IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF'S MOTION FOR PROTECTIVE ORDER TO PREVENT VIDEO DEPOSITION Plaintiff Jeffrey Epstein moves the Court for entry of a protective order, pursuant to Florida Rule of Civil Procedure 1.280, to prevent the taking on April 13, 2011 of Mr. Epstein's further deposition which Defendant Bradley J. Edwards ("Edwards") has noticed over the Plaintiffs objection. The grounds for this Motion are: 1. On or about March 30, 2011, counsel to Edwards noticed the video deposition of the Plaintiff for April 13, 2011 in West Palm Beach, Florida to retake the deposition of the Plaintiff, despite the fact that he was advised by Plaintiffs counsel that the Plaintiff was unavailable during this time and that there was no basis for the taking of a second deposition when the Plaintiff had already been deposed in 2010. A copy of the Notice is attached as Exhibit A. 2. The Plaintiff seeks a protective order to prevent his further deposition at this time because (a) he has already been deposed at length; (b) no meaningful grounds have been alleged to justify the taking of a second deposition other than the unsubstantiated assertion that the FOWLER WHITE BURNETT m• 901 PHILLIPS POINT WEST, 777 SOUTH FIADIER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (S61) 802.9044 EFTA00621428