IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and individually, Defendants. NOTICE OF TAKING DEPOSITION *Duces Tecum TO: All counsel on the attached Counsel List PLEASE TAKE NOTICE that the undersigned attorneys will take deposition(s) of: NAME AND ADDRESS Representative(s) of The Wackenhut Corporation with the most knowledge of the matters set forth below pursuant to Fla. R. Civ. P. 1.310(bX6) DATE AND TIME September 6, 2011 10:00 AM. LOCATION Searcy Denney Scarola Barnhart & Shi le PA *DUCES TECUM: TO HAVE AND BRING WITH YOU AT THE TIME OF THE DEPOSITION THE FOLLOWING: Any and all documents** reflecting or relating to services rendered: 1. at or in the general vicinity of 358 El Brillo Way, Palm Beach, FL 33480-4730; and 2. for the benefit of or at the direction of Jeffrey Epstein and/or Jack Goldberger including but not limited to documents reflecting when the services were performed, how long they were performed, the nature of the services, and by whom they were performed. EFTA01082332