JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S MOTION FOR A PROTECTIVE ORDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, hereby files his Memorandum of Law in Opposition to Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") legally and factually deficient Motion for Protective Order. In support thereof, Epstein states: INTRODUCTION On or about January 9, 2013, Edwards filed his Fourth Amended Counterclaim against Epstein, asserting therein that he suffered the following damages: "a) injury to his reputation; b) mental anguish, embarrassment, and anxiety; c) fear of physical injury to himself and members of his family; d) the loss of the value of his time required to be diverted from his professional responsibilities; e) the cost of defending against Epstein's [allegedly] spurious and baseless claims." Edwards likewise claims an entitlement to punitive damages. See Edwards's Fourth Amended Counterclaim. On April 23, 2013 Epstein, in defending this action, served upon Edwards an Amended Notice of Taking Deposition Duces Tecum. Attached thereto was a "Schedule A," delineating specific and narrowly-tailored requests for copies of items directly related 1 EFTA01107639