EFTA00722353.pdf

09/16/2010 15:13 FAX SEARCY DENNEY lit 001/008 #21874/mep JEFFREY EPSTEIN, Plaintiff, vs. S TT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 502009CA040800XXXXMBAG DEFENDANT/COUNTERPLAINTIFF BRADLEY J. EDWARDS' REQUEST FOR. I ADMISSIONS AND INTERROGATORY TO PLAINTIFF/COUNTERDEFENDANT JEFFREY EPSTEIN COMES NOW, the Defendant/Counterplaintiff, BRADLEY J. EDWARDS, by and thMugh his undersigned counsel, and files this, his Request for Admissions to the Plaintiff'Counterdefendant, JEFFREY EPSTEIN, and requests that PlaintiffiCountenlefendant admit or deny the following facts, in accordance with Rule 1.370, Fla.R.Civ.P.: ADMISSIONS 1. You have acted on a sexual preference for minor females' on multiple occasions over the course of at least the last decade. 2. You have engaged in sexual activity" with more than forty minor girls between 2002 and 2006 in your residence in West Palm Beach, Florida. I °tor females- is defined as females who were known by you at the time or who are now known to you to have beet under 18 years of age at the time of your interaction with them, and females who you now have reason to believe may have been under 18 years of age at the time of your Interaction with them. esitxua I activity' for purposes of these interrogatories means any physical contact with the genitals or exposed brerists of another person. EFTA00722353 09/16/2010 15:14 FAX SEARCY DENNEY Ii9002/006 Edwards adv. Epstein Request for Admissions to Epstein 3. Among the minor females with whom you have engaged in sexual activity bet[.veen 2002 and 2006 was a person identified in a civil suit filed against you as: a. Jane Doe b. I c. i 4. You paid to engage in sexual activity with minor females between 2002 and 2006, including the following persons identified in legal pleadings as: and: a. Jane Doe b. C. 5. When you engaged in sexual activity with minor females between 2002 and 2006, you knew or had substantial reason to believe at the time that they were wider the age of 18. 6. A document maintained by your employee, Mr. Alfredo Rodriguez, contains the names of dozens of minor girls with whom you had sexual relations and sexual interaction in West Palm Beach, New York, New Mexico, California, Michigan, the Virgin Islands and/or Paris, France including: a. Jane Doe 2 EFTA00722354 09/1e/2010 15:14 FAX SEARCY DENNEY gl 003/008 Ethkards adv. Epstein Request for Admissions to Epstein b. c. 7. You socialized with minor females in the presence of Donald Trump, Alan De ;Ishowitz, Bill Clinton, Tommy Manta, David Copperfield, and Bill Richardson. 8. You have transported on your airplanes minor females with whom you have engaged in sexual activity. 9. You engaged in the act of trafficking minors across state or country borders for the !purpose of sex or prostitution between 1997 and the present. 10. You filed an intentionally frivolous lawsuit against Bradley J. Edwards for the purpose of deterring his prosecution of claims against you. 11, The purpose of you filing the lawsuit against Bradley J. Edwards or ■ was to indlice the settlement of pending civil lawsuits against you. 12. You made allegations in your Complaint against Bradley J. Edwards knowing at the llme that you bad no good faith basis to believe the allegations were true. I 13. Since 2006, knowing that significant civil lawsuits would be filed against you, youlhave transferred assets with a total value in excess of $10 million with the intent to defeat the lability of the civil litigants who had filed suits against you to collect on any judgments they might obtain. 3 EFTA00722355 09/16/2010 15:14 FAX SEARCY DENNEY el 004/008 Edwards adv. Epstein Request for Admissions to Epstein 14. You are currently in the process of transferring assets with the intent to defeat the ability of Bradley J. Edwards, Esq. to collect any judgment he might obtain on his counterclaim ag4inst you in this lawsuit. 15. You have retitled and continue to retitle assets that you own directly or indirectly (including vehicles, vessels, and airplanes) in the name of other individuals to conceal those assets from potential judgment creditors. I 16. When civil lawsuits were filed against you by Jane Do; andM, you knew that the lawsuits would likely result in substantial judgments against you if they proceeded to trial. 17. When you filed your suit against Bradley J. Edwards in this case, you knew that you had engaged in sexual activity with the minor females he was representing and that it was likely you would be found civilly liable to them for substantial compensatory and punitive daMages if their claims proceeded to trial. 18. On or before July 1, 2010, you arranged for a private investigator to 19. The private investigator hired by you to conduct surveillance on Jane Doe 20. When you filed this lawsuit against Bradley J. Edwards, you knew that it had no basils in fact. 4 EFTA00722356 09/18/2010 15:16 PAZ SEARCY DENNEY Q005/008 Edwards adv. Epstein Request for Admissions to Epstein 21. When you filed this lawsuit against Bradley J. Edwards, you knew that there was no evidence that he was involved in any &Ise statements that may have been made by Scott Rothstein concerning lawsuits against you. 22. Bradley J. Edwards never made any false statements of fact to you. 23. All attorneys' fees and costs incurred by you to defend against lawsuits filed against you byl , Jane Doe, and other minor females with whom you engaged in sexual activity were incurred because you chose to defend against claims which you knew to be meritorious. 24. Lacking any substantive defense to the sexual assault claims filed against you by Jane Doe, and other minor females, you sought to avoid your compensatory and punitive liability by employing your fmancial resources to intimidate your victims into atnindoning their legitimate claims or resolving those claims for substantially less than their just value. 25. You have no personal and direct knowledge that Bradley J. Edwards engaged in any unethical, illegal or improper conduct. , 26. You filed your complaint in this case alleging that Bradley J. Edwards was a lmtiwing participant in a civil theft and criminal enterprise when you were well aware that there was no admissible evidence to support such false assertions. 27. Your goals in filing this lawsuit included harassing Bradley J. Edwards, causing injury to his reputation, interfering with his professional relationships, and causing him to divert 5 EFTA00722357 09/16/2010 15:15 FAX SEARCY DENNEY W1006/006 EdWards adv. Epstein Request for Admissions to Epstein time and attention away from effectively representing ad Jane Doe in their lawsuits against you. 28. Unless substantial punitive damages are awarded against you, you will continue to filelmeritless lawsuits like the one you filed against Bradley J. Edwards and to deter other minor females with whom you have engaged in sexual activity from collecting damages from yoti. I 29. Because of your vast wealth, unless a jury awards more than $10 million in punitive damages against you, it will have no affect on your behavior. INTERROGATORY 30. If your response to any of the Requests for Admissions previously submitted was otlitz than an unqualified admission, state for each such request for admission the following: a. All facts (not opinions) that you contend support in any manner your refusal to admit or your qualified admission. b. Identify all documents, notes, reports, memoranda, electronic and/or tape recordings, photographs, oral statements, or any other tangible or intangible thing that supports in any manner your refusal to admit or your qualification of your admission, Identification is to be sufficient to identify the aforesaid things in a request for production. c. The name and address of a custodian of all tangible or intangible things identified in response to (b) above. d. The name and address of all persons, including consultants, purporting to have any knowledge or factual data upon which you base your refusal to admit or the qualification of your admission. The purpose of the interrogatory is to have you reveal everything presently known by you that bears on your refusal to admit or your qualification of your admission. The propounding parties at the time of trial will move the court for an order excluding from evidence all tangible or intangible things known to you at the time of your response to these requests for admissions and interrogatories not disclosed in your responses thereto. 6 EFTA00722358 09/16/2010 15:15 FAX SEARCY DENNEY Q9007/008 Edwards adv. Epstein Request for Admissions to Epstein I HEREBY CERTIFY that a true copy of the foregoing was flunished by Fax and U.S. Mail to all counsel on the attached list on this' ir day of 2010. JAC AROLA Fl • Bar No. 169440 y Denney Scarola Barnhart & Shipley 39 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Phone: Fax: Attorneys for ra ey . wards 7 EFTA00722359 00/16/2010 15:16 FAX SEARCY DENNEY RI008/008 Ethjards adv. Epstein Case No. 502009CA040800)OOCMBAG Jac& A Goldb Es uire COUNSEL LIST A rbury, Goldberger eiss, PA. 250 Australian Avenue South, Suite 1400 Wit P lm Beach FL 33401 Phone: Attiorneys for Jeffrey Epstein Gary M. Fainter, Esq. Farkner, Jaffe, Weissing, Edwards, Elms & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 Fa*: Pho • Christopher E. Knight, Esq. Jodpph L. Ackerman, Esq. Fowler White Burnett, P.A. 777 S Flagler Drive, Suite 901 West Pain Beach.FL 33401 Phone: FaX: Attorneys for Jeffrey Epstein Marc S. Nurik, Esq. La‘ Offices of Marc S. Nurik Ong E Broward Blvd., Suite 700 Foit La 301 Phone: Fax: Atiomeys for Scott Rothstein 3 EFTA00722360