IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). MOTION TO DETERMINE ENTITLEMENT TO ADVERSE INFERENCE AND PRECLUDING EPSTEIN FROM OFFERING EVIDENCE AT TRIAL Bradley Edwards, by and through his undersigned attorneys, moves this Honorable Court to determine his entitlement to an instruction to the jury before whom this matter shall be tried, that the jury is entitled to conclude solely on the basis of Epstein's refusal to answer that had Jeffrey Epstein responded truthfully to any relevant discovery request as to which he has refused to answer or respond based upon an assertion of his Fifth Amendment privilege, that all such answers and responses would, in fact, have implicated him in the commission of a crime or would otherwise have disclosed information adverse to Jeffrey Epstein's interests in this lawsuit. Bradley Edwards further moves this Honorable Court to enter an Order precluding Jeffrey Epstein from offering evidence or testimony as to any matter about which he has declined on the basis of the assertion of privilege to provide pre-trial discovery. EFTA01084184