IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. BRADLEY J. EDWARDS, et al., Defendants/Counter-Plaintiff. Case No. 50 2009 CA 040800XXXXMBAG JUDGE HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR TEMPORARY STAY OF PROCEEDINGS Now comes the Plaintiff/Counter-Defendant Jeffrey Epstein, by and through undersigned counsel, and hereby respectfully moves this Honorable Court to temporarily stay the above- captioned proceedings pending the outcome of a related quasi-criminal matter, Doe v. United States, No. 08-cv-80736-ICAM (S.D. Fla.) (the "Doe Case"), brought by attorney Bradley J. Edwards on behalf of two civil claimants in the United States District Court for the Southern District of Florida. Mr. Edwards should not be permitted to pursue a monetary damage lawsuit against Mr. Epstein seeking large punitive damages amounts on behalf of himself while also contemporaneously pursuing a federal lawsuit which has as its articulated and ultimate aim the invalidation of a Non-Prosecution Agreement thus requiring Mr. Epstein to assert the Fifth Amendment and forego affirmative testimony that would be pivotal in his defense against the ongoing civil litigation.' ' Mr. Epstein, having withdrawn his claims, is, at this stage of the proceedings, a de facto defendant answering Mr. Edwards' counterclaims. 1 EFTA00800924