IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). MOTION TO COMPEL SUBSTANTIVE RESPONSE TO REOUEST TO PRODUCE SERVED APRIL 15, 2011 Bradley J. Edwards, by and through his undersigned attorneys, moves this Honorable Court to compel Jeffrey Epstein's substantive response to the attached Request to Produce over the objections asserted by Jeffrey Epstein. WHEREFORE, Bradley J. Edwards moves for an Order compelling Jeffrey Epstein to provide a substantive response to Edwards' Request to Produce served April 15, 2011. Movant counsel certifies, in good faith, they have conferred or attempted to confer with the person or party failing to make the discovery in an effort to secure the information or material without court action. EFTA00582710