EFTA00722339

09/16/2010 14:44 FAX 
SEARCY DENNEY 
liDoovoo4 
#291874/mep 
JEFFREY EPSTEIN, 
Plaintiff(s), 
SCpTT ROTHSTEIN, individually, 
B 
LEY J. EDWARDS, individually, and 
L.M., individually, 
I 
Defendant(s). 
I 
/ 
IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CASE NO.: 502009CA040800XXXXM BAG 
DEFENDANT/COIJNTERPLAINTIFF'S REOUEST TO PRODUCE 
TO PLADITIFF/COUNTERDEFENDANT, 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. 
All statements of the Defendant, Bradley J. Edwards, pertaining to any of the 
issues in this lawsuit 
2. 
All statements of any witness you intend to use at trial for impeachment. 
3. 
All documents* including but not limited to diaries, journals, computer database 
=lends or any other written or electronically stored information that reflect or relate to any 
communication to or from minor females and/or any physical contact which did or was planned 
to bccur between you and any person who was a minor female" at the time of the physical 
cotdact or planned physical contact including but not limited to any massage, fondling, or sexual 
EFTA00722339

09/10/2010 14:44 FAX 
SEARCY DENNEY 
U1002/004 
s adv. Epstein 
No.: 302009CA040800XXXXMBAG 
Request to Produce to Jeffrey Epstein 
interaction of any kind (this should include all message pads or appointment scheduler for minor 
feriales"). 
4. 
All written documents supporting the allegations in your complaint. 
5. 
All message pads, calendars of your schedule or appointments or other documents 
containing your "massage" appointments; and 
6. 
A complete copy of each and every exhibit which you intend to introduce or have 
considered introducing into evidence at trial. 
"Documents" shall include, but not be limited to all non-identical copies of writings, 
draWings, graphs, charts, photographs, phono-records, recordings, and/or any other data 
corlimilations from which information can be obtained, translated, if necessary, by the party to 
whom the request is directed through detection devices into reasonably usable form. 
"Dtcuments" also include all electronic data as well as application metadata and system 
metadata. 
All inventories and rosters of your information technology (IT) systems—e.g., 
hardware, software and data, including but not limited to network drawings, lists of computing 
devices (servers, PCs, laptops, PDAs, cell phones, with data storage and/or transmission 
features), programs, data maps and security tools and protocols. 
It is requested that the aforesaid production be made within thirty days of service of this 
request at the offices of Searcy Denney Scarola Barnhart & Shipley, M., 2139 Palm Beach 
- "minor females" is defined as females who were known by you at the time or who are now !mown to you to have 
beed under 18 yearn of age at the time of your interaction with diem, and females who you now bavc mason to 
believe may have been under 18 years of age at the time of your interaction with them. 
2 
EFTA00722340

09/16/2010 14:45 FAX 
SEARCY DENNEY 
lib003/004 
Edwards adv. Epstein 
Case No.: 502009CA040800=0CMBAG 
Request to Produce to Jeffrey Epstein 
Lakes Boulevard, West Palm Beach, Florida. Inspection will be made by visual observation, 
examination and/or copying. 
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by 
Fax and U.S. Mail to all Counsel on the attached list, th 
110.1)—day of 
la `• 
Bar No.: 169440 
cy Denney Scarola Barnhart & Shipley 
139 Palm Beach Lakes Boulevard 
West Palm Beach. Florida 33409 
Phone: 
Fax: 
Attorneys for 
2010. 
3 
EFTA00722341

09/16/2010 14:45 FAX 
SEARCY DENNEY 
in004/004 
Edwards
' 
adv. Epstein 
Ca+ No.: 502009CA040800,OOOCM:BAG 
Request to Produce to Jeffrey Epstein 
COUNSEL LIST 
Jack A. Goldberger, Esquire 
Attetbury, Goldberger & Weiss, M. 
25C Australian Avenue South, Suite 1400 
Wet Palm Beach, FL 33401 
PFac
iliar 
Carp? M. Farmer, Esq. 
Farmer, Jaffe, Weissing, Edwards, Fistos & 
Le 
an, PL 
42 N. Andrews Avenue, Suite 2 
Fo Lauderdale FL 33301 
Phone:
Pale 
Marc S. Nurik, Esq. 
Law Offices of Marc S. Nurik 
One E Broward Blvd., Suite 700 
Fort Lauderdale FL 33301 
Phcine: 
Fax: 
Christopher E. Knight, Esq. 
Joseph L. Ackerman, Esq. 
Fovher White Burnett, PA. 
777. S Flagler Drive, Suite 901 
West Palm Beach FL 33401 
Phone: 
Fax' 
4 
EFTA00722342