EFTA00724410.pdf

14:40 NOV 22. 2010 FAX NO: 1234567 *67493 PAGE: 2/11 #291874/mep JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)ODOCKBAG NOTICE OF PROPOUNDING EXPERT INTERROGATORIES TO PLAINTEFF/COUNTERDEFENDANT, JEFFREY EPSTEIN Defendant/Countexplaintiff, Bradley J. Edwards, hereby gives notice that pursuant to Rule 1.340(e), Florida Rules of Civil Procedure, Expert Interrogatories numbered 1 through 16 have been directed to Plaintiff/Counterdefendant, Jeffrey Epstein, this a Niday of 41111)4/11/49JA , 2010. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by #1 Fax and U.S. Mail to all Counsel on the attached list on this 00 day of VeAtefill-k,-- 2010. Jack S Ia Flo ar No.: 169440 S Denney Scarola Barnhart & Shipley, P.A. 9 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorney for Bradley J. Edwards EFTA00724410 14:41 NOV 22, 2010 FAX NO: 1234567 167493 PAGE: 3/11 Edwards adv. Epstein Case No.: 502009CA040800XXXXIABAG Expert Interrogatories To Jeffrey Epstein COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 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. Fanner, Esq. Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. Fowler White Burnett, P.A. 777 S Flagler Drive, Suite 901 West Palm Beach, FL 33401 Phone: (561)-802-9044 Fax: (561)-802-9976 Attorneys for Jeffrey Epstein Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein EFTA00724411 14:42 NOV 22, 2010 FAX NO: 1234567 4.67493 PAGE: 4/11 Edwards adv. Epstein Case No.: 502009CA040800XXXXMEAG Eipert Interrogatories To Jeffrey Epstein EXPERT INTERROGATORIES TO JEFREY EPSTEIN 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 lieu 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. EFTA00724412 14:43 N0V 22. 2010 FAX NO: 1234567 •67493 PAGE: 5/11 Edwards adv. Epstein Case No.: 502009CA040800,OOOCMBAG Expert Interrogatories To Jeffrey Epstein 4. State the name, volume and page number of the publication in which each article or paper listed above can be found. 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. EFTA00724413 14:44 NOV 22, 2010 FAX NO. 1234567 *67493 PAGE: 6/11 Edwards adv. Epstein Case No.: 502009CA040SOOXXXXMBAG Expert Interrogatories To Jeffrey Epstein 7. State the opinion to which the experts aforementioned are expected to testify. 8. Give a summary of the grounds of each opinion stated. 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. EFTA00724414 14.45 N0V 22. 2010 FAX NO: 1234567 •67493 PAGE: 7/11 Edwards adv. Epstein Case No.: 502009CA04080OOCOCIVD3AG Expert Interrogatories To Jeffrey Epstein c. The dates the expert was with each employer. d. The type of duty the expert performed with each employer. 11. If the expert has not practiced or worked in his/her field during the last five years, what was his/her employment during this time? 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. EFTA00724415 14:46 NOV 22. 2010 FAX NO: 1234567 +67493 PAGE: 8/11 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Expert Interrogatories To Jeffrey Epstein 13. Did the expert submit any other reports based upon tests, examinations or analyses 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. EFTA00724416 14:47 N0V 22, 2010 FAX NO: 1234567 *67493 PAGE: 9/11 Edwards adv. Epstein Case No.: 502009CA040800)OOOCM:BAG Expert Interrogatories To Jeffrey Epstein REQUEST TO PRODUCE EXPERT REPORTS 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. EFTA00724417 14:47 NOV 22. 2010 FAX NO: 1234567 #67493 PAGE: 10/11 Edwards adv. Epstein Case No.: 502009CA040800)0DOCINBAG Expert Interrogatories To Jeffrey Epstein 16. Has the expert served as an expert witness in any other litigated case in the past three years? If so, state as to each case: 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. STATE OF COUNTY OF EFTA00724418 14:48 NOV 22. 2010 FAX NO: 1234567 167493 PAGE: 11/11 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Expert Interrogatories To Jeffrey Epstein The foregoing instrument was acknowledged before me this day of , 20 , by who is personally known to me or who has produced as identification and who did did/ not take an oath. (SEAL) (Notary signature) (Notary name - print) NOTARY PUBLIC, State of Florida (Serial number, if any) EFTA00724419