' 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 su

0800)OOCXMBAG REOUEST TO PRODUCE TO JEFFREY EPSTEIN Bradley J. Edwards by and through his undersigned counsel, requests, pursuant to Rule 1.3 0 of the Florida Rules of Civil Procedure, that Jeffrey Epstein produce and permit Bradley J. NI/ Ed ards to inspect and copy each of the following documents*: 1. All contracts for legal s

EDWARDS' COUNTERCLAIM Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.110 of the Florida Rules of Civil Procedure, hereby files his Answer and Affirmative Defenses to Defendant/Counter-Plaintiff Bradley Edwards' ("Edwards") Counterclaim, and states: 1. Epstein

EDWARDS' COUNTERCLAIM Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.110 of the Florida Rules of Civil Procedure, hereby files his Answer and Affirmative Defenses to Defendant/Counter-Plaintiff Bradley Edwards' ("Edwards") Counterclaim, and states: 1. Epstein

E TO DEFENDANT BRADLEY EDWARDS' REOUEST TO PRODUCE Plaintiff Jeffrey Epstein, by and through his undersigned counsel and pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, hereby files his response to Bradley Edwards' Request to Produce as follows: No such requested document is in the possession of Plaintiff. WE HER

Defendant(s). REOUEST TO PRODUCE TO JEFFREY EPSTEIN Bradley J. Edwards by and through his undersigned counsel, requests, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that Jeffrey Epstein produce and permit Bradley J. Edwards to inspect and copy each of the following documents•: Any and all documents• reflecting

ent this proposal is rejected, the Defendant is subject to sanctions, including, but not limited to, those as outlined in Rules 1.442(g) and (h) of the Florida Rules of Civil Procedure, Fla. Stat. 768.79 and any other relief Plaintiff is entitled to as a matter of law and which the Court deems just and proper. 11. GOOD-FAITH: Thi

ent this proposal is rejected, the Defendant is subject to sanctions, including, but not limited to, those as outlined in Rules 1.442(g) and (h) of the Florida Rules of Civil Procedure, Fla. Stat. 768.79 and any other relief Plaintiff is entitled to as a matter of law and which the Court deems just and proper. 11. GOOD-FAITH: Thi

0800)OOCXMBAG REOUEST TO PRODUCE TO JEFFREY EPSTEIN Bradley J. Edwards by and through his undersigned counsel, requests, pursuant to Rule 1.3 0 of the Florida Rules of Civil Procedure, that Jeffrey Epstein produce and permit Bradley J. NI/ Ed ards to inspect and copy each of the following documents*: 1. All contracts for legal s

Defendant(s). REQUEST ro PRODUCE TO JEFFREY EPSTEIN Bradley J. Edwards by and through his undersigned counsel, request, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that Jeffrey Epstein, produce and permit Bradley J. Edwards to inspect and copy each of the following documents*: 1. Paragraph 12 of Edwards' Thi

ENDANT, JEFFREY EPSTEIN Defendant/Counterplaintiff, Bradley J. Edwards ,by and through his undersigned counsel, recuests, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that PlIntifUColuiterdefendant, Jeffrey Epstein, produce and permit Bradley J. Edwards to inspect and copy each of the following documents*: 1.

EFENDANT/COUNTER-PLAINTIFF, BRADLEY J. EDWARDS PlaintifOCounter-Defendant, Jeffrey Epstein, by and through his undersigned counsel, and pursuant to the Florida Rules of Civil Procedure, files this his Notice of Propounding First Set of Expert Witness Interrogatories and Request to Produce Expert Reports directed to Defendant/Count

t 1:00 p.m., at: Cambridge Court Reporters 675 Massachusetts Avenue 11th Floor Cambridge, MA 02139 The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day, weekends and holidays excepted, until completed. I HEREBY CERTIFY that a true and a correct copy of the foregoing h

aintiff; ) ) vs. ) ) JEFFREY EPSTEIN, ) ) Defendant. ) PLAINTIFF'S CROSS NOTICE OF TAKING DEPOSITION' PLEASE TAKE NOTICE that pursuant to the Florida Rules of Civil Procedure, before an officer authorized by law to take depositions in the State of Florida, Plaintiff, JANE DOE II, will take the deposition of the following

22, 2009, at 10:00 a.m., at: Esquire Court Reporters One Penn Plaza Suite 4715 New York, NY 10119 The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day, weekends and holidays excepted, until completed. I HEREBY CERTIFY that a true and correct copy of the foregoing has

21, 2009, at 11:00 a.m., at: Esquire Court Reporters One Penn Plaza Suite 4715 New York, NY 10119 The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day, weekends and holidays excepted, until completed. I HEREBY CERTIFY that a true and correct copy of the foregoing has

ll take the deposition of on Thursday, September 3, 2009, at 10:00 a.m., at: Esquire Court Reporters The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day, weekends and holidays excepted, until completed. I HEREBY CERTIFY that a true and correct copy of the foregoing has

earcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day, weekends and holidays excepted, until completed. I HEREBY CERTIFY that a true and correct copy of the foregoing has

nd 151-154. Accordingly, a more detailed inquiry is required for those same reasons set out above. III. The Legal Standard 9. In sum, nothing in the Florida Rules of Civil Procedure forbids a second EFTA00728269 Epstein v. Rothstein. et at Page 6 discovery deposition. Medina v. Yoder Auto Sales. Inc., 743 So.2d 621, 622-623

ON TO COMPEL DISCOVERY RESPONSES AND FOR SANCTIONS Plaintiff Jeffrey Epstein, by and through his undersigned counsel and pursuant to Rule 1.380 of the Florida Rules of Civil Procedure, hereby moves this Court to enter an order compelling the Defendant Bradley Edwards, yet again, to provide responses to Plaintiff's Request for Pro