EFTA00724373.pdf

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla.R.Civ.Pro. 1.201 Case No. 502009CA040800XXXXMBAG Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, Individually, BRADLEY J. EDWARDS, Individually, and L.M., Individually Defendants/Counter-Plaintiffs. PLAINTIFF, JEFFREY EPSTEIN'S NOTICE OF PROPOUNDING FIRST SET OF EXPERT WITNESS INTERROGATORIS AND REQUEST TO PRODUCE EXPERT REPORTS TO DEFENDANT/COUNTER-PLAINTIFF, BRADLEY J. EDWARDS PlaintifOCounter-Defendant, Jeffrey Epstein, by and through his undersigned counsel, and pursuant to the Florida Rules of Civil Procedure, files this his Notice of Propounding First Set of Expert Witness Interrogatories and Request to Produce Expert Reports directed to Defendant/Counter-Plaintiff, Bradley J. Edwards' numbered I through 13 and Request to Produce Expert Reports numbered 14-16 to respond to within the time prescribed by the Fla.R.Civ.Pro.. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true id correct copy of the foregoing has been duly furnished via O Email, el Facsimile, 34I.S. Mail, O Hand Delivery, O Federal Express this ay of November, 2010 to: Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 EFTA00724373 Epstein y. Rothstein, et al. 2 Case No. 50 2009 CA 040800XXXXMBAG Epstein's NOS of Expert Int to Edwards and RTP Experts Reports Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 Joy L. Acke Jr. 14 3 6± Fla. Bar No. 235954 FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Attorneys for Jeffrey Epstein, Plaintiff/ Counter-defendant EFTA00724374 Epstein v. Rothstein, et al. Case No. 50 2009 CA 040800XXXXMBAG Epstein's NOS of Expert Int to Edwards and RTP Experts Reports EPSTEIN'S EDWARDS EXPERT INTERROGATORIES TO EDWARDS & RTP EXPERT REPORTS 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. 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 lien thereof, please provide a copy of each expert's most recent curriculum vitae. 3. Give the name or title of each paper which each expert has authored in the field of his/her expertise. 4. State the name, volume and page number of the publication in which each article or paper listed above can be found. 3 EFTA00724375 Epstein v. Rothstein, et al. Case No. 50 2009 CA 0408003OOO(MBAG Epstein's NOS of Expert Int to Edwards and RTP Experts Reports 5. State the substance of the facts to which each expert listed is expected to testify. 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. 7. State the opinion to which the experts aforementioned are expected to testify. 8. Give a summary of the grounds of each opinion stated. 4 EFTA00724376 Epstein v. Rothstein, et al. Case No. 50 2009 CA 0408003OOOCMBAG Epstein's NOS of Expert Int to Edwards and RTP Experts Reports 9. Has the expert listed above practiced or worked in his/her field during the past five years? 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? 5 EFTA00724377 Epstein v. Rothstein, et al. 6 Case No. 50 2009 CA 040800XXXXMBAG Epstein's NOS of Expert Int to Edwards and RTP Experts Reports 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? a. If so, state the date the report was submitted. b. The name or other means of identification of the person to whom this report was submitted. c. The name and address of the person who has present custody of the report. 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? a. If so, state description of each report that was made. b. the date that each report was made. c. The name or other means of identification of the person to whom each report was submitted. d. The name and address of the person who has present custody of said report. EFTA00724378 Epstein v. Rothstein, et al. Case No. 50 2009 CA 040800)OOO(MBAG Epstein's NOS of Expert Int to Edwards and RTP Experts Reports EPSTEIN'S REQUEST TO PRODUCE EXPERT REPORTS TO EDWARDS 14. Attach a copy of any reports made by each expert on the basis of his/her tests, examinations or analyses to your answers to these Interrogatories. 15. Is the expert to be compensated for his/her work and efforts in connection with this action? a. If so. How much is the expert to be paid? b. If the expert has been paid, then give the basis for payment, such as hourly rate, weekly rate, etc. 16. Has the expert served as an expert witness in any other litigated case in the past three years? a. The style of the case, the Court in which it was filed and the names and addresses of the attorneys involved. b. Whether the expert testified for the Plaintiff or Defendant. c. the area or field in which the expert held himself/herself out to be an expert. 7 EFTA00724379 State of County of Epstein v. Rothstein, et al. Case No. 50 2009 CA 040800XXXXMBAG Epstein's NOS of Expert Int to Edwards and RTP Experts Reports The foregoing instrument was acknowledged before me this day of 2010 by , who is personally to me or who has produced as identification and who did did/not take an oath. (SEAL) (Notary Signature) (Print Notary Name) Notary Public, State of (Serial Number, if any) 8 EFTA00724380