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. COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO UNSEAL DISC AND PROPOSED TRIAL EXHIBITS FOR USE AT BANKRUPTCY COURT SHOW CAUSE PROCEEDINGS AND DEPOSITIONS Counter-Defendant Jeffrey Epstein ("Epstein") moves to unseal the disc labeled "Epstein Bate Stamp" and the 47 documents identified on Epstein's March 5, 2018, Clerk's Trial Exhibit List for the limited purpose of the Bankruptcy Court's show cause proceedings and depositions, and in support thereof, states: INTRODUCTION Counter-Plaintiff Bradley J. Edwards ("Edwards"), along with Fanner Jaffe and Intervenors L.M., E.W. and Jane Doe (collectively, the "Bankruptcy Movants") have moved the Bankruptcy Court for an Order to show cause why a November 2010 Agreed Order' has not been violated and for sanctions. The subject of those proceedings is a disc labeled "Epstein Bate Stamp" 'November 30, 2010, Agreed Order Cancelling Hearing on Motion for Relief from the Amended Order (DE 1068) and to Compel Jeffrey Epstein to Pay for the Production of All Documents in Response to His Requests Filed by Interested Party Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., In re Rothstein Rosenfeld! Adler, P.A., United States Bankruptcy Court, Southern District of Florida, Case No. 09-34791-RBR [D.E. 1194]. EFTA00805483