IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF JEFFREY EPSTEIN'S REPLY TO EDWARDS' RESPONSE IN OPPOSITION TO JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER RELATING TO HIS DEPOSITION AND MOTION TO TERMINATE DEPOSITION Plaintiff, Jeffrey Epstein ("Epstein"), hereby offers the following reply to Edwards' Response in Opposition to Epstein's Motion for a Protective Order to prevent Defendant, Bradley J. Edwards ("Edwards"), from inquiring into certain areas at the second deposition of Plaintiff, and to terminate the deposition of the Plaintiff for the reasons set forth below: ARGUMENT I. NO UNFETTERED DISCOVERY This Court has already ruled that discovery will not be permitted into sexual conduct. Edwards contends, however, that he is entitled to take "broad discovery" of Epstein, including inquiring about any aspect of Epstein's sex life at any time and place in part because Epstein charges him with making "'unfounded and highly charged sexual allegations" in the underlying litigation. (Resp. at 2, quoting Corrected Second Amended Complaint at 2.) Edwards has EFTA00597778