DRAFT IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT 5/1/118:14 PM IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN. Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF'S MOTION TO OUASH SUBPOENA AND FOR PROTECTIVE ORDER TO PREVENT DEPOSITION OF ALFRED SECKEL Plaintiff Jeffrey Epstein moves the Court, pursuant to Rule 1.280 and Rule 1.410, Florida Rules of Civil Procedure, for entry of a protective order and an order quashing a subpoena commanding non-party Alfred Seckel to appear for deposition in Los Angeles, California on May 23, 2011 which subpoena Defendant Bradley J. Edwards ("Edwards") has noticed over the Plaintiffs objection. The grounds for this Motion are: I. On or about April 7, 2011, counsel to Edwards noticed the deposition of Mr. Seckel, despite the fact that counsel to Edwards was advised by Plaintiffs counsel that Mr. Seckel has no knowledge of any issue in this case and is barely known to the Plaintiff at all. A copy of the Notice and Subpoena is attached as Exhibit A. 2. The Plaintiff seeks an order quashing the subpoena and entry of a protective order to prevent the taking of this deposition indefinitely because Mr. Seckel has no relevant information about this case and to allow the deposition would effectively condone harassment. FOWLER WHITE BURNETT • • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00583806