EFTA00724081.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50 2009CA040800)OO<XMB AG JEFFREY EPSTEIN Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. EPSTEIN'S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO EDWARDS' REQUEST TO PRODUCE Plaintiff, JEFFREY EPSTEIN ("Epstein"), pursuant to Fla. R. Civ. P. 1.090(b), moves for an enlargement of time to respond to Defendant/Counter-Plaintiff, Bradley J. Edwards' ("Edwards") Request to Produce and states: 1. On March 18, 2010, Edwards served Epstein with a Request to Produce (attached as Exhibit A). 2. As the Request to Produce was served via U.S. Mail only, Epstein's response to thereto is currently due on or before April 22, 2010 3. The first request seeks documents upon which Epstein relies in support of his claim for damages against Edwards, including all agreements with attorneys, invoices for attorney services, time records, and documents related to expenditures. See Exhibit A. 4. The second request seeks prescriptions for corrective lenses. See Exhibit A. Epstein has no objection to said request and is attaching the responsive document as Exhibit B. EFTA00724081 5. Epstein requests a thirty (30) day enlargement of time to respond to the first request in Edwards' Request to Produce. Epstein's counsel is currently reviewing documents potential responsive to Edwards' first request and determining all applicable objections including work product and attorney-client privilege. In addition, to the extent Epstein may produce documents responsive to Edwards' first request, his counsel needs additional time to redact any such documents to preserve attorney-client and work product privileges. 6. This action is set for trial on the Court's October 25, 2010 docket and Edwards will not be prejudiced by the requested enlargement of time. WHEREFORE, Plaintiff, JEFFREY EPSTEIN, pursuant to Fla. R. Civ. P. 1.090(b), requests the Court grant a thirty (30) day enlargement of time to respond to Defendant/Counter-Plaintiff, Bradley J. Edwards' Request to Produce and grant any additional relief the Court deems just and proper. Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. Mail to the following addressees on this 20th day of April , 2010: Gary M. Farmer, Jr., Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 - fax Attorneys for Defendant, L.M. Jack Scarola, Esq. Searcy Denney Scarola Barnhart Shipley, P.A 2139 Palm Beach Lakes Blvd. West 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 Fax: Co-Counsel for Defendant Jeffrey Epstein Law Offices of Marc S. Nurik & Counsel to Scott Rothstein One East Broward Boulevard, Suite 700 Fort Lauderdale, FL 33301 2 EFTA00724082 F Attorneys for Defendant Bradley Edwards BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 ch. FL 33401 ax By: D Florida Bar Michael J. Pike Florida Bar (Counsel for Defer", Epstein) 3 EFTA00724083 IN TILIE CIRCUIT COURT OF .-THE 1.11. LEENTH JUDICIAL aRcuTr, ni AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800X3OCCIvIBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. DEFENDANT/COUNTERPLAINTIFF'S REQUEST TO PRODUCE TO JEFFREY EPSTEIN Defendant/Counterplainliff Bradley J. Edwards by and through the undersigned counsel, request, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that Plaintiff Jeffrey Epstein, produce and permit to inspect and copy each of the following documents•: *"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 compilations 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. "Documents" also include all electronic data as well as application metadata and system metadata. All inventories and rosters of your infonnation 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. EXHIBIT EFTA00724084 It is requested that the aforesaid production be made within thirty (30) days of service of this request at the offices of Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida. Inspection will be made by visual observation, examination and/or copying. 1. All documents* upon which the Plaintiff does or may rely in support of his claim for damages against the Defendants, including but not limited to: a. All agreements with attorneys, the payment of whose services are alleged as an element of damages; b. MI invoices for attorney services and costs alleged as an element of damages; c. All time records reflecting services rendered, the payment for which is alleged as an element of damages; d. Every cancelled check, receipt, ledger entry, and other document of whatever kind or description reflecting, referencing, evidencing, or relating to every expenditure by you or on your behalf which expenditure is alleged as an element of damages. 2. Any and all prescriptions for corrective lenses issued to you within the past five (5) years. 2 EFTA00724085 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, this 21:1- 1-- day of March 2010. la ar No.: 169440 y Denney Scarola Barnhart & Shipley, P.A. 39 Palm Beach Lakes Boulevard West Palm Reach Florida 33409 Phone Fax: Attorney or a en an Counterplaintiff BRADLEY I. EDWARDS 3 EFTA00724086 COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West P 3401 Phone: Fax: Attorneys ore pstein Robert D. Critton, Jr., Esquire Burman, Critton, Luther & Coleman LLP 303 Banyan Boulevard, Suite 400 West P 401 Pho Fax: Attorneys for Jeffrey Epstein . ,.4-• Gary M. Farmer, Esq. Farmer, Jaffe, Weissing, et al 425 N. Andrews Avenue, Suite 2 Fort 01 Phone Fax: Attorneys • r e en t, LM. Law Offices of Marc S. Nurik One East Broward Boulevard, Suite 700 Fort L 01 Phone: Fax: Counse or cots o em 4 EFTA00724087 The Eye Center DR. ROBERT A. DAVIS DR. JAMES E. MORRIS DR. ARNOLD M. SEMEL DR. STEPHANIE N. DAVIS DR. LAN NGUYEN OPTOREYNC airman Ira UNNERSVIY DRIVE PENENCOCE PMES. FLORIN 93024 TELEPHONE: (954)424711 It:I JO FOR c ) : 5 1 ADDRESS 20 0.0..W16—a514 (3i cp.a.5"-- to k r?e.n MORRIS EL 0000171 0000228 es-00 era a5 S. DAVIS L. NGUYEN 0003705 D-5 OLtPl 015bi/ice_ EXHIBITIL EFTA00724088