EFTA00617113.pdf

Filing # 56943818 E-Filed 05/25/2017 03:20:22 PM 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 ■l., individually, Defendant, MOTION TO EXPAND INTERROGATORIES Bradley J. Edwards, by and through the undersigned counsel, moves this Honorable Court pursuant to the provisions of Rule I.340(a), Florida Rules of Civil Procedure, to increase the number of initial interrogatories permitted herein so as to allow for the filing of two sets of additional interrogatories in accordance with those attached, and in support of this motion, Bradley J. Edwards would show: 1. The Supreme Court has not approved a form of interrogatories for this type of action. 2. The elements of the claims asserted and the nature and complexity of the factual circumstances giving rise to the claims are not susceptible to being adequately covered within the twenty-five (25) interrogatory limit. 3. The elements of defenses asserted or expected to be asserted are not susceptible to being adequately covered within the twenty-five (25) interrogatory limit. Two sets of additional interrogatories are attached. EFTA00617113 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Edwards' Motion to Expand Interrogatories Page 2 of 3 4. The use of written interrogatories is the least burdensome, least expensive and most expeditious discovery means available to the Defendant by which to obtain necessary information and narrow trial issues. 5. The Plaintiff will not be prejudiced through the granting of this motion. 6. The foregoing factors and others to be presented upon hearing of this Motion constitute good cause for increasing the number of interrogatories permitted herein. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to all counsel on the attached list, thi day of May, 2017. a ar No.: 169440 Denney Scarola Barnhart & Shipley, M. 9 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for Defendant EFTA00617114 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Edwards' Motion to Expand Interrogatories Page 3 of 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. Goldberger, Atterbury Goldberger & Weiss, M. 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Bradley J. Edwards, uire Fanner Jaffe Weissing Edwards Fistos & Lehrman, 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. Nurik, Es Esquire One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein EFTA00617115 FACT WITNESS INTERROGATORIES TO JEFFREY EPSTEIN As to every individual identified on Jeffrey Epstein's List of Trial Witnesses, state the following: 1. Each contested factual issue expected to be addressed by the witness; ANSWER: 2. A detailed description of the testimony expected to be presented at trial by the witness as to each contested factual issue; ANSWER: 3. A description of the Trial Exhibit List number of each exhibit expected to be introduced into evidence by the witness; ANSWER: 4. A description of the Trial Exhibit List number of each exhibit introduced through other means which the witness is expected to testify about, together with a description of the witness' expected testimony regarding each exhibit; ANSWER: EFTA00617116 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Bradley J. Edwards Fact Wimess Interogs to Epstein Page 2 of 5 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) 2 EFTA00617117 EFTA00617118 NET WORTH NTERROGATORIES TO JEFFREY EPSTEIN 1. What is your full name? 2. How are you currently employed? 3. State the amount of your current salary and describe all additional benefits of employment including bonuses, allowances, pension and profit sharing participations, stock options, deferred compensation, insurance benefits and other prerequisites of your employment including the dollar amount or dollar value of each during the twelve months preceding your receipt of these interrogatories. 4. If you own or have any beneficial interest in any stocks, bonds, mutual funds, or other securities of any class in any government, governmental organization, company, firm or corporation, whether foreign or domestic, please state: (a) The name and address of the entity in which you own or have any beneficial propriety or security interest of any sort; EFTA00617119 Case No.: 502009CA040800XXXXMBAG Notice of Serving Net Worth Interrogatories (b) The serial number of each bond, share, stock certificate or other evidence of ownership or security; (c) The current fair market value of each such interest; (d) The manner in which such value was calculated. 5. As to each federal income tax return filed by you or on your behalf for the years 2011 through and including 2016, identify as specifically as identified in your tax return the source of all reported income and the separate amounts derived from each source 6. For each parcel of real property in which you hold any interest, state: (a) The address, 2 EFTA00617120 Case No.: 502009CA040800XXXXMBAG Notice of Serving Net Worth Interrogatories (b) The legal description of the property; (c) The assessed value of the property for tax purposes; (d) The date and price of acquisition; (e) Whether, when, and at what amount the property has been appraised since the time of purchase; (0 Whether, when, and at what price the property has been offered for sale since the time of purchase; 3 EFTA00617121 Case No.: 502009CA040800XXXXMBAG Notice of Serving Net Worth Interrogatories (g) The name and address of each real estate agent with whom the property has been listed for sale since the time of purchase; (h) The cost of any improvements made to the property since purchase; (i) The nature of your interest in the property. 7. List each item and state the estimated value of all personal property in which you have an interest which personal property was acquired at a cost in excess of $5,000 or which personal property has an estimated present value in excess of $5,000, and as to each state: (a) The date of acquisition; (b) The cost of acquisition; 4 EFTA00617122 Case No.: 502009CA040800XXXXMBAG Notice of Serving Net Worth Interrogatories (c) The current estimated fair market value; (d) The manner in which the fair market value was estimated. 8. If any of the real or personal property owned by you, either individually, jointly or otherwise, is encumbered by either a real estate mortgage, chattel mortgage, or any other type of lien, then for each item of property, state a description of the nature and amount of the encumbrance, the date the encumbrance arose, whether the encumbrance is evidenced by any written document and, if so, a description of that document. 9. If you have an ownership interest in any businesses, for each business state: (a) The name and address of the business; 5 EFTA00617123 Case No.: 502009CA040800XXXXMBAG Notice of Serving Net Worth Interrogatories (b) The present book value and the present market value of your interest in the business, and its percentage of the total value of the business; (c) A description of the manner in which the stated fair market value was calculated. 10. Identify all banks, credit union and savings and loan accounts, in which you have an interest or right of withdrawal and for each account state: (a) Where the account is located; (b) The highest and lowest balance in the account during the 40 day period immediately preceding your receipt of these interrogatories. 6 EFTA00617124 Case No.: 502009CA040800XXXXMBAG Notice of Serving Net Worth Interrogatories 11. Identify all other assets of a value in excess of $5,000 which assets were not previously identified and as to each state: (a) The date of acquisition; (b) The cost of acquisition; (c) The current estimated fair market value; (d) The means utilized to estimate the current fair market value. 12. Identify all other liabilities not previously identified and as to each state: 7 EFTA00617125 Case No.: 502009CA040800XXXXMBAG Notice of Serving Net Worth Interrogatories (a) The date the liability arose; (b) The amount of the liability at inception; (c) The terms of repayment or satisfaction; (d) The current outstanding balance. 13. State your year end net worth for each of the past 5 years and your best estimate of your present net worth. 8 EFTA00617126 Case No.: 502009CA040800XXXXMBAG Notice of Serving Net Worth Interrogatories 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) 9 EFTA00617127