Filing # 59288959 E-Filed 07/20/2017 01:27:48 PM 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). REQUEST TO PRODUCE TO JEFFREY EPSTEIN Bradley J. Edwards, by and through his undersigned counsel, requests, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that Jeffrey Epstein produce and permit Bradley J. Edwards to inspect and copy each of the following documents*: 1. Any and all documents* constituting or referencing directly or indirectly any communication between you and any other person (other than an attorney rendering legal services to you unless shared with any non-lawyer) which communication references directly or indirectly Bradley Edwards, this pending litigation or litigation involving Ghislaine Maxwell. *"Documents" shall include, but not be limited to all non-identical copies of writings, drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data compilations from which information can be obtained, translated, if necessary, by the party to whom the request is directed through detection devices into reasonably usable form. "Documents" also include all electronic data as well as application metadata and system metadata. All inventories and rosters of your information technology (IT) systems—e.g., hardware, software and EFTA00593718