EFTA00704664.pdf

#291874/mep JEFFREY EPSTE1N, Plaintiff(s), VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG NOTICE OF ERVING ANSWERS TO FIR SE OF EXPERT WITNESS REQUEST TO PROD , E COMES NOW the Defendant/Counterplaintiff, Bradley J. Edwards, by and through his undersigned counsel, and hereby files this Notice with the Court that Answers to the First Set of Expert Interrogatories propounded by the Plaintiff Jeffrey Epstein, on November 4, 2010, have been furnished to the attorney for the Plaintiff. 1°) I HEREBY CERTIFY that a true copy of the foregoing has been furnished by mail this A 2nd day of December, 2010 to all counsel ed list. JACK OLA Flori'" No.: 169440 ey Scarola Barnhart & Shipley, In 2 Palm Beach Lakes Boulevard est Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorney for Bradley J. Edwards EFTA00704664 Edwards adv. Epstein Case No.: 502009CA040800)OOOO4BAG Edwards' Answers to Expert Interrogatories ANSWERS TO INTERROGATORIES 1. State the name, address and profession of each person whom you expect to call as an Expert witness at trial or for any other purposes in this cause. Answer. Bradley Edwards has not retained any experts at this time. However, it is expected that some or all of the attorneys who have prosecuted civil claims against Jeffrey Epstein arising out of his abuse of children will be called to testify on behalf of Edwards and may express opinions regarding the services rendered by Edwards on behalf of his clients. 2. With regard to each listed above, state his/her background, education and experience which qualify him/her to testify as an expert in his/her area of expertise; and/or in lieu thereof, please provide a copy of each expert's most recent curriculum vitae. Answer. N/A 3. Give the name or title of each paper which each expert has authored in the field of his/her expertise. Answer. N/A 4. State the name, volume and page number of the publication in which each article or paper listed above can be found. Answer. N/A 5. State the substance of the facts to which each expert listed is expected to testify. Answer: N/A 2 EFTA00704665 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Edwards' Answers to Expert Interrogatories 6. Give a complete list of all documents, depositions, exhibits, plans, drawings, ordinances or statutes which each expert has used in basing his/her opinion. Answer. N/A 7. State the opinion to which the experts aforementioned are expected to testify. Answer. N/A 8. Give a summary of the grounds of each opinion stated. Answer. N/A 9. Has the expert listed above practiced or worked in his/her field during the past five years? Answer: N/A 10. If so, please state: a. Whether the expert was self-employed, employed by someone else or associated as a partner b. Each address where the expert practiced or was employed c. The dates the expert was with each employer d. The type of duty the expert performed with each employer 11. If the expert was not practiced or worked in his/her field during the last five years, what was his/her employment during this time? Answer: N/A 3 EFTA00704666 Edwards adv. Epstein Case No.: 502009CA040800)OOOO4BAG Edwards' Answers to Expert Interrogatories 12. Did the expert submit a report setting forth his/her opinions or conclusions reached from his/her examination or any tests he/she conducted? Answer: N/A 13. Did the expert submit any other reports based upon tests, examinations or analysis of documents that he/she conducted in which he/she did not render an opinion? Answer. N/A 14. Attach a copy of any reports made by each expert on the basis of her/her tests, examinations or analyses to your answers to these Interrogatories. Answer. N/A 15. Is the expert to be compensated for his/her work and efforts in connection with this action? Answer. N/A I6. Has the expert served as an expert witness in any other litigated case in the past three years? Answer. N/A 4 EFTA00704667 Edwards adv. Epstein Case No.: 502009CA040800)OOOCMEIAG Edwards' Answers to Expert Interrogatories Signs f Answering Party STATE OF ) COUNTY OF ) Croele-W The foregoing instrument was acknowledged before me this C7d11 day of ,))mmther- , 20 /0 by\ //R A' reselgo(4- who is personally known to me et- who has- produced (type- o€—identification) as- -ideatifizationand who did/did-not take an oath. Not Publi Sta e of Florida tlr,Large My Commission expires: Commission No: 5 EFTA00704668 Edwards adv. Epstein Case No.: 502009CA040800XXXXM13AO Edwards' Answers to Expert Interrogatories COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, M. 250 Australian Avenue South, Suite 1400 West Palm Beach FL 33401 Pho Fax: Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phon Fax: Joseph L. Ackerman, Jr. Esquire Fowler White Burnett, M. 901 Phillips Point West 777 S Flagler Drive West Palm Beach, FL 33401-6170 Fax: : Fax:( Marc S. Nurik Esquire Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale. FL 33301 Phon Fax: EFTA00704669