WI THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)OOOCMJ3AG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and individually, Defendant(s). MOTION TO COMPEL OR ALTERNATIVELY TO STRIKE PLAINTIFF'S CLAIM FOR DAMAGES Defendant, Bradley J. Edwards, moves this Honorable Court to compel the Plaintiff to respond to the attached Request to Produce over the objections raised by the Plaintiff or alternatively, to strike the Plaintiff's claim for damages and in support would show that Plaintiffs response to Defendant's Request to Produce denies the Defendant access to basic information essential to enable the Defendant to prepare his defense against the Plaintiff's claim for damages. To the extent the Plaintiffs objections are not well-founded, they must be overruled and production must be compelled. To the extent the objections may be well-founded, the "sword/shield doctrine" precludes the Plaintiff from continuing to seek affirmative relief while maintaining his assertions of privilege. WHEREFORE, Defendant requests this Honorable Court to grant his Motion to Compel or Alternatively to Strike Plaintiff's Claim for Damages. l ECEOVIE OCT 1 4 2010 EFTA00722479