IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation Fla.R.Civ.Pro. 1201- Civil — Div. Case No 502009CA040800XXXXMB Judge: AG — David Crow SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and ■., individually, v. Plaintiff, Defendants. PLAINTIFF, JEFFREY EPSTEIN'S MOTION TO TAKE JUDICIAL NOTICE Plaintiff, Jeffrey Epstein ("Epstein"), by and through his undersigned representative and pursuant to Sections 90.202(6)(12) and 90.203, Florida Statutes (2006), files this Motion to Take Judicial Notice and in support thereof would state the following: 1. The Defendant, Bradley J. Edwards ("Edwards") has filed a Motion for Summary Judgment against Epstein, which is presently set for hearing before this Court on January 5, 2011. 2. The basis of the Plaintiffs Response in Opposition to Edwards' Motion for Summary Judgment concerns in part filed court records in the following Cases: A. In re Rothstein Rosenfeldt Adler, •, Debtor, Case No. 09-34791-RBR filed in the United States Bankruptcy Court, Southern District of Florida, Fort Lauderdale Division B. Herbert Stettin, Chapter 11 Trustee, Plaintiff v. Russell Adler and Katie Adler, Defendants. ADD. PRO. NO. 10-02612-BKC-RBR-A 3. Section 90.202(6), Florida Statutes, provides this Court discretion to take judicial notice of "records of any court of this state..." See also Michael Falls v. National Environmental Products, a al., 665 So. 2d 320, 321 (Fla. 4th DCA 1995) (holding that "it is fitting and proper that a court should take judicial notice of other actions...which bear a relationship to the case at bar"). 4. Section 90.202(12), moreover, allows this court to take judicial notice of records EFTA01081107