IN THE CIRCUIT COURT OF THE FIFTEENTH

EFTA01080974 Dataset 9 5 pages Download original PDF Download as text
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. Complex Litigation, Fla. R. Civ. Pro.1201 Case No. 50 2009CA040800XXXXMB AG RE-NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM TO: All Counsel of Record PLEASE TAKE NOTICE that the undersigned, pursuant to Florida Rule of Civil Procedure 1.310(b)(4), will take the video deposition of: NAME DATE AND TIME AJ DiScala 303 Park Ave. #1401 New York, NY 10010 Thursday May 12, 2011 10:00 a.m. PLACE Dewey LeBoeuf 1301 Avenue of the Americas New York, NY 10019 *The deponent has been instructed to bring with him all documents listed in Schedule A attached hereto. upon oral examination before DIAMOND REPORTING AND LEGAL VIDEO, a Notary Public, or before some other officer authorized by law to take depositions in the State of New York. 1 EFTA01080974 Epstein v. Rothstein Case No. 502009CA 040800XXXXMBAG NT13- Duces Tecum - AJ Discala — NY The oral examination will continue from day to day until completed. This deposition is being taken for the purpose of discovery, for use at trial or for such other purposes as are permitted under the applicable Statutes, Rules of Civil Procedure or Rules of Court. PLEASE GOVERN YOURSELVES ACCORDINGLY. In accordance with the Americans With Disabilities Act, persons in need of a special accommodation to participate in this proceeding shall, within a reasonable time prior to any proceeding, contact the Administrative Office of th Court 3 North Dixie Hi hway, Room 300, Wst Palm Beach, FL 33401, telephone 1 (TDD), or 1 Via Florida Relay Service. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed, faxed and emailed this day of April, 2011 to : Jack Scuola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 2 EFTA01080975 Epstein v. Rothstein Case No. 502009CA 040800XXXXMBAG NTD- Duces Tecum - AJ Discala — NY Marc S. Nurik, Esq. Law Offices of Marc s. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 Cc: Diamond Reporting & Legal Video WA/30743 \Discovery1NTD- DT Al Discala•ReNoticc NY 3 By: *1/4AiticisJo L. Ackerman, .11. Fla. Bar No. 235954 Lilly A. Sanchez, Fla. Bar No. 195677 FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach. Florida 33401 Telephone; Facsimile: Attorneys for Jeffiey Epstein, Plaintiff EFTA01080976 SCHEDULE "A" I. Any and all documents including but not limited to correspondence and emails by/between you and any of the following attorneys, employees or agents of the former Rothstein law firm regarding investment opportunities in any claim or litigation against Jeffrey Epstein: a) Scott Rothstein b) Russell Adler c) William Berger d) Bradley Edwards e) Michael Fisten ft Kenneth Jenne g) David Bodcn h) Deborah Villegas i) Andrew Barnett J) Patrick Roberts k) Richard (Rick) Fandrey I) Christina Kitterman 2. Any and all contracts and/or agreements, including all drafts and final versions, which were provided to you by any of the following attorneys, employees or agents of the former Rothstein law firm relating to any potential investment in any claim or litigation against Jeffrey Epstein. a) Scott Rothstein b) Russell Adler c) William Berger d) Bradley Edwards e) Michael Fisten Q Kenneth Jenne g) David Boden 10 Deborah Villegas i) Andrew Barnett j) Patrick Roberts k) Richard (Rick) Fandrey I) Christina Kitterman 3. Any and all written notes regarding any meetings you were in attendance with any of the following attorneys, employees or agents of the former Rothstein law firm regarding any potential investment in any claim or litigation against Jeffrey Epstein. a) Scott Rothstein b) Russell Adler c) William Berger d) Bradley Edwards EFTA01080977 e) Michael Fisten 1) Kenneth Jenne g) David Boden h) Deborah Villegas i) Andrew Barnett j) Patrick Roberts k) Richard (Rick) Fandrey I) Christina Kitterman 4. Any and all documents given to you by any of the following attorneys, employees or agents of the former Rothstein law firm regarding any potential investment in any claim or litigation against Jeffrey Epstein a) Scott Rothstein b) Russell Adler c) William Berger d) Bradley Edwards e) Michael Fisten f) Kenneth Jenne g) David Boden h) Deborah Villegas i) Andrew Barnett j) Patrick Roberts k) Richard (Rick) Fandrey I) Christina Kitterman EFTA01080978

📷 Images in this document (5 detected)

AI-generated factual descriptions of embedded images (llava:13b). These are searchable across the corpus.

[Image 1] The image shows a document with a heading that reads "SCHEDULE A" followed by a subheading "ALL SCHEDULES AND DOCUMENTS INCLUDING NOTES NOT LIMITED TO THE FOLLOWING." Below this, there is a list of names, which appear to be individuals associated with the document. The names are listed in a column, and each name is followed by a number, suggesting a sequence or a reference to a larger document or [Image 2] The image shows a document, which appears to be a court order or a legal notice. The document is titled "ORDER OF THE COURT" and includes a case number and a date. It mentions that the court has ordered the defendant to appear for a trial on a specific date. The document is signed by a judge and includes a section titled "CERTIFICATE OF SERVICE," indicating that the defendant has been served with [Image 3] The image shows a document that appears to be a court order or a legal notice. It is a formal document with a header that includes the name of the court and the names of the parties involved. The text of the document is not fully visible, but it mentions a "Deposition Deposit" and includes a date and time for a deposition. There is a reference to a case number and a specific individual's name. The [Image 4] The image shows a document that appears to be a letter or a report. It includes a header with the date and a reference number. The body of the document contains text, which seems to be a formal communication, possibly related to legal matters or a report on a case. There is a signature at the bottom, indicating that the document has been signed by an individual. The text is too small to read in de [Image 5] The image shows a document with a list of names, which appears to be a form or a list of individuals. The names are listed in a structured format, with each name followed by a number. The document is a scan, and the text is clear and legible. The names include "Michael H. Holder," "Kenneth H. Bone," "Andrew Bennett," "Richard A. Daley," "Bradley M. Foster," "Ronald A. Adams," "David R. Bender," "C