EFTA00286378.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800X)CaMB JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. COPY RECEIVED FOR FILING DEC 13 2011 SHARON CLERK CIRCUIT CIVIL DIVISION wiR.SORCKLER PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE TO BRADLEY J. EDWARDS' REQUEST TO PRODUCE Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby files his Responses and Objections to Defendants/Counter-Plaintiffs' Request to Produce to Jeffrey Epstein dated October 28, 2011 and in support states as follows: Request No. 1.: All contracts for legal services rendered in defense of the criminal charges and civil claims prosecuted against you arising out of allegations involving your misconduct with minor females. Answer: If there is a contract for legal services relating to the damages claimed by Mr. Epstein in his Second Amended Complaint, it will be produced. Plaintiff objects to producing any and all other contracts for legal services in the defense of criminal charges or other civil claims against EFTA00286378 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Mr. Epstein not related to the claims in the Second Amended Complaint as being irrelevant, overbroad, and privileged as attorney-client and work product. Request No. 2.: All invoices for legal services rendered in connection with the referenced matters. Answer: The invoices for legal services relating to the damages claimed by Mr. Epstein in his Second Amended Complaint will be produced. Plaintiff objects to producing any and all other invoices for legal services in the defense of criminal charges or other civil claims against Mr. Epstein not related to the claims in the Second Amended Complaint as being irrelevant, overbroad, and privileged as attorney-client and work product. Request No. 3.: All statements for costs incurred in connection with the referenced matters. Answer: The statements for costs incurred in connection to the damages claimed by Mr. Epstein in his Second Amended Complaint will be produced. Plaintiff objects to producing any and all other statements for costs incurred in connection with the defense of criminal charges or other civil claims against Mr. Epstein not related to the claims in the Second Amended Complaint as being irrelevant, overbroad, and privileged as attorney-client and work product. Request No. 4.: All documents reflecting and/or relating to the payment for services and costs incurred in connection with the referenced matters. - 2 - EFTA00286379 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Answer: The documents reflecting and/or relating to the payment for services and costs incurred in connection with the damages claimed by Mr. Epstein in his Second Amended Complaint will be produced. Plaintiff objects to producing any and all other documents reflecting and/or relating to .the payment for services and costs incurred in connection with the defense of criminal charges or other civil claims against Mr. Epstein not related to the claims in the Second Amended Complaint as being irrelevant, overbroad, and privileged as attorney-client and work product. Dated: December 12, 2011. Respectfully submitted, seph . Ackerman, Jr. •lorida 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 Plaintiff Jeffrey Epstein - 3 - EFTA00286380 Epstein v. Rothstein and Edwards Case No. 502009CA04080OOOO(MB/Div. AG CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served by U.S. Mail on this 12th day of December, 2011 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, ■., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401-5012; and Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Blvd., Suite 700, Fort Lauderdale, FL 33301. By: - 4 - sep11 L Ackerman, Jr. EFTA00286381