#291874/mep 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 L.M., individually, Defendant(s). / REQUEST TO PRODUCE TO i Defendant/Counter-Plaintiff, Bradley J. Ed rtJ,f bind through his undersigned counsel, requests, pursuant to Rule 1.350 of the Flo( of Civil Procedure, that Plaintiff/Counter Defendant, Jeffrey Epstein, produce a rmit c( radley J. Edwards to inspect and copy each of the following documents*: 1. All document con #Eating, reflecting, or relating to communications between Plaintiff or any nt of Plaintiff, on the one hand, and William Scherer, or any person associate th William Scherer in the practice of law, any prosecuting, law enforcement, edfiment entity which communication relates directly or indirectly to any e gage: of illegal activity or tortuous conduct in which Epstein is alleged to have + *"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 STEIN EFTA00795460