IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Complex Litigation, Fla. IL Civ. P. 1.201 Case No. 50 2009CA040800XVOCMB AG JEFFREY EPSTEIN, Plaintiff, V. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. I BANKRUPTCY TRUSTEE'S MOTION FOR PROTECTIVE ORDER Pursuant to Rule 1.410, Herbert Stettin, Trustee of the Bankruptcy Estate of Rothstein Rosenfeld Adler, P.A., files this Motion for Protective Order and states: 1. On November 10, 2009, Rothstein Rosenfeld) Adler, P.A. ("RRA") was put into involuntary bankruptcy. That case is pending as In Re Estate of Rothstein Rosenfeld Adler, P,A., On November 20, 2009, Herbert Stettin was appointed Trustee of RRA. On November 30, 2009, an Order for Relief was entered by this Court. 2. On April 16, 2010, Plaintiff caused a subpoena duces tecum to be served on the Trustee for production of documents. A copy of the subpoena duces tecum is annexed hereto as Exhibit A. 3. The Trustee's responsibility under the involuntary bankruptcy filing is to wind- down the business affairs of RRA. In that regard, the Trustee has three (3) people in his employ P4, "R„QER. S INGERMANI v.."" attorneys at law acrd train. ter! Lowder's'. Miami TT 200 South Biscayne Boulevard Suite 1000 Miami, Florida 33131-5308 Telephone 306.766.9600 Facsimile 306.714.4340 EFTA00725165