EFTA00725959.pdf

EXHIBIT D EFTA00725959 U7/1U/ZULU 14:Z1 YAA 5alUb4b610 SEARCY VENNEI IQUIWUJA IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACI I COUNTY, FLORIDA CASE NO: b02009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, v. SCOT F ROTHSTEIN, Individually. BRRILIVY J. EDWARDS, individually, anCi M., individually, Defendants. DEFENDANT BRADLEY J. EDWARDS'S MOTION TO APPOINT COMMISSIONER Defendant, Bradley J. Edwards, files this Motion to Appoint Commissioner and states: 1. Defendant wishes to depose the Records Custodian of The New York Daily ti6-. News around July 31 , 2010 in New York, NY. The deposition duces tecum notice for this witness is attached to this Motion. 2. New York law does not authori7e the issuance of a subpoena for the taking of a deposition unless a commission has been appointed. Accordingly, the defendant moves for the appointment of Metro Attorney Service, Inc., 305 Broadway, 141° Floor, NeW York, NY 10007 as the commissioner to take the deposition duces tecum of the Rocords Custodian of The New York Daily News. WHEREFORE, Defendant, Bradley J. Edwards, respectfully requests that this Honorable Court grant his Motion to Appoint Commissioner. EFTA00725960 - 1. 07/18/2018 .14:22 FAS 5016840816 SEARCY PENNEY WM/use) CERTICATE OF $ERVICE I HEREBY CERTIFY that on July 141112010 a copy of the foregoing has been seked via U.S. MaU and email transmittal to all those ore the attached service list. Robert D. Critton, Jr. BURMAN, CRITTON, et al. West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. rbu Goldbe er et al. West Palm , 33401 Goy M. Farmer, Jr. Farmer, Jaffe, Weissing, Edicands Flstos & Lehrman, Pt. Fort Lauderdale, FL 33301 Jack Scarola Se Denne Scarola Barnhart & Shipley ch, FL 33409 By: SERVICE LIST 2 EFTA00725961 VI/III/ZULU 14:Z2 FAA 6016045610 Wal0.4 llISNNtZ NOVUO/U10 I JEFFREY EPSTEIN, Plaintiff, v. , S TT i ty ROTHSTEIN, individually. B J. EDWARDS, individually, and ., individually, ! Defendants. I IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502009CA040800XXXXMBAG NOTICE OF TAKING DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that Defendant, Bradley Edwards. will take the I .. de?osttion duces tecum (See attached Exhibit 'A") of: NAME DATE AND TIME PLACE OF TAKING DEPOSITON ReCords Custodian NeW York Daily News cid Legal Department Attn: Anne Carnal 450, West 33rd Street New York, NY 10001 Aufroar shzeio 9:00A.AL. US Legal Support 1 Penn Piz, #1410 New York, NY 10119-1410 Phone: (212) 759-6014 upon oral examination before US Legal Support, Notary Public, or any other notary public or officer authorized by law to take depositions in the State of New York. The oral examination will continue from day to day until completed. The depositions are begig taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the Rules of Court. EFTA00725962 UT/19/201U 14:23 FAL 3010845818 SEARCY MONEY MMUu2/Ule CERTICATE OF SERVICE I HEREBY CERTIFY that on July +✓9~~ 2010 a copy of the foregoing has been seq./ad via U.S. Mail and email transmittal to ail those on the attached service list Jack Scarola Sears Donne Scarola Barnhart & Shipley West Palm Beach, FL 33409 (fax) BY: cci US Legal (via email) SERVICE LIST Robert D. Critton, Jr. RIEMAN, CRITTON, et al. West Pam !I 'M - 1 Jack Alan Goldberger, Esq. Atterbury Goldberger et al. West Palm Beach, FL 33401 Gary M. Farmer, Jr. Fanner, Jaffe, Weissing, Edivarcls Fistos & Lehrman P.t. Fort Lauderdale, FL 33301 2 EFTA00725963 O7/19/201U 14:23 FAS 531157PM15 bLAMA Viscuusx Vic AI...WW1 Exhibit "A" — DUCES TECUM All taped conversations between George Rush and Jeffrey Epstein, including telephone recordings, all emails to and from Jeffrey Epstein or someone representing themselves to bo Jeffrey Epstein. This request includes the 22 mtuto taped conversation that has already been identified between George Rush and Jeffrey Epstein as well as the transcript of that tape. 3 1 EFTA00725964 Vf/IV/GlitU 14:L4 lA1 0010010010 JMANt.1 unAnrx wuvw/Vau JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHS 1 UN, individually. BR.AillY J. EDWARDS, individually, and M., individually, Defendants. IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502009CA040800XXXXMBAG SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA TO: Records Custodian New York Daily News, do Legal Department Attn: Anne Carrel 450, West 33rd Street New York, NY 10001 YOU ARE COMMANDEllito appear at US Legal Support, 1 Ponn Piz, #1410, New York,1NY 10119-1410, on Ally g al, 2010 © 9.0..0 a.m., and to have with you at that time and place the following: All taped conversations between George Rush and Jeffrey Epstein, including telephone recordings, all emails to and from Jeffrey Epstein or someone representing themselves to be Jeffrey Epstein. This request Includes the 22 minute taped conversation that has already been identified between George Rush and Jeffrey Epstein as well as the transcript of that tape. If you fail to appear, you may be in contempt of court_ You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. IL - Dated July // , 2010 By. Der ola, B Sca embed & Shipley FL 33409 carola, Esq. THE COURT EFTA00725965