IN THE CIRCUIT COURT OF THE 1 EENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT'S MOTION FOR CONTINUANCE AND TO EXTEND PRE-TRIAL DEADLINES OR BIFURCATION OF TRIAL! Plaintiff/Counter-Defendant Jeffrey Epstein ("Plaintiff') moves under Rule 1.460 of the Florida Rules of Civil Procedure for a brief 90-day continuance of the special set 10-day trial commencing on December 5, 2017, and to extend the pre-trial deadlines. In the alternative, Plaintiff moves under Rule 1.270 of the Florida Rules of Civil Procedure to bifurcate the trial and limit the first stage of the proceedings to: (i) Plaintiff's damages against Defendant Scott Rothstein and (ii) the absence of probable cause element of Defendant/Counter-Plaintiff Bradley Edwards' ("Defendant") malicious prosecution claim. BACKGROUND Although this case has been pending since December 2009, in May 2014, this Court granted final summary judgment in Plaintiffs favor. Defendant appealed, and the Fourth District Court of Appeal reversed and remanded in November 2015, with the Mandate issuing in December I Counsel for Plaintiff has contacted counsel for Defendant, who [opposes] this motion. EFTA00597890