#291874/mep JEFFREY EPSTErN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXAMAG MOTION FOR PROTECTIVE ORDER, OBJECTIONS TO CANCELLED NOTICE OF DEPOSITION DUCES TECUM OF RECORDS CUSTODIAN OF TRUSTEE HERBERT STETTIN [JANUARY 20, 2011, AND MOTION FOR APPOINTMENT OF ROBERT CARNEY AS SPECIAL MASTER Defendant/Counter-Claimant Bradley J. Edwards, through counsel, files this Motion for Protective Order, Objections to Plaintiff's Notice of Deposition Duces Tecum of Records Custodian of Trustee Herbert Stettin, and Motion for Appointment of Robert Carney as Special Master and states the following: 1. Plaintiff Jeffrey Epstein has directed two discovery requests to the Trustee. This motion is directed at the second discovery request. 2. Epstein claims that he served his second Trustee discovery request, a Notice of Deposition Duces Tecum of Records Custodian of RRA Bankruptcy Trustee Herbert Stettin ("Trustee Depo Notice"), scheduled for January 20, 2011. The deposition was cancelled upon an agreement reached between counsel for Epstein and the Trustee respectively. EFTA00283658