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. EDWARI)S, individually, Defendants/Counter-Plaintiffs. RENEWED MOTION FOR ORDER TO TAKE SCOTT ROTHSTEIN'S DEPOSITION Plaintiff, JEFFREY EPSTEIN, by and through undersigned counsel, hereby files his Renewed Motion for Order to take the deposition of Defendant, SCOTT ROTHSTEIN (hereinafter "ROTHSTEIN") and states as grounds the following: 1. Plaintiff is seeking to take the deposition of SCOTT ROTHSTEIN in the above-styled litigation. 2. ROTHSTEIN is a party to this matter and therefore, Plaintiff is entitled to take his deposition in accordance with Rule 1.310 of the Florida Rules of Civil Procedures. 3. To the knowledge of the Plaintiff, ROTHSTEIN is currently incarcerated within the U.S. Department of Justice Federal Bureau of Prisons and is in protective custody. 4. The Federal Bureau of Prisons and the United States Bankruptcy Court for the Southern District of Florida require an Order entered by this Court to allow Plaintiff to take the deposition of ROTHSTEIN at the location where he is currently incarcerated. EFTA01107329