EFTA00801479Set 9
2016-08-0819p2,944w
interest of any sort;
EXHIBIT B
EFTA00801488
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
(b) The serial number of each bond, share, stock certificate or other evidence ... interest, state:
(a) The address,
2
EFTA00801489
Case No.: 502009CAD40800XXXXMBAG
Notice of Serving Net Worth Interrogatories
(b) The legal description of the property;
(c) The assessed value of the property ... since the time of purchase:
3
EFTA00801490
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
(g) The name and address of each real estate agent with whom the property
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801479.pdf
EFTA00593892Set 9
2015-12-298p1,737w
should
issue a protective order staying Dershowitz's obligation to respond to the "net worth"
interrogatories, the "punitive damages" document requests, and any further discovery that
Plaintiffs may seek that ... Punitive Damages" Discovery
1. On November 24, 2015, Plaintiffs served more than 57 "Net Worth
Interrogatories," including numbered subparts (which number does not include all of the
multiple ... This set of "Net Worth Interrogatories" is in addition to the 58 Interrogatories that
Plaintiffs previously served on Dershowitz.
2. The "Net Worth Interrogatories" seek extraordinarily detailed personal financial
information
https://www.justice.gov/epstein/files/DataSet%209/EFTA00593892.pdf
EFTA00617113Set 9
2017-05-2515p1,547w
security interest of any sort;
EFTA00617119
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
(b) The serial number of each bond, share, stock certificate or other evidence
of ownership ... interest, state:
(a) The address,
2
EFTA00617120
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
(b) The legal description of the property;
(c) The assessed value of the property ... since the time of purchase;
3
EFTA00617121
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
(g) The name and address of each real estate agent with whom the property
https://www.justice.gov/epstein/files/DataSet%209/EFTA00617113.pdf
EFTA00613719Set 9
15p1,528w
security interest of any sort;
EFTA00613725
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
(b) The serial number of each bond, share, stock certificate or other evidence
of ownership ... interest, state:
(a) The address,
2
EFTA00613726
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
(b) The legal description of the property;
(c) The assessed value of the property ... since the time of purchase;
3
EFTA00613727
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Net Worth Interrogatories
(g) The name and address of each real estate agent with whom the property
https://www.justice.gov/epstein/files/DataSet%209/EFTA00613719.pdf
EFTA00801993Set 9
94p19,003w
notice that pursuant to Rule 1.340(e),
Florida Rules of Civil Procedure, that Net Worth Interrogatories numbered 1 through 13 have
been directed to Counterdefendant, JEFFREY EPSTEIN, this ... BRADLEY J. EDWARDS,
individually. JUDGE: CROW
Defendants.
PLAINTIFF/COUNTER-DEFENDANT EPSTEIN'S AMENDED RESPONSES TO
NET WORTH INTERROGATORIES TO JEFFREY EPSTEIN
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein'), by and through his
undersigned counsel ... Civil Procedure
hereby files his amended responses to Defendant/Counter-Plaintiff Bradley Edward's Net
Worth Interrogatories to Jeffrey Epstein:
1. What is your full name?
ANSWER: Jeffrey Edward Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801993.pdf
EFTA01107625Set 9
2012-12-1814p3,914w
Protective Order from
Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") Request for Production and
Net Worth Interrogatories. In support thereof, Epstein states:
INTRODUCTION
On December 18, 2012, this court granted Edwards ... discovery requests, to wit: Request for Production and Notice of Service of
Interrogatories (hereinafter together "financial net worth discovery"). See Exhibit A,
attached hereto. Edwards, however, had not yet served ... enter a Protective Order from Defendant/Counter-Plaintiff Bradley Edwards's Request
for Production and Net Worth Interrogatories, and grant such other and further relief as
deemed necessary and proper.
WE HEREBY
https://www.justice.gov/epstein/files/DataSet%209/EFTA01107625.pdf
EFTA00801703Set 9
2017-09-216p1,285w
Edwards' (1) April 15, 2011 Requests to Produce, (2) December
21, 2012 Interrogatories (Net Worth), (3) December 21, 2012 Request for Production (Punitive
Damages), and (4) February 26, 2013 Requests ... Request to Produce. (Exhibit E.)
July 9, 2013 — Epstein's Amended Responses to Net Worth Interrogatories and
Amended Responses to Edwards' Request for Production (Punitive Damages).
(Exhibits ... returns
and stipulated that his present net worth is more than $100 million. See July 9, 2013 Amended
Response to Interrogatory No. 14. (Exhibit F.) These disclosures provided sufficient
information
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801703.pdf
EFTA00801130Set 9
12p2,013w
exhibits to our
21 motion, Mr. Epstein has already filed
22 interrogatory responses related to his net
23 worth for the punitive damages, and we have
24 attached for your ... appropriate, they are limited, and the
22 fact that prior answers to net worth
23 interrogatories were filed, which I believe to
24 be deficient to begin with ... going to grant the motion to expand
21 the interrogatories, treat the net worth
22 interrogatories to the extent that the
23 responses were provided fully in the prior
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801130.pdf
EFTA01107356Set 9
9p2,606w
ROTHSTEIN, individually,
and BRADLEY J. EDWARDS,
individually.
Defendants.
PLAINTIFF/COUNTER-DEFENDANT EPSTEIN'S RESPONSES TO NET
WORTH INTERROGATORIES TO JEFFREY EPSTEIN
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his
undersigned counsel ... Rules of Civil Procedure
hereby files his responses to Defendant/Counter-Plaintiff Bradley Edward's Net Worth
Interrogatories to Jeffrey Epstein:
I. What is your full name?
Jeffrey Edward Epstein ... reason for performing the calculation or estimate;
d. The amount of net worth calculated or estimated.
Objection. This Interrogatory is overly burdensome, as it is well-settled law that
only
https://www.justice.gov/epstein/files/DataSet%209/EFTA01107356.pdf
EFTA01111222Set 9
2013-05-1718p5,126w
PROCEEDINGS
On February 22, 2013, Epstein filed his responses to Edwa
rds's Net Worth
Interrogatories and Request for Production. On February 25, 2013,
in response, Edwards filed
a Motion ... privil
ege log is required for
Mr. Epstein's responses to the Net Worth Interrogatories. Howe
ver, because responses to
Interrogatories must be verified; sworn to under Oath,
they ... Jeffrey Epstein's
(the "Plaintiff") Objections to Defendant/Counter-Plaintiff's
Request for Production and Net
Worth Interrogatories. This Court, having carefully
reviewed the Plaintiff's objections and all
applicable legal authority
https://www.justice.gov/epstein/files/DataSet%209/EFTA01111222.pdf
EFTA01105079Set 9
2013-06-175p891w
constitutional claims of privilege in response
to Defendant/Counter Plaintiff Bradley Edwards's Net Worth Interrogatories and Requests for
Production (hereinafter "the Order"). In support thereof, Epstein states:
SUMMARY OF PROCEEDINGS ... EFTA01105079
On February 22, 2013, Epstein filed his responses to Edwards's Net Worth
Interrogatories and Request for Production. On February 25, 2013, Edwards filed a Motion to
Strike Untimely ... Exhibit A." In response thereto, Epstein filed Amended responses to
Edwards's Net Worth Interrogatories and Request for Production, in which he only asserted
2
EFTA01105080
his Fifth Amendment Privilege
https://www.justice.gov/epstein/files/DataSet%209/EFTA01105079.pdf
EFTA00808813Set 9
2017-09-153p578w
JEFFREY EPSTEIN'S RESPONSE TO BRADLEY EDWARDS'S MOTION TO
OC MPEL RESPONSES TO INTERROGATORIES
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned
counsel and pursuant to this Court ... Edwards's "updated" Net Worth Interrogatories, Epstein asserted his Fifth
Amendment Privilege to some of the Interrogatories, just as he did to Edwards's Initial Net
Worth Interrogatories with which ... questions related to his net worth solely because of actions
taken by Edwards. As stated in his responses to the Interrogatories at issue, Epstein's "concern
is in part derived
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808813.pdf
EFTA01085298Set 9
13p3,340w
individually,
and BRADLEY J. EDWARDS,
individually.
Defendants.
PLAINTIFF/COUNTER-DEFENDANT EPSTEIN'S AMENDED RESPONSES TO
NET WORTH INTERROGATORIES TO4EFFREY-EPST-EIN
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his
undersigned counsel ... Civil Procedure
hereby files his amended responses to Defendant/Counter-Plaintiff Bradley Edward's Net
Worth Interrogatories to Jeffrey Epstein:
I. What is your full name?
Jeffrey Edward Epstein ... calculation or estimate of your net worth at any time in the five years
immediately preceding your receipt of these interrogatories, state:
a. The date of the calculation or estimate
https://www.justice.gov/epstein/files/DataSet%209/EFTA01085298.pdf
EFTA00317211Set 9
2010-02-0437p13,297w
each apply to request number 1 of Plaintiff's First
request to produce Net Worth Discovery.
The Request for Production and the responses thereto arc attached as Composite
Exhibits ... gild the lily" as Plaintiff contends nor are they misleading. Despite what the
interrogatory sought, Plaintff chose to limit same in her Reply to only what the Federal
Government gave ... information through deposition or
disclosure in an affidavit by the requested party of net worth, wealth, and income. Id. at 331-32.
See Barton v. Cascade Regional Blood Services
https://www.justice.gov/epstein/files/DataSet%209/EFTA00317211.pdf
EFTA01117340Set 9
2010-02-0437p13,297w
each apply to request number 1 of Plaintiff's First
request to produce Net Worth Discovery.
The Request for Production and the responses thereto arc attached as Composite
Exhibits ... gild the lily" as Plaintiff contends nor are they misleading. Despite what the
interrogatory sought, Plaintff chose to limit same in her Reply to only what the Federal
Government gave ... information through deposition or
disclosure in an affidavit by the requested party of net worth, wealth, and income. Id. at 331-32.
See Barton v. Cascade Regional Blood Services
https://www.justice.gov/epstein/files/DataSet%209/EFTA01117340.pdf
EFTA01112365Set 9
2013-05-179p2,220w
Constitutional Privilege Against
Self- Incrimination in response to Defendant/Counter Plaintiff Bradley Edwards's Net
Worth Interrogatories and Requests for Production (hereinafter "the Order"). In support
thereof, Epstein states:
1
EFTA01112365 ... PROCEEDINGS
On February 22, 2013, Epstein filed his responses to Edwards's Net Worth
Interrogatories and Request for Production. On February 25, 2013, in response,
Edwards filed a Motion ... privilege log is
required for Mr. Epstein's responses to the Net Worth Interrogatories. However,
because responses to Interrogatories must be verified; sworn to under Oath, they are
irrefutably testimonial
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112365.pdf
EFTA00614294Set 9
2015-11-242p175w
CASSELL,
Plaintiffs,
vs.
ALAN M. DERSHOWITZ,
Defendants.
PLAINTIFF'S NOTICE OF SERVING NET WORTH
INTERROGATORIES TO DEFENDANT
Bradley J. Edwards, by and through his undersigned attorneys, hereby give notice that ... pursuant to Rule 1.340(e), Florida Rules of Civil Procedure, that Net Worth Interrogatories
numbered 1 through 15 have been directed to Defendant, Alan M. Dershowitz, this 2c(4-iday ... Plaintiffs
EFTA00614294
Edwards, Bradley vs. Dershowitz
Case No.: CACE 15.000072
Notice of Serving Net Worth Interrogatories to Defendant
COUNSEL LIST
Sigrid Stone McCawley, Esquire
Attorneys for Alan M. Dershowitz
Attorneys
https://www.justice.gov/epstein/files/DataSet%209/EFTA00614294.pdf