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 individually, Defendant(s). REQUEST TO PRODUCE Counter-plaintiff, 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. All invoices, communications, reports, summaries, and other documents of any description constituting, reflecting, or relating directly or indirectly to any effort or the results of any effort to subject Bradley Edwards to surveillance or to otherwise monitor the movements or activities of Bradley Edwards. "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. EFTA00608309