IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, JUDGE: DAVID CROW VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, MOTION IN LIMINE TO PRECLUDE AT TRIAL THE USE OF THE FOLLOWING ITEMS LISTED ON EDWARDS'S REVISED EXHIBIT LIST Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel moves for an Order in Limine precluding Defendant/Counter- Plaintiff Bradley Edwards ("Edwards") and his Counsel from making any mention of the below-listed matters. In support thereof, Epstein states: INTRODUCTION This motion in limine seeks to prohibit any reference to evidence at trial by first having its inadmissibility determined outside the presence of the jury. Rosa v. Fla. Power & Light Co., 636 So. 2d 60, 61 (Fla. 2d DCA 1994). The purpose of this motion in limine is to prevent Edwards from offering improper evidence at trial, the mere mention of which would be prejudicial. Buy-Low Save Ctrs., Inc. v. Glinert, 547 So. 2d 1283, 1284 (Fla. 4th DCA 1999); Dailey v. Multicon Dev., Inc., 417 So. 2d 1106, 1107 (Fla. 4th EFTA00598330