IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO RE-OPEN DISCOVERY TO TAKE DEPOSITIONS Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), moves the Court for permission to re-open discovery for the limited purpose of taking the depositions of two of Defendant/Counter-Plaintiff Bradley J. Edwards' ("Edwards") three clients (L.M. and Jane Doe) and states: BACKGROUND Edwards is attempting to clear his name by proving that the individual allegations pled by Epstein in the original civil proceeding against Edwards were false. ("[T]his case is my only chance to finally set the record straight.") (Edwards' 11/10/17 Tr. 8:19-21.)' ("I want to right the wrong that's been done.") (Edwards' 11/10/17 Tr. 9:9-11.) Edwards claims that he has experienced anxiety every single day since the Complaint was filed in December 2009 and he is seeking compensation for that anxiety and reputational damages. ("The more reminders that I I Excerpts of Mr. Edwards' November 10, 2017, Deposition Transcript are attached as Exhibit A. EFTA00805475