IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. Complex Litigation, Ha. R. Civ. Pro.1201 Case No. 50 2009CA040800XXXXMB AG AMENDED AND SUPPLEMENTAL MOTION OF PLAINTIFF TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT EDWARDS TO ANSWER QUESTIONS AND APPEAR FOR FURTHER DEPOSITION Plaintiff Jeffrey Epstein ("Epstein") moves the court, pursuant to Rule 1.380(a), Fla. R. Civ. P., for entry of an order directing Defendant Bradley J. Edwards ("Edwards") to appear forthwith for further deposition before a court appointed Special Master and to respond to questions asked of him at his deposition taken on March 23, 2010 and to answer such follow up questions as are appropriate. This motion is in addition to and supplements a previously filed motion on May 10, 2010 seeking the similar relief. The grounds for this motion are: 1. Late last year, Epstein filed this action to recover damages from Defendants, Scott Rothstein ("Rothstein") and Edwards, based on Epstein's well founded belief that the two, and possibly others, had perpetrated an illegal pyramid scheme directed toward unwitting investors who were defrauded into investing in settlements allegedly concerning Epstein as its centerpiece defendant who reportedly had settled and was expected to settle cases worth millions of dollars with clients of Rothstein Rosenfeldt & Adler ("RRA"). EFTA01111246