EFTA00722339.pdf

09/16/2010 14:44 FAX SEARCY DENNEY liDoovoo4 #291874/mep JEFFREY EPSTEIN, Plaintiff(s), SCpTT ROTHSTEIN, individually, B LEY J. EDWARDS, individually, and L.M., individually, I Defendant(s). I / IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXM BAG DEFENDANT/COIJNTERPLAINTIFF'S REOUEST TO PRODUCE TO PLADITIFF/COUNTERDEFENDANT, JEFFREY EPSTEIN Defendant/Counterplaintiff, Bradley J. Edwards ,by and through his undersigned counsel, recuests, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that PlIntifUColuiterdefendant, Jeffrey Epstein, produce and permit Bradley J. Edwards to inspect and copy each of the following documents*: 1. All statements of the Defendant, Bradley J. Edwards, pertaining to any of the issues in this lawsuit 2. All statements of any witness you intend to use at trial for impeachment. 3. All documents* including but not limited to diaries, journals, computer database =lends or any other written or electronically stored information that reflect or relate to any communication to or from minor females and/or any physical contact which did or was planned to bccur between you and any person who was a minor female" at the time of the physical cotdact or planned physical contact including but not limited to any massage, fondling, or sexual EFTA00722339 09/10/2010 14:44 FAX SEARCY DENNEY U1002/004 s adv. Epstein No.: 302009CA040800XXXXMBAG Request to Produce to Jeffrey Epstein interaction of any kind (this should include all message pads or appointment scheduler for minor feriales"). 4. All written documents supporting the allegations in your complaint. 5. All message pads, calendars of your schedule or appointments or other documents containing your "massage" appointments; and 6. A complete copy of each and every exhibit which you intend to introduce or have considered introducing into evidence at trial. "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 corlimilations 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. "Dtcuments" 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. It is requested that the aforesaid production be made within thirty days of service of this request at the offices of Searcy Denney Scarola Barnhart & Shipley, M., 2139 Palm Beach - "minor females" is defined as females who were known by you at the time or who are now !mown to you to have beed under 18 yearn of age at the time of your interaction with diem, and females who you now bavc mason to believe may have been under 18 years of age at the time of your interaction with them. 2 EFTA00722340 09/16/2010 14:45 FAX SEARCY DENNEY lib003/004 Edwards adv. Epstein Case No.: 502009CA040800=0CMBAG Request to Produce to Jeffrey Epstein Lakes Boulevard, West Palm Beach, Florida. Inspection will be made by visual observation, examination and/or copying. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Fax and U.S. Mail to all Counsel on the attached list, th 110.1)—day of la `• Bar No.: 169440 cy Denney Scarola Barnhart & Shipley 139 Palm Beach Lakes Boulevard West Palm Beach. Florida 33409 Phone: Fax: Attorneys for 2010. 3 EFTA00722341 09/16/2010 14:45 FAX SEARCY DENNEY in004/004 Edwards ' adv. Epstein Ca+ No.: 502009CA040800,OOOCM:BAG Request to Produce to Jeffrey Epstein COUNSEL LIST Jack A. Goldberger, Esquire Attetbury, Goldberger & Weiss, M. 25C Australian Avenue South, Suite 1400 Wet Palm Beach, FL 33401 PFac iliar Carp? M. Farmer, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Le an, PL 42 N. Andrews Avenue, Suite 2 Fo Lauderdale FL 33301 Phone: Pale Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale FL 33301 Phcine: Fax: Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. Fovher White Burnett, PA. 777. S Flagler Drive, Suite 901 West Palm Beach FL 33401 Phone: Fax' 4 EFTA00722342