02/01/2012 16:11 FAX 5616845816 SEARCY DENNEY liboovois JEF v REY EPSTEIN, Plaintiff, SCOTT ROTHSTELN, individually, BRAD I LEY J. EDWARDS, individually, and individually, Defendant, 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003OOOOvIBAG DEFENDANT/COUNTER-PLAINTIFF, BRADLEY J. EDWARDS, RESPONSE IN dPPOSITION TO JEFFERY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER RBLATING TO HIS DEPOSITION AND IN SUPPORT OF EDWARDS' MOTINO TO COMPEL AND IMPOSE SANCTIONS j Defendant/Counterplaintiff, Bradley J. Edwards (hereinafter EDWARDS), by and throligh his undersigned attomeys, respectfully responds in opposition to Plan tiff/Counterdefendant, Jeffrey Epstein's (hereinafter EPSTELN) motion for a protective orde[ and to terminate his deposition. The motion is ffivolous and should be denied. EPSTEIN has filed a Complaint against EDWARDS that alleges that EDWARDS filed lawsltits making "unfounded . . . sexual allegations" and pleading "a causc of action for RICO wheii there was no good faith basis for doing so." EPSTEIN's Complaint further alleges that much of the discovery EDWARDS look in support of these lawsuits "had no legitimate purpose." In prior filings with this Court, EDWARDS has painstakingly detailed under oath the gooci faith basis for every claim he brought and every step be took in the prosecution of Chose clainps. In defense of the lawsuit against him, EDWARDS is now obviously entitled to ask EFTA00294291