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 RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' MOTION FOR PROTECTIVE ORDER RELATING TO =.'S DEPOSITION AND MOTION TO COMPEL M. TO ANSWER OUESTIONS RELATING TO THE CRIMES VICTIMS' RIGHTS ACT AND TO REOPEN DEPOSITION Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), responds in opposition to the Motion for Protective Order [D.E. 1026] filed by Defendant/Counter-Plaintiff, Bradley Edwards ("Edwards"), relating to the deposition of M. 1 [D.E. 1027], and moves to compel her to answer questions relating to the Crimes Victims' Rights Act ("CVRA") and to reopen her deposition, and in support states: BACKGROUND In support of his malicious prosecution Counterclaim, Edwards plans to call as witnesses his three clients — and Jane Doe. M. was a plaintiff in a lawsuit she brought against Epstein until she settled her claims in 2010. She currently is a plaintiff in the CVRA action against I Although Edwards' counsel claimed that Edwards' clients wished to remain anonymous, Edwards identified .'s name in his Motion and filed her deposition testimony with the Court. EFTA00808633