EFTA00724396.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL' CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Ha. R. Civ. Pro.1201 Plaintiff, v. Case No. 50 2009CA040800,OOO(MB AG SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. gPSTEIN'S REQUEST TO PRODUCE TO EDWARDS Defendant, JEFFREY EPSTEIN ('Epstein'), pursuant to Fla. R. Civ. P. 1.350, requests that Defendant, BRADLEY J. EDWARDS (*Edwards"), produce or make available for inspection documents responsive to the requests below within thirty (30) days from the date of service: DEFINITIONS AND INSTRUCTIONS A. "Document' means any written or graphic matter or other means of preserving thought or expression, and all tangible things from which Information can be processed or transcribed, including the originals and all non-Identical copies, whether different from the original by reason of any notation made on such copy or otherwise, including, but not limited to, correspondence, memoranda, notes, messages, letters, purchase orders, telegrams, teletype, telefax bulletins, s-mails, electronic data, meetings, reports, or other communications, interoffice and intro-office telephone calls, diaries, chronological data, minutes, books, reports, charts, ledgers, invoices, worksheets, receipts, returns, trade information regarding fabric, carpets, samples EFTA00724396 etc..., computer printouts, prospectuses, financial statements, schedules, affidavits, contracts, cancelled checks, transcripts, statistics, surveys, magazine or newspaper articles, releases (and any and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphs or aural records or representations of any kind, including, without limitation, photographs, charts, graphs, microfiche, microfilm, video tape, recordings, motion pictures and electronic, mechanical or electric recordings or representations of any kind (including, without limitation, tapes, cassettes, discs and recordings), and including the file and filo cover. The term "Document" also means any and all computer records, data, files, directories, electronic mail, and information of whatever kind whether printed out or stored on or retrievable from floppy diskette, compact diskette, magnetic tape, optical or magnetic-optical disk, computer memory, hard drive, zip drive, Jaz drive, orb drive, microdisk, external memory stick, software, or any other fixed or removable storage media, including without limitation, all back-up copies, dormant or remnant files, and any and all miscellaneous files and/or file fragments, regardless of the media on which they reside and regardless of whether the data consists in an active file, deleted file, or file fragment. B. "Communications" means any oral or written statement, dialogue, colloquialism, discussion, conversation or agreement. C. "Plaintiff' means L.M. (LM. v. Jeffrey Epstein, Palm Beach County Case #502008CA028051XXXXMB), E.W. (E.W. v. Jeffrey Epstein, Palm Beach County Case #502008CA028058XXXXMB), Jane Doe (Jane Doe v. Jeffrey Epstein, United States District Court Case #08-civ-80893-Marra/Johnson), and any other person who is or was represented by Rothstein Rosenfeldt & Adler that has not 2 EFTA00724397 yet filed an action against Jeffrey Epstein, and any employee, agent or attorney for any plaintiff andfor any other person acting for or on behalf of any plaintiff, or under her authority and control. D. "RRA' means Rothstein Rosenfeldt & Adler, P.A. E. "Money" means any tangible thing of value. F. "Costs" include, but are not limited to, court costs, filing fees, Sheriffs service and any other necessary service of legal papers or notices or subpoenas, court reporters' charges, long distance telephone charges, postage, courier services or Federal Express or UPS, investigative costs, investigative bills, photocopies, faxes, Westlaw computerized research, travel expenses, and witness fees and expert witness fees and costs. G. "Trustee" means Herbert Stettin as bankruptcy trustee for RRA. REQUEST FOR PRODUCTION' 1. For the time period from March 1, 2009 to present any and all documents between, or on behalf of RRA, its employees or agents or clients, and any third party regarding a purported settlement of any litigation between Jeffrey Epstein and a RRA client or Plaintiff, or the financing of any litigation between Jeffrey Epstein and a RRA client or Plaintiff, (whether existing clients or fabricated clients), including but not limited to: a. Documents indicating that litigation with Jeffrey Epstein has been settled; b. Soliciting or receiving money in return for settlement funds allegedly paid or to be paid by Jeffrey Epstein; c. Soliciting money to help finance ongoing litigation against Jeffrey Epstein; d. Soliciting money to be given to, or used on behalf of, the Plaintiffs in litigation against Jeffrey Epstein; e. Communication between third party investors or potential investors and the Plaintiffs or their attorneys involved in litigation against Due to the potential volume of documents involved, the parties and the Court should consider appointment of a special master andlor an In camera Inspection to address any objections, claims of pdvllege and generally manage the production of documents. 3 EFTA00724398 Jeffrey Epstein; f. Payments made by RRA to or on behalf of any Plaintiff. 2. Any and all fee agreements that exist or have existed between the following: a. Any Plaintiff and Bradley J. Edwards or any entity with which he has been associated; b. Any Plaintiff and the law firm RRA. 3. All emails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (Including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All emalls, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, and/or any attorney or representative of RRA regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 5. All agreements or documents of any nature which were provided to or received from an investor or potential Investor relating to any case (real or fabricated) Involving Jeffrey Epstein and any of the following: a. Scott W. Rothstein b. Bradley J. Edwards c. RRA e. any entity formed by RRA or Bradley J. Edwards or Scott W. Rothstein to create investment opportunities for third party investors to Invest in any plaintiffs case against Jeffrey Epstein 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiffs case. . 7. All documents made available to any investor or potential investor by Bradley J. Edwards, RRA, Scott W. Rothstein or any of Scott W. Rothstein's entities to solicit "Investors" for any case involving Jeffrey Epstein. 8. All document reflecting the names and addresses of all individuals or entities who invested or purported to invest In any aspect of any case against Jeffrey Epstein. 9. AU documents evidencing the Costs and payment of any bill or Costs in each Plaintiffs case against Jeffrey Epstein, and the source(s) for said payments of any Costs. 4 EFTA00724399 10. All documents received by you or your current firm wherein the Trustee of RRA has asserted a lien for attorney's fees or Costs arising out of work done and Costs incurred related to the Plaintiffs' cases during the time Plaintiffs' were represented by RRA. 11. All documents and tangible things retrieved from the trash at 358 El Brillo Way, Palm Beach, Florida which is alleged to be the home of Jeffrey Epstein. 12. All conversations recorded from any telephones which purported to be that of Jeffrey Epstein that are contained In any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions). 13. All conversations recorded from any telephones which purported to be from Jeffrey Epatein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions). 14. All intercepted phone conversations authorized by RRA including but not limited to any one of its attorneys or investigators or anyone retained by or working for RRA related to Jeffrey Epstein that are saved or stored in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions). 15. All intercepted or acquired electronic mail (e-mails) to or from Jeffrey Epstein authorized by RRA including but not limited to any one of its attorneys or investigators or anyone retained by or working for RRA. 18. All Intercepted or acquired electronic mall (e-mails) to and from the attorneys for Jeffrey Epstein including but not limited to: Roy Black, Alan Dershowitz or Jack Goldberger, authorized by RRA including but not limited to any one of its attorneys or investigators or anyone retained by or working for RRA. 17. All documents supporting the contention that a sexual assault took place on an airplane purportedly owned by Jeffrey Epstein or a Jeffrey Epstein entity at any time between 1998 and 2005. 18. AU documents related to the amount of all Costs that were incurred by you in the representation of you and/or your law firm in representing Jane Doe, L.M. and E.W. prior to joining RRA. 19. All documents setting forth to the amount of Costs were incurred by RRA in its representation of Jane Doe, L.M. and E.W. during the time you were employed by RRA (or that is being claimed by the Trustee). 20. In the attached transcript dated July 31, 2009, you stated to Judge Hafele with regard to the E.W. and L.M. cases the following: 5 EFTA00724400 "What the evidence is really going to show is that Mr. Epstein — at least dating back as far as our Investigation resources have permitted, back to 1997 or '98 — has every single day of his Ilfe, made an attempt to sexually abuse children. We're not talking about five, we're not talking about 20, we're not talking about 100, we're not talking about 400, which I believe, is the number known to law enforcement, we are talking about thousands of children, and it is through a very intricate and complicated system that he devised where he has as many as 20 people working underneath him that he is paying well to schedule these appointments, to locate these girls.° (A) Provide all documents to support this assertion including any documents which are the source of the information. 21: All documents related to or mentioning potential deponents in the Jane Doe, L.M. or E.W. cases. 22. All documents that support your claim of damages In your counterclaim in this case. 23. The written fee agreement with the Searcy Denney firm for their representation of you In this case. 24. All emails exchanged between you (or anyone of your behalf) and one or more of the following Individuals wherein Epstein, a Palm Beach billionaire or a similar reference was mentioned: a. Scott Rothstein b. Russell Adler c. William Berger d. Michael Paten e. Kenneth Jenne f. David Boden g. Deborah Vilieges h. Andrew Barnett i. Patrick Roberts J. Richard (Rick) Fandrey k. Christina Kitterman. 25. A copy of your RRA business card. 26. Any employment agreements, letter agreements or memos given to you by RRA or a representative or agent of RRA describing your compensation and benefits at RRA. 6 EFTA00724401 27. All documents and communications from Herbert Stettin, as bankruptcy Trustee for RRA, asserting liens against recoveries in: a. b. c. L.M. v. Epstein, Case No. 502008CA028051)000(MB E.W. v, Epstein Case No. 502008CA028058)00(XMB Jane Doe v. Epstein Case No. 08-CV-80119-MARRA/JOHNSON 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 12th day of April , 2010: Gary M. Farmer, Jr., Esq. Farmer, Jaffe, Welssing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 954-524-2820 954-524-2822 - fax Attorneys for Defendant, LM. Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 686-6300 383-9424 F Attorneys for Defendant Bradley Edwards Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Fax: 561.835-8691 Co-Counsel for Defendant Jeffrey Epstein MARC S. NURIK, ESQ. Law Offices of Marc S. Murk One East Broward Boulevard Suite 700 Fort Lauderdale, FL 33301 954-745-5849 954-745-3556 Fax Attorneys for Defendant Scott Rothstein BURMAN, CRITTON, LUTHER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 West Pal 33401 (561) (561) By: o D. ritton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) 7 EFTA00724402 Will/2010 1$:59 FAX $61.6845810 SF.AECY DENNEY JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, Individually, BRADLEY J. EDWARDS, individually, and L.M., Individually, Defendant. 0001/005 IN THE CIRCUIT COURT OF TIIE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)C<XXMBAG DEFENDANT BRADLEY J. EDWARDS RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION DATED APRIL 12. 2010 Defendant, BRADLEY J. EDWARDS, hereby files his Response to Request for Production propounded by Plaintiff on April 12, 2010 as follows: 1 None. a. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence. b. None. 3. Objection as to communications to or from investigators as that Is protected by the work-product and /or attorney-client privilege. 4. Objection; any such communications are protected by the work-product and /or attorney-client privilege. 5. None. 6. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence; vague; overbroad, without waiving objection, there are no fee agreements with any investor. EFTA00724403 05/11/2010 18:59 FAX 5016845810 SEARCY DENNEY Case No.: 502009CA041)800XXXXMBAO Edwards' Response to Request for Production dated 4/12110 0002/005 7. None. 8. None. 9. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence. 10. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence. 11. None. 12. None. 13. None. 14. None. 15. None. 16. None. 17. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence; vague; overbroad, ambiguous. 18. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence. 19. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence and protected by the work-product privilege. 20. Objec0en, vague overbroad and any and all such documents are protected by the work-product privilege. 21. Objection, vague overbroad and any and all such documents are protected by the work-product and attorney-client privilege. 22. Not yet determined. 2 • EFTA00724404 06/11/2010 18:00 FAX 5818846816 SEARCY DENNEY VI003/005 Case No.: 502009CA040800XXXXMEtAG Edward,' Response to Request for Production dated 4/12/10 23. Objection. 24. Objection; attorney-client privilege and/or work-product privilege. 25. None In Defendants possession. 28. None. 27. None in Defendant's possession. 3 EFTA00724405 08/11/2010 18:00 FAX 8818845810 SEARCYDENIM Case No.: so2oo$CAimoaeoxXXXMHAG Edwards' Response to Request for Production dated 4112/10 tossioes CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been 611c44,Th furnished via U.S. Mail to all counsel on the attached list on IA% In010. Jack Scarola Seamy Denney Scamla Barnhart & Shipley. PA Attorneys for Defendant, Bradley Edwards 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 666-6300 Fax: (561 1 BY: 4-/Ca / %1 Jack tar No.: atter° 4 EFTA00724406 05711/2010 16:00 FAX 5616665616 SEARCY DENNEY Case No.: 502000CA040800XXXXMBAG Edwards' Response to Request for Production dated 02/10 COUNSEL LIST Robert D. Critton, Jr., Esquire Michael J. Pike, Esquire Burman, Critton, LutUer & Coleman LLP 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 Phone: (561)-842-2820 Fax: (561)-844-8929 Attorneys for Jeffrey Epstein Jack Goldberger Atterbury, Goldberger & Weiss, PA. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659.8300 Fax (561)-835-8691 Attorneys for Jeffrey Epstein Gary M. Farmer, Jr. Fanner, Jaffe, WelssIng, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (964) 524-2822 Attorneys for L.M. Marc Nurik Law Offices of Marc S. Nurik One East Broward Boulevard, Suite 700 Fort Lauderdale, FL 33301 Phone: 954-745-5849 Fax: 954-745-3556 Counsel for Scott Rothstein 6 e005/006 EFTA00724407