IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR PALM BEACH COUNTY Case No. 502009CA040800XXXXMBAG Judge: Hafele JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants, JOINT PRETRIAL STIPULATION Pursuant to this Court's Order Setting Jury Trial and Directing Pretrial and Mediation Procedures, Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") and Defendant/Counter- Plaintiff Bradley Edwards ("Edwards') hereby submit this Joint Pretrial Stipulation. 1. List of All Pending Motions: a. Edwards' Motion to Determine Entitlement to Adverse Inference and Precluding Epstein from Offering Evidence at Trial; b. Epstein's Motion in Limine. 2. Stipulated Facts: None. 3. Statement of Issues of Fact for Determination at Trial: a. Edwards contends that the following are issues of fact for determination at trial: 1. Whether Epstein had probable cause to bring suit against Edwards for the claims brought by him; EFTA00583839