IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT EDWARDS' RENEWED MOTION FOR SUMMARY JUDGMENT Plaintiff, Jeffrey Epstein ("Plaintiff" or "Epstein"), hereby files the following Response in Opposition to Defendant Bradley J. Edwards' ("Edwards") Renewed Motion for Summary Judgment ("Motion") and states as follows:' SUMMARY OF ARGUMENT Edwards' Renewed Motion for Summary Judgment should be denied for numerous reasons. First, Epstein has not had an opportunity to conduct discovery essential to refute Edwards' arguments. Edwards' insufficient privilege log has tied relevant discovery in knots. Second, Edwards filed a "Statement of Undisputed Facts" with exhibits — all of which violate Rule 1.510 and should be stricken. The "undisputed facts" are impertinent and entirely irrelevant, as are the unswom and unauthenticated exhibits on which Edwards improperly relies Nothing factually new has been submitted by Edwards. The Statement of Undisputed Facts is identical to the one used for Edwards' first Motion for Summary Judgment. EFTA00808026