EFTA00603517.pdf

Filing # 61717726 E-Filed 09/19/2017 03:04:43 PM 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 1., individually, Defendant(s). NOTICE OF PRODUCTION FROM NON-PARTY TO: Tonja Haddad Coleman, Es uire Tonja Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 William Chester Brewer, Es uire 250 S Australian Avenue, Suite 1400 West Palm Beach, FL 33401 YOU ARE NOTIFIED that after ten (10) days from the date of service of this Notice, if service is by delivery, or fifteen (15) days from the date of service, if service is by mail, and if no objection is received from any party, the undersigned will issue or apply to the Clerk of this Court for issuance of the attached Subpoenas directed to the following individual to produce the items listed at the time and place specified in the Subpoena. 1. Joseph L. Ackerman, EaBire Fowler White Burnett, M.. 515 N. Flagler Drive, Suite 2100 West Palm Beach, FL 33401 EFTA00603517 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Notice of Production from Non-Party Page 2 2. Robert D. Critton, Esquire 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 3. Jack A. Goldberger, Esquire Atterbury Goldberger & 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 4. Roy Black, Esquire Black Srebnick Komspan and Stumpf, M. 201 South Biscayne Boulevard, #1300 Miami, FL 33131 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 .94 4 ' 2017. JACK S Flori Atto mm Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: 561-383-9451 Attorneys for Bradley J. Edwards EFTA00603518 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Notice of Production from Non-Party Page 3 COUNSEL LIST William Chester Brewer, Es uire 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. Goldber Atterbury Goldberger & Weiss, . . 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Bradle J. Edwards,ki re Fanner Jaffe Weissing Edwards Fistos & Lehrman, E. 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 Fred Haddad, Esquire Fred Haddad, One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: (954)-467-6767 Fax: (954)467-3599 Attorneys for Jeffrey Epstein Tonja Haddad Coleman, Esquire Tonja Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: (954)467-1223 Fax: (954)-337-3716 Attorneys for Jeffrey Epstein Marc S. l i l E urilc, uire One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein EFTA00603519 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 individually, Defendant(s). SUBPOENA DUCES TECUM TO NON-PARTY THE STATE OF FLORIDA TO: Joseph L. Ackerman, Esquire Fowler White Burnett, ■. 515 N. Flagler Drive, Suite 2100 West Palm Beach, FL 33401 YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart & Shipley, e., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 10, 2017 at 1:00 ■. and to have with you at that time and place the following: Duces Tecum: All documents* regarding your representation of Jeffrey Epstein with respect to any allegation of criminal wrongdoing against Jeffrey Epstein and any consideration of and involvement in the filing prosecution of any claim by Jeffrey Epstein against Scott Rothstein and/or Bradley Edwards. EFTA00603520 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 2 *"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 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) systems—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. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: 1) Appear as specified; or EFTA00603521 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The undersigned, as custodian of records for Joseph L. Ackerman, Esquire, certifies that the attached documents consisting of pages represents a true copy of all items within my possession, custody or control which are described in the Subpoena Duces Tecum Without Deposition served on me in the above styled action and each page is numbered by me for identification. Production is complete and has been numbered by the custodian of records. It is further certified that originals of the items produced are maintained under the direction, custody and control of the undersigned. The foregoing Certification was acknowledged before me, an officer duly authorized in the State and County aforesaid to take acknowledgments, this day of , 2017, who: [ ] is personally known to me; or [ ] has produced as identification; and who: ] did or [ ] did not, take an oath, and who executed the foregoing certification, and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited. Notary Public, State of Florida at Large My Commission Expires: EFTA00603522 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 individually, Defendant(s). SUBPOENA DUCES TECUM TO NON-PARTY THE STATE OF FLORIDA TO: Robert D. Critton, Esquire 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart & Shipley, fl ., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 6, 2017 at 1:30 and to have with you at that time and place the following: Duces Tecum: All documents* regarding your representation of Jeffrey Epstein with respect to any allegation of criminal wrongdoing against Jeffrey Epstein and any consideration of and involvement in the filing and prosecution of any claim by Jeffrey Epstein against Scott Rothstein and/or Bradley Edwards. •"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 EFTA00603523 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 2 compilations from which information can be obtained, translated, if necessary, by the party to 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) systems—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. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: I ) Appear as specified; or 2) Furnish the records instead of appearing as provided above; or 3) Object to this subpoena, EFTA00603524 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 3 You may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED this day of JAC Fl 2017. ROLA ar No.: 169440 E-Mail s Primary E-mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: 561-383-9451 Attorneys for Bradley Edwards EFTA00603525 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The undersigned, as custodian of records for Robert D. Critton, Esquire, certifies that the attached documents consisting of pages represents a true copy of all items within my possession, custody or control which are described in the Subpoena Duces Tecum Without Deposition served on me in the above styled action and each page is numbered by me for identification. Production is complete and has been numbered by the custodian of records. It is further certified that originals of the items produced are maintained under the direction, custody and control of the undersigned. The foregoing Certification was acknowledged before me, an officer duly authorized in the State and County aforesaid to take acknowledgments, this day of , 2017, who: [ ] is personally known to me; or [ ] has produced as identification; and who: [ ] did or [ ] did not, take an oath, and who executed the foregoing certification, and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited. Notary Public, State of Florida at Large My Commission Expires: EFTA00603526 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 individually, Defendant(s). SUBPOENA DUCES TECUM TO NON-PARTY THE STATE OF FLORIDA TO: Jack A. Goldberger, Esquire Atterbury Goldberger & Weiss, ■. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart & Shipley, .., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 6, 2017 at 10:30 and to have with you at that time and place the following: Duces Tecum: All documents* regarding your representation of Jeffrey Epstein with respect to any allegation of criminal wrongdoing against Jeffrey Epstein and any consideration of and involvement in the filing and prosecution of any claim by Jeffrey Epstein against Scott Rothstein and/or Bradley Edwards. EFTA00603527 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 2 *"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 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) systems—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. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: 1) Appear as specified; or EFTA00603528 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non•Party Page 3 2) Furnish the records instead of appearing as provided above; or 3) Object to this subpoena, You may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED this day of , 2017. Primary E-mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: 561-383-9451 Attorneys for Bradley Edwards EFTA00603529 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The undersigned, as custodian of records for Jack A. Goldberger, Esquire, certifies that the attached documents consisting of pages represents a true copy of all items within my possession, custody or control which are described in the Subpoena Duces Tecum Without Deposition served on me in the above styled action and each page is numbered by me for identification. Production is complete and has been numbered by the custodian of records. It is further certified that originals of the items produced are maintained under the direction, custody and control of the undersigned. The foregoing Certification was acknowledged before me, an officer duly authorized in the State and County aforesaid to take acknowledgments, this day of , 2017, who: is personally known to me; or has produced did or did not, take an oath, as identification; and who: and who executed the foregoing certification, and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited. Notary Public, State of Florida at Large My Commission Expires: EFTA00603530 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 individually, Defendant(s). I SUBPOENA DUCES TECUM TO NON-PARTY THE STATE OF FLORIDA TO: Roy Black, Esquire Black Srebnick Komspan and Stumpf, 201 South Biscayne Boulevard, #1300 Miami, FL 33131 YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart & Shipley,.., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 6, 2017 at 3:30 and to have with you at that time and place the following: Duces Tecum: All documents* regarding your representation of Jeffrey Epstein with respect to any allegation of criminal wrongdoing against Jeffrey Epstein and any consideration of and involvement in the filing and prosecution of any claim by Jeffrey Epstein against Scott Rothstein and/or Bradley Edwards. EFTA00603531 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 2 *"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 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) systems—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. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose name appears on this subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: 1) Appear as specified; or EFTA00603532 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 3 2) Furnish the records instead of appearing as provided above; or 3) Object to this subpoena, You may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED this day of , 2017. 7 JACK AR LA Fier' Ba o.: 169440 Attu -Mai l(s): mm Primary E-mail: Searcy Denney Scarola Barnhart & Shipley. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: 561-383-9451 Attorneys for Bradley Edwards ;and EFTA00603533 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Subpoena to Non-Party Page 4 CERTIFICATION OF RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION STATE OF FLORIDA COUNTY OF The undersigned, as custodian of records for Roy Black, Esquire, certifies that the attached documents consisting of pages represents a true copy of all items within my possession, custody or control which are described in the Subpoena Duces Tecum Without Deposition served on me in the above styled action and each page is numbered by me for identification. Production is complete and has been numbered by the custodian of records. It is further certified that originals of the items produced are maintained under the direction, custody and control of the undersigned. The foregoing Certification was acknowledged before me, an officer duly authorized in the State and County aforesaid to take acknowledgments, this day of , 2017, who: is personally known to me; or has produced as identification; and who: did or did not, take an oath, and who executed the foregoing certification, and who acknowledged the foregoing certification to be freely and voluntarily executed for the purposes therein recited. Notary Public, State of Florida at Large My Commission Expires: EFTA00603534