UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA Fort Lauderdale Division IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A. Debtor. CASE NO. 09-3479I-BKC-RBR CHAPTER 11 JEFFREY EPSTEIN'S RENEWED MOTION FOR ENTRY OF ORDER GRANTING LEAVE TO DEPOSE SCOTT W. ROTHSTEIN AND FOR AN ORDER RE-CERTIFYING TO THE DISTRICT COURT THE NEED FOR MORE TIME TO DEPOSE SCOTT W. ROTHSTEIN COMES NOW, Interested Party Jeffrey Epstein, by and through his undersigned counsel, and hereby files his Renewed Motion for the entry of an Order granting Jeffrey Epstein leave to depose SCOTT W. ROTHSTEIN. The grounds for this Motion are as follows: 1. On June 2, 2011, this Court entered its Agreed Order Granting, In Part: The Motion of Trustee Herbert Stetting to issue a Writ of Habeas Corpus Ad Testlficandum (D.E. 1595); Gibraltar Private Bank & Trust's Motion for Leave to Depose Scott Rothstein and for Certification to District Court for Issuance of Writ of Habeas Corpus Ad Testificandum (D.E. 1660); and Razorback Creditors' Motion for issuance of Writ of Habeas Corpus Ad Testlficanduni to Depose Scott W. Rothstein in State Court Litigation [D.E. 1685) and Establishing Protocol for Examination and Deposition (the "Rothstein Deposition Protocol Order") [D.E. 1751]. 2. Paragraph 2 of the Rothstein Deposition Protocol Order states, inter alia, that "[a]ll parties who have not as of the date of this Order secured permission to depose [Scott] Rothstein and who wish to take his deposition shall: a) secure from the court in which the litigation is pending an order granting leave to depose Rothstein..." EFTA01111276