Epstein Secrets

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408

ry responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstanding damages discovery requests to which Edwards's Response is not due until after the Court's deadline date for the filing of this Motion. As such, an additional Motion may be required upon receip

ANSWER: Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards' right to economic privacy. 15. State the amount of gross income that you received from the provision of goods or services other than while acting a

rue and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 19 Tonja Hadd

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408

ry responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstanding damages discovery requests to which Edwards's Response is not due until after the Court's deadline date for the filing of this Motion. As such, an additional Motion may be required upon receip

ANSWER: Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards' right to economic privacy. 15. State the amount of gross income that you received from the provision of goods or services other than while acting a

rue and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 19 Tonja Hadd

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408

ry responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstanding damages discovery requests to which Edwards's Response is not due until after the Court's deadline date for the filing of this Motion. As such, an additional Motion may be required upon receip

ANSWER: Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards' right to economic privacy. 15. State the amount of gross income that you received from the provision of goods or services other than while acting a

rue and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 19 Tonja Hadd

ward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 42

xhibits as referenced/used in the Deposition of Scott W. Rothstein taken by Epstein on June 14, 2012. 6. Privilege Log of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, Dated February 23, 2011 as filed in this matter and in In re: Rothstein Rosenfeldt Adler, P.A.; 09-34791 -RBR. 7. Docket from

EBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this June 20, 2013. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 acsimile) 10 EF

CUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and ■1., individually, Defendant(s). RESPONSE TO PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S REQUEST FOR PRODUCTION TO DEFENDAN

ed includes attorney work product; attorney-client privileged information, and information protected by rights to financial privacy. EFTA00808629 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Response to Epstein's Request for Production served 9.5.17 4. Objection. The request is overly broad

33301 Pho Fax: Fred Haddad, Fred Haddad, One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Pho Fax: Attorneys for Jeffrey Epstein 4 Tonia Haddad Coleman, Esquire Tonja Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phon Fax: Attorneys for Jeffrey Epstein Marc S. Esquire One E

ward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 42

xhibits as referenced/used in the Deposition of Scott W. Rothstein taken by Epstein on June 14, 2012. 6. Privilege Log of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, Dated February 23, 2011 as filed in this matter and in In re: Rothstein Rosenfeldt Adler, M.; 09-34791-RBR. 7. Docket from Doe

EBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this June 20, 2013. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954

UIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)OOOCMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually, Defendant(s). SUPPLEMENTAL RESPONSE TO EPSTEIN'S REQUEST FOR PRODUCTION DATED DECEMBER 9, 2011 Bradley J. E

e available for inspection and copying in accordance with Counter-Plaintiff's Response to Request to Produce dated January 6, 2012. EFTA00624845 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Supplemental Response to Epstein's Request for Production dated December 9, 2011 1 HEREBY CERTIFY th

Fax: Attorneys for Scott Rothstein The L-S Law Firm 1441 Brickell Avenue, 15th Floor Miami, FL 33131 Phone: Fax Attorneys for Jeffrey Epstein Tonia Haddad Coleman. Esquire Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: Fax: Attorneys ore rey Epstein EFTA00624847