevant 6:23 relying 6:1 remember 9:14 report 14:5 Reported 1:22 Reporter 1:24,25 14:1 14:4,4,17,17 561-835-0220 EFTA00595392 Page 3 request 8:12 requests 3:23 6:5,10 9:11 10:12 required 6:25 respect 6:12 respond 5:14,24 6:4,5 9:24,25 responded 6:9 response 4:19 6:7 9:1 9:17 10:18 responses 3:22,24 4:12 4:15,24 6:19 8:16,17 10:25 right 6:21 9:16 12:9,19 rights 7:14,14 Rothstein 1:7 3:3 RPR 1:23 rule 3:21 6:1,18 7:3,8 7:19 9:15 ruled 9:11,15 rules 8:8,8 ruling 10:7 S saw 12:16 says 6:24 8:22 9:18 10:4 Scarola 2:8,10 3:4,4,7,9 3:15 5:25 9:20,25 11:12 12:6,10,22,24 13:5,11 scope 7:10 SCOTT 1:7 SEARCY 2:8 second 3:6 see 12:7 seeing 13:9 seeking 10:7,9 separate 10:23 serially 10:16 served 3:18 Seventh 2:3 SHIPLEY 2:8 significance 5:6 single 4:19 sir 9:24 Smith 11:23 somebody 12:15,17 sorry 8:10 11:11 Southeast 2:3 specifically 10:3 statements 8:23 states 6:3 10:6 stenographic 14:8 stenographically 1:22 14:5 strange 10:10 Street 2:3 stricken 8:3 strike 3:10 5:4 8:2,5,13 10:9.20 striking 5:7 substance 5:3 substantial 10:14 substantive 4:19 substantively 5:1 10:11 Suites 2:4 Sunday 6:9 supports 7:16 sure 5:24 T take 10:24 12:1 taken 6:22 thank 12:5,6 13:10,11 13:12 think 7:7 thought 12:14,16 three 9:8 time 3:12 4:8 6:22 timely 6:9,24 7:17 9:13 today 11:1 Tonja 2:3,6 5:22 tonja@tonjahaddad.... 2:5 transcript 14:6 tried 11:25 12:15,17 true 14:7 turn 6:2 U unable 9:1 unartfully 8:25 understand 7:18 9:5 understanding 8:8 undue 6:17 7:5 untimely 3:11 4:25 5:6 6:4 10:9 unusual 11:22 V vague 8:25 valid 5:10 variety 4:1 various 7:21 vs 1:6 3:3 W waived 9:4,4,6 10:5 want 9:24 wants 8:2,5,12 wasn't 8:18,18 way 11:1 West 1:18 2:9 We've 6:17 whatsoever 5:19 wondered 11:16 word 7:8 work 9:2 works 11:17 worth 3:16 writ 12:11 13:2 wrong 12:19 Y Yeah 11:5 years 8:24 Y'all 12:8 1 1 14:6 1.280(c) 7:3 1.340 3:21 1.350 3:22 1.380 6:18 1.380(d) 7:8 11 1:15 12 3:20 13 14:7 13th 14:10 17 10:25 2 20 4:13,146:6 2013 1:15 14:10 205 1:17 213:20 2139 2:8 22nd 6:10 24th 6:8 25th 6:8 29th 4:6 3 30 3:23,24 4:23 30-day 10:17 3012:4 315 2:3 33301 2:4 334092:9 4 4th 4:12 6:7 5 502009CA040800XX... 1:2 561.686.6300 2:9 9 9C 1:17 9:05 1:16 9:16 13:13 9:17 1:16 954.467.1223 2:5 561-835-0220 EFTA00595393