Filing # 23082060 E-Filed 01/28/2015 02:43:13 PM JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XVOCMBAG PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR AN ORDER OF PROTECTION AND INCORPORATED MEMORANDUM OF LAW Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, hereby requests that this Court enter an Order of Protection from Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") January 21, 2015 Notice of Taking Deposition (videotaped) of Jeffrey Epstein and Edwards's January 21, 2015 Requests for Production to Epstein. In support thereof, Epstein states: INTRODUCTION On May 19, 2014, this Court granted Epstein's Motion for Summary Judgment as to both counts of Edwards's Complaint. This Court entered Final Judgment in favor of Epstein on May 27, 2014. On June 2, 2014, Epstein filed his Motion for Costs and Attorneys' Fees pursuant to §768.79 of the Florida Statutes and Rule 1.442 of the Florida Rules of Civil Procedure. This Motion is still pending, but all issues were fully briefed by the parties as requested by this Court as of January 12, 2015. Epstein's entitlement to Costs and Attorneys' Fees is a question of law for the Court, as it is the Court which must determine whether Epstein's Proposal for Settlement and its attached release agreement were in compliance with the applicable Florida Statute and Florida Tonja Haddad, . • 315 SE 7th Street, Fort Lauderdale, FL 33301• 954.467.1223 EFTA00592733