EFTA01087251

THE OF COURT CIRCUIT THE IN AND IN CIRCUIT, JUDICIAL FIFTEENTH FLORIDA COUNTY, BEACH PALM FOR 502009CA040800XXXXMBAG NO.: CASE EPSTEIN, JEFFREY Plaintiff(s), vs. individually, ROTHSTEIN, SCOTT and individually, EDWARDS, J. BRADLEY individually, L.M., Defendant(s). SET THIRD PLAINTIFF'S TO ANSWERS SERVING OF NOTICE DEFENDANT/COUNTER-PLAINTIFF TO INTERROGATORIES OF EDWARDS J. BRADLEY his through and by Edwards, J. Bradley Defendant/Counterplaintiff, the NOW COMES Third Plaintiffs to Answers that Court the with Notice this files hereby and counsel, undersigned have 2011, 9, December on Epstein, Jeffrey Plaintiff, the by propounded Interrogatories of Set Plaintiff. the for attorney the to furnished been and Fax by furnished been has foregoing the of copy true a that CERTIFY HEREBY I ist. • attach the on 1 co all to 20 January, of day this Mail U.S. OL r SC JA 169440 No.: ar Fl M. Shipley, & Barnhart Scarola Denney Boulevard Lakes Beach Palm 33409 Florida Beach Palm est Phone: Fax: Edwards J. Bradley for Attorney EFTA01087251 Epstein adv. Edwards 502009CA040800XXXXMBAG No.: Case Edwards to Interrogatories of Set Third Plaintiff's to Answers LIST COUNSEL Esquire Goldberger, A. Jack P.A. Weiss, & Goldberger Atterbury, 1400 Suite South, Avenue Australian 250 33401 FL Beach, Palm West Phone Fax: Epstein Jeffrey for Attorneys PL Lehrman, & Fistos Edwards, Weissing, Jaffe, Farmer, 2 Suite Avenue, Andrews N. 425 01 Lauderdale. Fort Phone: Fax: Esquire Jr., Ackerman, L. Joseph P.A. Burnett, White Fowler West Point Phillips 901 Drive Flagler S 777 33401-6170 FL Beach. Palm West Phone: Fax: Epstein Jeffrey for Attorneys Esquire Nurik, S. Marc Nurik S. Marc of Offices Law 700 Suite Blvd., Broward E One 33301 FL Lauderdale. Fort Phone: Fax: Rothstein Scott for Attorneys EFTA01087252 PLAINTIFF'S TO ANSWERS EDWARDS J. BRADLEY TO INTERROGATORIES OF SET THIRD Second your in forth set allegations the supports that fact every and each Identify I. providing: by Counterclaim, Amended but including, suffered, have you allege you damages the of description detailed a a. in resulted have claim you those to, limited not and reputation, your to injury (1) and relationships; professional your in interference (2) suffered, have you that allege you damages special the of description detailed a b. to: limited not but including, (1) professional your from diverted time your of value the of loss the and responsibilities, lawsuit. this in you against claims defending of cost the (2) ANSWER: require would allegations specific supports" hat fact every and "each of identification The accordingly is and counsel of processes thought and impressions mental the of disclosure the Bradley privilege, that waiving without and to Subject privilege. -product work the by protected the in sustain to continue will and sustained has he damages special the described has Edwards unethical, immoral, of accused falsely been has He counterclaim. pending currently his in future his and competence, professional his integrity, professional his impugning conduct illegal and conclusively law Florida and se per defamatory are accusations Such law. practice to tness fi have accusations false The defamation. such from arises inevitably that damage the presumes but community legal Florida South the only not throughout repeatedly disseminated been internationally. and nationally from attention and effort, time, divert to obliged been has Edwards Bradley addition, In Epstein. of misconduct tortuous the against defend to profession his of practice productive the claims the advance to ability his impeded pursuits professional his from diverted minute Every additional and other undertaking from him precluded and clients existing of interests and detail Produce to Request Epstein's to response in available made records Time responsibilities. for invoices Cost suffered. has Edwards Mr. diversion the of extent the minimum) a (at available made been also have misconduct Epstein's against defending in incurred expenditures 3 EFTA01087253 in continuing and ongoing are damages Those Produce. to Request Epstein's to response in nature. this of result direct a as injured been has reputation your how detail in Explain 2. the identify specificity, With present. the to action this of filing the from you against action following: action; this of filing the to prior reputation alleged Your a. the after reputation your about statements made have who persons all and Any b. action; this of filing your about made written, or verbal whether communications, all and Any c. and reputation; statements said which in communications of substance and manner, date, The d. reputation. your about made been have ANSWER: above. See Excellent a. the including lawyers numerous his and Epstein except known presently are None b. Edwards of prosecution malicious Epstein's advancing in engaged presently attorneys process. of abuse extortionate his and above. 2b See c. the and case this in made statements -record -the on and filings, pleadings, the See d. proceedings. bankruptcy RRA your with interfered has you against action this of filing the how detail in Explain 3. relationship: such each for and relationships professional relationship; the had or have you whom with person the and nature its identify a. with; interfered been has relationship the how exactly specify b. and interference; the of knowledge with person each identify c. interference. such of result a as damages actual identify d. ANSWER: parties the include interference the of knowledge with Persons above. #1 to answer See of certificate the on persons all record, of attorneys prior and present all action, this to bankruptcy RRA the in filed Rothstein Depose to Motion Epstein's of service that occasion every on Court in observers and judges, attorneys, all proceedings, 4 EFTA01087254 all Edwards, against claims spurious Epstein's of support in presented been has argument Edwards. against claims spurious Epstein's of coverage media to exposed persons include: Edwards by sustained damages Actual misconduct; outrageous Epstein's against defending in incurred costs the • attention; and time diverted Edwards' of value the • as reputation professional Edwards' to injury the for compensation of value the • jury. a by liquidated to seek you damages the of knowledge has that witness every and each Identify 4. your partners, your employer, your to limited not but including action, this in recover each, for and, clients and sources, referral colleagues, associates, members, family knowledge. her or his of nature the describe ANSWER: Bradley which to extent the of knowledge have Lehrman Seth Farmer, Gary Jaffe, Steve pursuits, professional gainful from Epstein by diverted were attention and time Edwards' character. and integrity, competence, reputation, professional Edwards' Bradley above. described matters same the of knowledge has Cassell Paul Judge Federal Former above. described matters same the of knowledge has Esq. Cote, Earleen by injured been has reputation your that claim your for basis the Explain 5. action. this in you against allegations the ANSWER: se. per Defamation your to injury distinguished have you which by method the Explain 6. to injury from action this in you against allegations from directly resulting reputation Rothstein of firm defunct he it partner a been having your from resulting reputation your Adler. & Rosenfeldt ANSWER: Edwards' Bradley of accusations false unsupportable, unsupported, malicious, Epstein's Mr. singled scheme Ponzi massive a in participation active and involvement knowing 5 EFTA01087255 the were accusations Those employees. RRA innocent other all among from out Edwards and enterprise, criminal Rothstein's to Edwards Bradley linking falsely source only impeccable Edwards' Bradley that believe to basis no is there allegations those absent with employment brief his by tarnished been have would reputation professional were employees RRA of majority vast the Indeed, Adler. & Rosenfeldt Rothstein firm. the with employment their from taint any escaped have and innocent presumed this of defense the for incurred have you that costs and fees all Identify 7. you. against action ANSWER: production. contemporaneous Edwards' Bradley See Searcy of firm the with agreement engagement written a have you If 8. of scope the agreement, the of date the describe Shipley, & Barnhart Scarola Denney compensated. be to are counsel your which on terms the and services ANSWER: production. contemporaneous Edwards' Bradley See of rm fi the with agreement engagement written a have not do you If 9. oral your of terms the describe P.A., Shipley, & Barnhart Scarola Denney Searcy are counsel your which on terms the and services of scope the agreement, representation compensated. be to ANSWER: N/A relationship any have you whom with firm and attorney other any Identify 10. action. this of defense your with connection in ANSWER: None 6 EFTA01087256 costs and fees legal any paid have behalf) your on another (or you If 11. each of date the and paid amounts the provide action, this of defense the for incurred payment. ANSWER: production. contemporaneous Edwards' Bradley See your to devoted you that hours of amount the month, or week by State, 12. and 2011) and 2010 2009, (in you against action this of filing the since work professional or manual diary, personal sheets, time (e.g., information this of source the detail in describe calendar). computer ANSWER: he work his of course ordinary the in that estimates Edwards Bradley although Unknown, regularly total This activities. professional to week per hours 60 approximately devotes trials. during and to prior immediately increases your to devoted have you that hours of amount the month, or week by State, 13. and 2007 (in you against action this of filing the to prior years two the during work professional diary, personal sheets, time (e.g., information this of source the detail in describe and 2008) calendar). computer or manual ANSWER: he work his of course ordinary the in that estimates Edwards Bradley although Unknown, regularly total This activities. professional to week per hours 60 approximately devotes trials. during and to prior immediately increases a as services providing from received you that income gross of amount the State 14. that of source the identify and 2011 and 2010 2009, 2008, 2007, years the of each for lawyer same). the of payor the (including income ANSWER: of discovery the to lead to calculated reasonably not immaterial, Irrelevant, Objection. economic to right Edwards' Bradley of invasion unwarranted an and evidence admissible privacy. 7 EFTA01087257 or goods of provision the from received you that income gross of amount the State 15. and 2010 2009, 2008, 2007, years the of each for lawyer a as acting while than other services same). the of payor the (including income that of source the identify and 2011 ANSWER: of discovery the to lead to calculated reasonably not immaterial, Irrelevant, Objection. economic to right Edwards' Bradley of invasion unwarranted an and evidence admissible privacy. years the for work bono pro to devoted have you that hours of amount the State 16. or cases the of names the with answer your substantiate and 2011 and 2010 2009, 2008, 2007, service. such provided you which for causes ANSWER: of discovery the to lead to calculated reasonably not and immaterial Irrelevant, Objection. evidence. admissible as anguish mental and embarrassment, distress, emotional for damages 'claim You 17. psychological or medical professional sought you Have you. against action this of result a so, If services? services; such of provider each identify a. such for assistance or treatment received you which during dates the state b. and services; services. such for paid have you money of amount the state c. ANSWER: No. 8 EFTA01087258 please services, psychological or medical professional sought not have you If 18. why. explain ANSWER: professional without stress psychological and emotional the with deal to managed have I treatment to attaches sometimes that stigma potential the avoid to preferred have and assistance issues. psychological and emotional for as remuneration other or wages, income, of loss any suffered have to claim you If 19. detail in describe action, this in you against made claims the of result a remuneration other or wages by whether income, lost the of nature the a. of practice the in engaged hours for earnings of loss clients, of loss (e.g., etc.); law, for remuneration, other or wages by whether income, lost of amount the b. or bill you if (e.g., above the receive typically you which for period each number the hour, the by provide you services legal of track keep otherwise month) each for services such perform to unable were you which hours of action; this of ling fi the since concluded; and commenced loss the date the i.e., loss, the of duration the c. and client specific the identify i.e., loss, the determining for basis the d. and matter; or wages by whether income, of loss your calculating in used method the e. suffered have to claim have you period the for remuneration, other damages. ANSWER: production. contemporaneous Edwards' Bradley See result a as capacity earning future of loss suffered have you that claiing are you If 20. specificity: with describe conduct, wrongful allegedly the of capacity; earning future lost the of duration the a. and capacity, earning future lost the of amount the b. calculation. your for basis the c. ANSWER: time. this at Undetermined 9 EFTA01087259 result a as opportunities employment or business lost have to claiming are you If 21. each, for and, specificity with each describe plaintiff, the of conduct wrongful allegedly the of recover. to seek you damages money of amount the state ANSWER: time. this at Undetermined earnings. future of loss your calculating in used method the Describe 22. ANSWER: N/A the each for state please opportunity, business lost alleged each to respect With 23. following: who entity or attorney client, employer, the of address and name the a. lost; was claim you that opportunity business the presented or offered opportunity; business lost the in involved work of scope and nature the b. you that estimated you remuneration or compensation of amount the c. basis the and opportunity the undertaken you had paid be or earn would and estimation; that for opportunity. business the lost had you that determined you date the d. ANSWER: N/A press the with communicated or to spoken have you which in instance each State 24. of identity the Provide Epstein. Jeffrey Plaintiff to relating representative media other any or communication. the of description a and contact, the of date the contact, each ANSWER: is Edwards Bradley that extent the to except privilege product work Attorney Objection. Jeffrey to available easily as are which reports published in information of source a as identified searches. internet through Edwards Bradley to as Epstein 10 EFTA01087260 dated case this in Log Privilege your on listed source(s) confidential the Identify 25. 2011. 23, February ANSWER: product. -work Attorney Objection. Log. Privilege your in source confidential a including for basis legal the Identify 26. ANSWER: privilege product work Attorney investigating still is enforcement law that belief your for explanation an Provide 27. govemment/law with contacts Identify Epstein. Jeffrey Plaintiff/Counter-Defendant the belief, this form to claim you which from else anyone or attorneys, other media, enforcement, etc. communication, of substance dates, names, the including ANSWER: law with communications restricted statutorily and -product work Attorney Objection. calculated reasonably not and immaterial, Irrelevant, authorities. prosecutorial and enforcement evidence. admissible of discovery the to lead to claims prosecuting in persist still others that claim your for basis the Identify 28. prosecuting still persons the Identify Epstein. Jeffrey PlaintiffiCounterdefendant the against prosecuting still persons the of knowledge with or PlaintiffiCounterdefendant the against claims of substance persons, such with contact of dates names, including him, against claims etc. communication, ANSWER: law with communications restricted statutorily and -product work Attorney Objection. calculated reasonably not and immaterial, Irrelevant, authorities. prosecutorial and enforcement evidence. admissible of discovery the to lead to 11 EFTA01087261 Amended Second the of 25 and 9 Paragraphs in claims your for support Provide 29. recover to never was claims civil filing of purpose sole the allege you which in Counterclaim suffered never he knew Epstein Jeffrey PlaintilMounterdefendant that damages, monetary etc. claims, unsupportable and baseless asserted knowingly he that damages, monetary ANSWER: attachments. and Judgment Summary for Motion Edwards' Bradley See their with connection in clients to made payments all list and clients all Identify 30. Epstein. Jeffrey Plaintiff/Counter-Defendant the against cases ANSWER: of discovery the to lead to calculated reasonably not and immaterial Irrelevant, Objection. the settled directly Epstein since relevant, deemed extent the to However, evidence. admissible him. to available readily is requested information the payments, the made and claims in payments made or received who -clients) (non parties third all Identify 31. Plaintiff/CounterDefendant the against cases client purported or cases client the with connection the list (2) parties; third such of relationship the explain (1) specificity: andswith Epstein Jeffrey Your payments. of purpose and payments of date the list (3) and each; by or to made payments referring persons, referring witnesses, investigators, all limitation without include should answer to made payments all and any include also should It experts. outside counsel, outside attorneys, Epstein Jeffrey Plaintiff/CounterDefendant the against cases client the of any in investors by or cases. client the with connection in person other any to or by made payments or ANSWER: of discovery the to lead to calculated reasonably not and immaterial Irrelevant, Objection. evidence. admissible 12 EFTA01087262 against cases client the on worked who attorneys all Identify 32. formerly attorneys the to, limited not but including, Epstein, Jeffrey Plaintiff/CounterDefendant & Fistos Edwards, Weissing, Jaffe, Farmer, at attorneys the Adler; & Rosenfeldt Rothstein at attorneys. referring and attorneys outside PL; Lehrman, ANSWER: substantive rendered Berger Bill and Jaffe Steve Weissing, Matt Cassell, Paul Edwards, Bradley at attendance in was Adler Russell Epstein. Jeffrey against claims of prosecution the in services participant. active an not was but depositions multiple etc. investigators, secretaries, paralegals, staff, support of members all Identify 33. but including Epstein, Jeffrey Plaintiff/CmmterDefendant the against cases client on worked who Adler; & Rosenfeldt Rothstcin at formerly attorneys the office; Edwards' Bradley to, limited not outside of offices and PL; Lehrman, & Fistos Edwards, Weissing, Jaffe, Farmer, of office the attorneys. referring and attorneys ANSWER: Fisten, Mike Sterling, Susan Williamson, Beth Johnson, Jacquie Black, Wayne Gilbert, Shawn Diaz Pat Roberts, Pat related etc. negotiations, discussions, offers, proposals, agreements, any Identify 34. deals. similar or rights other or book, movie, any of development or sale the to ANSWER: None 13 EFTA01087263 ) FLORIDA OF STATE britti- ?frac ) BROW-ARE/4 OF COUNTY me before acknowledged was instrument foregoing The this / c c ak Scatty J.46: 4 known personally is who Edwards, J. Bradley by me to oath. an take not 2012 January, of day produced has- who or did/did. who -and identification (type-of-identi€ieaatien}ss ~ Guru Public otary Large at Florida of tate expires: Commission y No: Commission 14 PIRROlia_ MARY CM/MICA MY 00 [,...)M 0 I EXPIRES: ' 4, .: , tiovr4: EICHAdThfuNotstryncw.t--ov.:- EFTA01087264 THE OF COURT CIRCUIT THE IN AND IN CIRCUIT, JUDICIAL FIFTEENTH FLORIDA COUNTY, BEACH PALM FOR 502009CA040800XXXXMBAG NO.: CASE EPSTEIN, JEFFREY Plaintiff(s), VS. individually, ROTHSTEIN, SCOTT and individually, EDWARDS, J. BRADLEY individually, L.M., Defendant(s). PRODUCE TO REQUEST TO RESPONSE PLAINTIFF'S attorney undersigned his through and by Edwards, J. Bradley Defendant/Counterplaintiff, to respond hereby Procedure, Civil of Rules Florida 1.350, Rule to pursuant and as 2011 9, December dated Produce to Request Epstein's, Jeffrey Plaintiff/Countcrdefendant, follows: claim specific a support" to tend "that documents of identification The Objection. I. is and counsel of processes thought and impressions mental the of disclosure a require would privilege. -product work the by protected accordingly claim specific a support" to tend "that documents of identification The Objection. 2. is and counsel of processes thought and impressions mental the of disclosure a require would privilege. -product work the by protected accordingly claim specific a support" to tend "that documents of identification The Objection. 3. is and counsel of processes thought and impressions mental the of disclosure a require would privilege. -product work the by protected accordingly EFTA01087265 Epstein adv. Edwards 502009CA040800XXXXMBAG No.: Case Produce to Request to Response Plaintiff(s) claim specific a support" to tend "that documents of identification The Objection. 4. is and counsel of processes thought and impressions mental the of disclosure a require would privilege. -product work the by protected accordingly claim specific a support" to tend "that documents of identification The Objection. 5. is and counsel of processes thought and impressions mental the of disclosure a require would privilege. -product work the by protected accordingly for available are lawsuit this of defense in incurred expenses reflecting Invoices convenient mutually any at counsel Edwards' Bradley of offices the at copying and inspection arrangement. prior by determined time are: documents responsive only The 6. action this in Complaints amended and original the • of certificate and attachments (with Rothstein Depose to Motion Epstein's • proceedings bankruptcy RRA the in filed service) the in already arc which of all transcripts hearing and filings bankruptcy • counsel his and Epstein of possession None 7. for available are lawsuit this of defense in incurred expenses reflecting Invoices 8. convenient mutually any at counsel Edwards' Bradley of offices the at copying and inspection arrangement. prior by determined time 2 EFTA01087266 Epstein adv. Edwards 502009CA040800XXXXMBAG No.: Case Produce to Request to Response PlaintiMs) of offices the at copying and inspection for available are documents Responsive 9. arrangement. prior by determined time convenient mutually any at counsel Edwards' Bradley None 10. of discovery the to lead to calculated reasonably not broad, Overly Objection. 11. clients, his of rights the and right Edwards' Bradley to pursuant privileged evidence, admissible to subject circumstances some in and privacy, economic to associates and partners, law provisions. confidentiality contractual None 12. obliged been has Edwards Bradley which time of amount the reflecting Records 13. against actions legal baseless and abusive, malicious, Epstein's of defense the to devote to Edwards' Bradley of offices the at copying and inspection for available are Edwards Bradley arrangement. prior by determined time convenient mutually any at counsel None 14. obliged been has Edwards Bradley which time of amount the reflecting Records 15. against actions legal baseless and abusive, malicious, Epstein's of defense the to devote to Edwards' Bradley of offices the at copying and inspection for available are Edwards Bradley arrangement. prior by determined time convenient mutually any at counsel privilege product work Attorney Objection. 16. privilege product work Attorney Objection. 17. 3 EFTA01087267 Epstein adv. Edwards 502009CA040800XXXXMBAG No.: Case Produce to Request to Response Plaintiff(s) of discovery the to lead to calculated reasonably not broad, Overly Objection. 18. clients, his of rights the and right Edwards' Bradley to pursuant privileged evidence, admissible to subject circumstances some in and privacy, economic to associates and partners, law provisions. confidentiality contractual Bradley that extent the to except privilege product work Attorney Objection. 19. easily as are which reports published in information of source a as identified is Edwards searches. internet through Edwards Bradley to as Epstein Jeffrey to available None 20. None 21. within fall proceedings Act Rights Victims pending that extent the to except None 22. to available readily records public arc matter that in Pleadings request. this of description the Epstein. Jeffrey thereto attachments and Judgment Summary for Motion Edwards' Bradley See 23. in and Epstein against proceedings criminal federal and state the in filings and pleadings all and the in already are which of —all him by settled and against brought claims civil the of each represented have and do who firms law various the of members the and/or Epstein of possession him. 4 EFTA01087268 Epstein adv. Edwards 502009CA040800XXXXMBAG No.: Case Produce to Request to Response Plaint'(Rs) by furnished been has foregoing the of copy correct and true a that CERTIFY HEREBY I 2012. January, of day -- f" l(e this list attached the on Counsel all to Mail U.S. and Fax C Jack 169440 No.: ar r da Flo P.A. Shipley, & Barnhart Scarola Denney rc, S Boulevard Lakes Beach Palm 33409 'cla Palm est Phone: Fax: Edwards J. Bradley for Attorney 5 EFTA01087269 Epstein adv. Edwards 502009CA040800XXXXMBAG No.: Case Produce to Request to Response Plaintiff(s) LIST COUNSEL Esquire Goldberger, A. Jack P.A. Weiss, & Goldberger Atterbury, 1400 Suite South, Avenue Australian 250 33401 FL Beach, Palm West Phone Fax: & Fistos Edwards, Weissing, Jaffe, Fanner, PL Lehrman, 2 Suite Avenue, Andrews N. 425 33301 FL Lauderdale Fort Phone: Fax: Esquire Nurik, S. Marc Nurik S. Marc of Offices Law 700 Suite Blvd., Broward E One 33301 FL Lauderdale, Fort Phone: Fax: Esquire Jr., Ackerman, L. Joseph P.A. Burnett, White Fowler West Point Phillips 901 Drive Flagler S 777 33401-6170 FL Beach, Palm West Phone: Fax: 6 EFTA01087270 THE OF COURT CIRCUIT THE IN AND IN CIRCUIT, JUDICIAL FIFTEENTH FLORIDA COUNTY, BEACH PALM FOR 502009CA040800XXXXMBAG NO.: CASE EPSTEIN, JEFFREY Plaintiff(s), VS. individually, ROTHSTEIN, SCOTT and individually, EDWARDS, J. BRADLEY individually, L.M., Dcfendant(s). EPSTEIN'S JEFFREY PLAINTIFF/COUNTER-DEFENDANT ON ORDER EDWARDS' J. BRADLEY TO OBJECTIONS 10/28/11 DATED PRODUCE TO REOUEST Plaintiff/Counter- of Objections the upon considered be to come having CAUSE THIS by served Produce to Request the to objections EPSTEIN'S JEFFREY Defendant, file the reviewed having Court the and EDWARDS, J. BRADLEY Defendant/Counter-Plaintiff, hereby, is it premises, the in advised fully being and 1 over/14G ce4,,ze, un_s- <..)4igc 77t.e. - ADJUDGED: and ORDERED r iv an - 1 etp -6( sh,// 74-0- 1/ Florida, clieckunty, B Palm Beach, Palm West at ORDERED AND DONE 2011. Dec- of day CROW F. DAVID JUDGE CIRCUIT list. counsel attached the on counsel all to furnished been have Copies ctir „a-3 ,„/ L Lin Corp et. ley 6e-• I ?.^ :rep L4.1 EFTA01087271 Epstein adv. Edwards 502009CA040800XXXXMBAG No.: Case LIST COUNSEL Esquire Goldberger, A. Jack P.A. Weiss, & Goldberger Atterbury, 1400 Suite South, Avenue Australian 250 33401 FL Beach, Palm West (561)-659-8300 Phone: I (561)-835-869 Fax: Epstein Jeffrey for Attorneys & Fistos Edwards, Weissing, Jaffe, Fanner, PL Lehrman, 2 Suite Avenue, Andrews N. 425 33301 FL Lauderdale, Fort (954)-524-2820 Phone: (954)-524-2822 Fax: Esquire Jr., Ackerman, L. Joseph P.A. Burnett, White Fowler West Point Phillips 901 Drive Flagler S 777 33401-6170 FL Beach, Palm West 2 Phone: Fax: Epstein Jeffrey for Attorneys Esquire Nurik, S. Marc 700 Suite Blvd., Broward E One 33301 FL Lauderdale, Fort Phone: Fax Rothstein Scott for Attorneys Esquire Scarola, Jack Shipley & Barnhart Scarola Denney Searcy Boulevard Lakes Beach Palm 2139 33409 FL Beach, Palm West Phone: Fax: Edwards J. Bradley or Attorneys EFTA01087272 CIRCUIT JUDICIAL th 15 THE OF COURT CIRCUIT THE IN FLORIDA COUNTY, BEACH PALM FOR AND [N AG DIVISION CIVIL 502009CA040800XXXXMB NO. CASE Crow F. David Judge EPSTEIN, JEFFREY Plaintiff/Counter-Defendant, v. and individually, ROTHSTEIN, SCOTT individually, EDWARDS, J. BRADLEY Defendants/Counter-Plaintiffs. COPY FILING FOR RECEIVED 2012 0 1 JAN BUCK R. SHARON COMPTROLLER & CLERK DIVISION CIVIL CIRCUIT EPSTEIN'S JEFFREY PLAINTIFF/COUNTER-DEFENDANT COURT'S WITH COMPLY TO TIME OF ENLARGEMENT FOR MOTION REQUESTS DISCOVERY TO OBJECTIONS ON ORDER 2011 21, DECEMBER undersigned through and by ("Epstein"), EPSTEIN JEFFREY Plaintiff/Counter-Defendant of enlargement an for moves hereby Procedure, Civil of Rules Florida the to pursuant and counsel J. Bradley to Objections Epstein's on Order 2011 21, December Court's this to respond to time follows: as are Motion this for grounds The 10/28/11. Dated Produce to Request Edwards' the considered Court this 2011, 21, December on held matter this on hearing a At 1. ("Edwards") EDWARDS' J. BRADLEY Defendant/Counter-Plaintiff to Epstein of objections 10/28/11. Dated Produce to Request to Plaintiff the directed and privilege to as except objections the overruled Court The 2. attached is Order the of copy A log. privilege a with together days, 20 within response complete a file 1. Exhibit as hereto the until Order this receive not did office his that certifies Plaintiff for Counsel 3. Order. the with comply to days business 3 than less him giving thereby 2011, 6, January of afternoon EFTA01087273 Edwards adv. Epstein Cue No.: 502009CA040800XXXXMBAG COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach FL 33401 Phone Fax: Attorneys or Jee my Epstein Farmer, Jaffe, Wcissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: Fax: Joseph L. Ackerman, Jr., Esquire Fowler White Burnett, P.A. 901 Phillips Point West 777 S Flagler Drive West Palm Beach, FL 33401-6170 2 Phone: Fax: Attorneys for Jeffrey Epstein Marc S. Nurik, Esquire One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: - Fax:' Attorneys for Scott Rothstein Jack Scarola, Esquire Searcy Denney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Boulevard %Vest Palm Beach, FL 33409 Phone. Fax: Attorneys for Bradley J. Edwards EFTA01087274