EFTA00606606.pdf

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. NOTICE OF HEARING (Specially Set- 15 min.) PLEASE TAKE NOTICE that the undersigned has set down for hearing before the Honorable David F. Crow, one of the Judges of the above-styled Court, in his Palm Beach County Courthouse, 205 North Dixie Highway, Courtroom 9C, West Palm Beach, Florida 33401, on Tuesday, April 5, at 8:30 a.m., the following: EPSTEIN'S MOTION TO COMPEL/MOTION TO DETERMINE IF PRIVILEGE CLAIMS ARE WAIVED The following procedures must be noted on all specially set hearing notices in Division AG: 1. The JA cannot cancel this hearing unless the issue is resolved. 2. No add-ons are permitted without contacting the JA. 3. Any Memorandums submitted are limited to 10 double-spaced pages. 4. Any materials submitted are due at least 7 days prior to the hearing. 5. The moving party is required to bring to the hearing a blank proposed Order with copies and envelopes. FOWLER WHITE BURNETT PA. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00606606 Epstein v Rothstein, Edwards CASE NO. 502009CA040800XXXXMBAG Notice of Hearing PLEASE GOVERN YOURSELVES ACCORDINGLY. In accordance with the Americans With Disabilities Act of 1990, persons needing a special accommodation to participate in this proceeding should contact Barry Blacey, ADA Coordinator for the Courts of Palm Beach County, 205 N. Dixie Highway, West Palm Beach, Florida 33401, Telephone Number (561) 355- 4796, no later than seven days prior to the proceeding. I HEREBY CERTIFY that a true and correct copy of the foregoing was emailed and mailed this gay of February, 2011 to Marc S. Nurik, Esq., One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301; and Jack Scarola, Esquire, 2139 Palm Beach Lakes Boulevard, P.O. Drawer 3626, West Palm Beach, FL 33409. seph L. Ackerman, Jr. Fla. Bar No. 235954 FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 W‘30743INOTERG75-NOH co Epucin's M-Compel 15 mon..11.A.docx - 2 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401. (561) 802-9044 EFTA00606607 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 5020O9CA04O800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSI'EIN, individually, BRADLEY J. EDWARDS, individually, Defendants. MOTION TO COMPEL/MOTION TO DETERMINE IF PRIVILEGE CLAIMS ARE WAIVED Plaintiff/Counter-Defendant, Jeffrey Epstein, ("Plaintiff or Epstein") by and through his undersigned counsel files this his Motion to Compel; in the alternative, Motion to Determine that Privilege Claims of Bradley J. Edwards, ("Edwards") are waived. The grounds for this Motion are as follows: 1. On April 12, 2010, the Plaintiff served a Request to Produce to Defendant Edwards. A copy of the Request to Produce is Exhibit "I" to this motion. 2. On May 11, 2010, counsel for Edwards filed his Response to Plaintiffs Request to Produce. A copy of Edwards' Response to the Request to Produce is attached as Exhibit "2". 3. The Plaintiff asks the Court to note that these were requests for documents in Defendant Edwards possession or control as opposed to those documents or records in the possession or control of the bankruptcy trustee. 4. Paragraph 4 requests all emails, correspondence, etc. by and between Mr. Rothstein and Mr. Edwards on the one hand and several of their investigators relating to Mr. FOWLER WHITE BURNETT P.A.. 901 PHILLIPS POINT WEST, 777 SOUTH FIAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561)802-9044 EFTA00606608 Epstein v Rothstein, Edwards CASE NO. 502009CA040800XXXXMBAG Epstein's case. Objections were filed based on work product and/or attorney-client privilege; and to date, no privilege log has been filed. 5. Paragraph 6 requested fee sharing agreements between Mr. Edwards, RRA and/or Scott Rothstein relating to any aspect of Mr. Epstein's case. Objections were based on relevance and other non-privilege grounds. Paragraph 31 of the Complaint demonstrates that these records are relevant. Moreover, in addition, the Defendant Edwards has a counterclaim that seeks damages for among other things his reputation, interference in professional relationships, loss of value of time required to be diverted from his professional responsibilities. The compensation relationship by and between Mr. Edwards and/or RRA are relevant to that issue and should be produced. 6. Paragraph 9 asks for costs or payment of costs made by the Rothstein firm against Mr. Epstein. Defendant Edwards' response is based on relevance and not on any claim of privilege. The Requests are relevant based on the allegations in Paragraphs 10, 13, 14 and 31 of the Complaint. 7. Paragraph 10 of the Request is similar to Paragraph 9 in that it requests documentation pertaining to any liens for any attorney's fees or costs asserted by the trustee for RRA. The objection is based on relevance. Paragraphs 10, 13, 14 and 31 of the Complaint shows that the allegation is relevant. 8. Paragraph 17 seeks documents supporting the contention made by the Plaintiff for alleged sexual assaults on airplanes. Defendant Edwards objects on several non-privilege grounds which include relevance, vague, over broad, etc. See Paragraphs 34-36 of the Complaint where this is a material part of the Plaintiffs abuse of process claim. - 2 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER MOVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00606609 Epstein v Rothstein, Edwards CASE NO. 502009CA040800XXXXMBAG 9. Paragraph 18 seeks records similar to those described in Paragraphs 9 and 10. Defendant Edwards has not made a privilege claim. The documents are relevant. See the allegations in Paragraphs 10, 13, 14 and 31 of the Complaint. 10. Paragraph 20 seeks the foundation for statements made to the court in one of the pending cases. The objection is based on work product for which no privilege log has been provided. Objections of vagueness and over broad have also been lodged. 11. Paragraph 21 seeks documents relating to potential deponents named by Edwards in each of the three (3) cases against Mr. Epstein. The objections include work product and attorney-client privilege for which no privilege log has been prepared. The documents are relevant based on the allegations contained in Paragraphs 38-41 of the Complaint and should be produced. 12. Paragraph 22 seeks documents supporting Mr. Edwards' claim for damages with a response of not yet determined. Plaintiff Epstein cannot formulate a defense to such a claim in absence of those damages and requests an order compelling the production of those records. 13. Paragraph 24 seeks emails exchanged between Mr. Edwards and a number of named individuals relating to Mr. Epstein. The objections are based on attorney-client work product privilege and no privilege log has been prepared. 14. Under the case of TIG Insurance Corporation of America v. Johnson, 799 So. 2d 339 (Fla. 4111 DCA 2001) and its progeny, states that the failure to timely provide a privilege log may be grounds to determine that a waiver of privileges have occurred. Given the extraordinary passage of time without the preparation of privilege log, the Plaintiff submits those privileges have been waived. - 3 " FOWLER Wtirm BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 Sarni FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802.9044 EFTA00606610 Epstein v Rothstein, Edwards CASE NO. 502009CA040800XXXXMBAG 15. The Plaintiff submits that the discovery request are reasonable, relevant and calculated to lead to other discoverable and admissible evidence. 16. The undersigned counsel certifies that this motion is made in good faith and not for the purpose of delay. I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this PA- 7 day of February, 2011 to Marc S. Nurik, Esq., One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301; and Jack Scarola, Esquire, 2139 Palm Beach Lakes Boulevard P.O. Drawer 3626, West Palm Beach, FL 33409. ost, L. cke an, Jr. Fla. Bar No. 235954 FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 WM107431MTNCPL75-MOTION TO COMPELMOTION TO DETERMINE IF PRIVILEGE CLAIMS ARE WAIVED4LA.doca - 4 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH. FLORIDA 33401 • (561) 802-9044 EFTA00606611 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL' CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, v. Case No. 50 2009CA040800XXXXMB AG SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. EPSTEIN'S REQUEST TO PRODUCE TO EDWARDS Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Fla. R. Civ. P. 1.350, requests that Defendant, BRADLEY J. EDWARDS ("Edwards"), produce or make available for inspection documents responsive to the requests below within thirty (30) days from the date of service: DEFINITIONS AND INSTRUCTIONS A. "Document' means any written or graphic matter or other means of preserving thought or expression, and all tangible things from which information can be processed or transcribed, including the originals and all non-Identical copies, whether different from the original by reason of any notation made on such copy or otherwise, including, but not limited to, correspondence, memoranda, notes, messages, letters, purchase orders, telegrams, teletype, telefax bulletins, e-mails, electronic data, meetings, reports, or other communications, interoffice and Infra-office telephone calls, diaries, chronological data, minutes, books, reports, charts, ledgers, invoices, worksheets, receipts, returns, trade information regarding fabric, carpets, samples _ EXHIBIT B I a EFTA00606612 etc..., computer printouts, prospectuses, financial statements, schedules, affidavits, contracts, cancelled checks, transcripts, statistics, surveys, magazine or newspaper articles, releases (and any and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphs or aural records or representations of any kind, including, without limitation, photographs, charts, graphs, microfiche, microfilm, video tape, recordings, motion pictures and electronic, mechanical or electric recordings or representations of any kind (Including, without limitation, tapes, cassettes, discs and recordings), and including the file and file cover. The term "Document" also means any and all computer records, data, files, directories, electronic mail, and information of whatever kind whether printed out or stored on or retrievable from floppy diskette, compact diskette, magnetic tape, optical or magnetic-optical disk, computer memory, hard drive, zip drive, jaz drive, orb drive, microdisk, external memory stick, software, or any other fixed or removable storage media, including without limitation, all back-up copies, dormant or remnant files, and any and all miscellaneous files and/or file fragments, regardless of the media on which they reside and regardless of whether the data consists in an active file, deleted file, or file fragment. B. "Communications" means any oral or written statement, dialogue, colloquialism, discussion, conversation or agreement. C. "Plaintiff' means L.M. (LM. v. Jeffrey Epstein, Palm Beach County Case #502008CA028051,OOO(MB), E.W. (EVV. v. Jeffrey Epstein, Palm Beach County Case #502008CA028058)OOOO48), Jane Doe (Jane Doe v. Jeffrey Epstein, United States District Court Case #08-cW-80893-MarrafJohnson), and any other person who is or was represented by Rothstein Rosenfeldt & Adler that has not 2 EFTA00606613 yet filed an action against Jeffrey Epstein, and any employee, agent or attorney for any plaintiff and/or any other person acting for or on behalf of any plaintiff, or under her authority and control. D. "RRA' means Rothstein Rosenfeidt & Adler, P.A. E. "Money" means any tangible thing of value. F. "Costs" include, but are not limited to, court costs, filing fees, Sheriffs service and any other necessary service of legal papers or notices or subpoenas, court reporters' charges, long distance telephone charges, postage, courier services or Federal Express or UPS, investigative costs, investigative bills, photocopies, faxes, Westlaw computerized research, travel expenses, and witness fees and expert witness fees and costs. G. "Trustee" means Herbert Stettin as bankruptcy trustee for RRA. REQUEST FOR PRODUCTION' 1. For the time period from March 1, 2009 to present, any and all documents between, or on behalf of RRA, its employees or agents or clients, and any third party regarding a purported settlement of any litigation between Jeffrey Epstein and a RRA client or Plaintiff, or the financing of any litigation between Jeffrey Epstein and a RRA client or Plaintiff, (whether existing clients or fabricated clients), including but not limited to: a. Documents indicating that litigation with Jeffrey Epstein has been settled; b. Soliciting or receiving money in return for settlement funds allegedly paid or to be paid by Jeffrey Epstein; c. Soliciting money to help finance ongoing litigation against Jeffrey Epstein; d. Soliciting money to be given to, or used on behalf of, the Plaintiffs In litigation against Jeffrey Epstein; e. Communication between third party investors or potential investors and the Plaintiffs or their attorneys Involved in litigation against I Due to the potential volume of documents Involved, the parties and the Court should consider appointment of a special master andfor an In camera Inspection to address any objections, claims of privilege and generally manage the production of documents. 3 EFTA00606614 Jeffrey Epstein; 1. Payments made by RRA to or on behalf of any Plaintiff. 2. Any and all fee agreements that exist or have existed between the following: a. Any Plaintiff and Bradley J. Edwards or any entity with which he has been associated; b. Any Plaintiff and the law firm RRA. 3. All emalls, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All emalls, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, and/or any attorney or representative of RRA regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 5. All agreements or documents of any nature which were provided to or received from an investor or potential Investor relating to any case (real or fabricated) involving Jeffrey Epstein and any of the following: a. Scott W. Rothstein b. Bradley J. Edwards c. RRA e. any entity formed by RRA or Bradley J. Edwards or Scott W. Rothstein to create investment opportunities for third party investors to invest In any plaintiffs case against Jeffrey Epstein 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiffs case. 7. All documents made available to any investor or potential investor by Bradley J. Edwards, RRA, Scott W. Rothstein or any of Scott W. Rothstein's entitles to solicit "investors" for any case involving Jeffrey Epstein. B. All document reflecting the names and addresses of all individuals or entities who invested or purported to invest in any aspect of any case against Jeffrey Epstein. 9. All documents evidencing the Costs and payment of any bill or Costs in each Plaintiff's case against Jeffrey Epstein, and the source(s) for said payments of any Costs. 4 EFTA00606615 10. All documents received by you or your current firm wherein the Trustee of RRA has asserted a lien for attorney's fees or Costs arising out of work done and Costs incurred related to the Plaintiffs' cases during the time Plaintiffs' were represented by RRA. 11. All documents and tangible things retrieved from the trash at 358 El Brillo Way, Palm Beach, Florida which is alleged to be the home of Jeffrey Epstein. 12. All conversations recorded from any telephones which purported to be that of Jeffrey Epstein that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions). 13. All conversations recorded from any telephones which purported to be from Jeffrey Epstein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions). 14. All intercepted phone conversations authorized by RRA including but not limited to any one of its attorneys or investigators or anyone retained by or working for RRA related to Jeffrey Epstein that are saved or stored in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions). 15. All Intercepted or acquired electronic mail (e-mails) to or from Jeffrey Epstein authorized by RRA including but not limited to any one of its attorneys or investigators or anyone retained by or working for RRA. 16. All Intercepted or acquired electronic mall (e-mails) to and from the attorneys for Jeffrey Epstein including but not limited to: Roy Black, Alan Dershowitz or Jack Goldberger, authorized by RRA including but not limited to any one of Its attorneys or investigators or anyone retained by or working for RRA. 17. All documents supporting the contention that a sexual assault took place on an airplane purportedly owned by Jeffrey Epstein or a Jeffrey Epstein entity at any time between 1998 and 2005. 18. All documents related to the amount of all Costs that were incurred by you in the representation of you and/or your law firm in representing Jane Doe, L.M. and E.W. prior to joining RRA. 19. All documents setting forth to the amount of Costs were incurred by RRA in Its representation of Jane Doe, L.M. and E.W. during the time you were employed by RRA (or that is being claimed by the Trustee). 20. In the attached transcript dated July 31, 2009, you stated to Judge Hafele with regard to the E.W. and L.M. cases the following: 5 EFTA00606616 "What the evidence is really going to show Is that Mr. Epstein — at least dating back as far as our Investigation resources have permitted, back to 1997 or '98 — has every single day of his life, made an attempt to sexually abuse children. We're not talking about five, we're not talking about 20, we're not talking about 100, we're not talking about 400, which I believe, Is the number known to law enforcement, we are talking about thousands of children, and it is through a very intricate and complicated system that he devised where he has as many as 20 people working underneath him that he is paying well to schedule these appointments, to locate these girls." (A) Provide all documents to support this assertion including any documents which are the source of the information. 21: All documents related to or mentioning potential deponents In the Jane Doe, L.M. or E.W. cases. 22. All documents that support your claim of damages In your counterclaim in this case. 23. The written fee agreement with the Searcy Denney firm for their representation of you in this case. 24. All emalls exchanged between you (or anyone of your behalf) and one or more of the following Individuals wherein Epstein, a Palm Beach billionaire or a similar reference was mentioned: a. Scott Rothstein b. Russell Adler c. William Berger d. Michael Flsten e. Kenneth Jenne f. David Boden g. Deborah Villages h. Andrew Barnett i. Patrick Roberts j. Richard (Rick) Fandrey k. Christina Kitterman. 25. A copy of your RRA business card. 26. Any employment agreements, letter agreements or memos given to you by RRA or a representative or agent of RRA describing your compensation and benefits at RRA. 6 EFTA00606617 27. All documents and communications from Herbert Stettin, as bankruptcy Trustee for RRA, asserting liens against recoveries in: a. b. c. L.M. v. Epstein, Case No. 502008CA028051)OOO(MB E.W. v. Epstein, Case No. 502008CA028058XXXXMB Jane Doe v, Epstein, Case No. 08-CV-80119-MARRA/JOHNSON Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. Mall to the following addressees on this 12th day of April , 2010: Gary M. Farmer, Jr., Esq. Farmer, Jaffe, Weissing, Edwards, Flstos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Attorneys for Defendant, LM. Jack Scarola, Esq. Searcy Denney Scarola Barnhart Shipley, P.A 2139 Palm Beach Lakes Blvd. est Palm Beach, FL 33409 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Co-Counsel for Defendant Jeffrey Epstein MARC S. NURIK, ESQ. & Law Offices of Marc S. Nurik One East Broward Boulevard Suite 700 Fort Lauderdale, FL 33301 Attorneys for Defendant Bradley Edwards Attorneys for Defendant Scoff Rothstein BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 West Pal 33401 (561) 8 (561) Role D. ritton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) 7 EFTA00606618 01/11/2010 18:60 PAX 6616845816 SEARCY DENNBY JEFFREY EPSTEIN, Plaintiff, vs. ®001/o05 onfifro SCOTT ROTHSTEIN, IndNIdually, BRADLEY J. EDWARDS, Individually, and L.M., Individually, Defendant. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 602009CA040800XXXXMBAG DEFENDANT BRADLEY J. EDWARDS RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION DATED APRIL 12, 2010 Defendant BRADLEY J. EDWARDS, hereby files his Response to Request for Production propounded by Plaintiff on April 12, 2010 as follows: 1. None. a. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence. b. None. 3. Objection as to communications to or from investigators as that Is protected by the work-product and /or attorney-client privilege. 4. Objection; any such communications are protected by the work-product and /or attorney-client privilege. 5. None. 6. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence; vague; overbroad, without waiving objection, there are no fee agreements with any investor. EXHIBIT II 9.... EFTA00606619 06/11/2010 16:69 FAX 6616846816 SEARCY DENNEY la 002/005 Can No.: 502009CA040800XXXXMBAG Edwards' Response to Request for Production dated 4/12110 7. None. 8. None. 9. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence. 10. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence. 11. None. 12. None. 13. None. 14. None. 15. None. 16. None. 17. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence; vague; overbroad, ambiguous. 18. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence. 19. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence and protected by the work-product privilege. 20. Objection, vague overbroad and any and all such documents are protected by the work-product privilege. 21. Objection, vague overbroad and any and all such documents are protected by the work-product and attorney-client privilege. 22. Not yet determined. 2 EFTA00606620 05/11/2010 18:00 FAX 6818845618 SEARCY DENNEY O003/005 Case No.: 602009CA040500XXXXMI3AG Edwards Response to Request for Production dated 4/12/10 23. Objection. 24. Objection; attorney-client privilege and/or work-product privilege. 25. Nona in Defendant's possession. 26. None, 27. None in Defendant's possession. 3 EFTA00606621 06/11/2010 16:00 FAX 6618846816 SEARCY DENNEY cp004/006 One No.: 502009CA0408000000ABAO Edwards' Response to Request for Production dated 4/12/10 CERTIFICATE OF SERVIoE I HEREBY CERTIFY that a true and correct copy of the foregoing has been mil) y furnished via U.S. ee Mail to ell counsel on the attached list on #0.- ' 2010. Jack Scarola Searcy Denney Scarola Bamhart & Shipley, P.A. Attorneys for Defendant, Bradley Edwards 2139 Palm Beach Lakes Boulevard West Pakn Beach, Florida 33409 Jack a Flor". a %ar No.: a fle(eo 4 EFTA00606622 05/11/2010 18:00 FAX 6618846818 SEARCY DENNEY ®005/005 Case No,: 602009CAO40800/0X0A8AG Edwards' Response to Request for Production dated 4/12/10 COUNSEL UST Robert D. Critton, Jr., Esquire Michael J. Pike, Esquire Burman, Critton, Luttier & Coleman LLP 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 0 Attorneys for Jeffrey Epstein Jack Goldberger Atterbury, Goldberger & Weiss, PA. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401 Phone: (561)-6594300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Gary M. Farmer, Jr. Farmer, Jaffe, Welssing, Edwards, Fistos & Lehrman, P.L 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Attorneys for L.M. Marc Nurik Law Offices of Marc S. Nurik One East Broward Boulevard, Suite 700 Fort Lauderdale, FL 33301 Counsel for S e n 6 EFTA00606623