IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800X3OOCMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, and ■., individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT, JEFFREY EPSTEIN'S MOTION FOR LEAVE TO USE DOCUMENTS PRODUCED UNDER CONFIDENTIALITY AGREEMENT Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to the Florida Rules of Civil Procedure, files this his Motion for Leave of Court to use certain documents which are not privileged, which were produced under a Confidentiality Agreement by the Defendant/Counter-Plaintiff, Bradley J. Edwards ("Edwards"). The grounds for this motion are as follows: I. On or about February 23, 2011, Edwards produced documents under a Confidentiality Agreement. The production was in two parts. The first documents, were labeled for review by attorney's only. ("Attorney's Eyes Only"). The Second set of documents, were labeled irrelevant, but could be reviewed by Epstein ("Irrelevant"). Under the Agreement, if Epstein's counsel believes the documents were either not privileged or relevant, leave of court would be sought prior to disclosure. FOWLER WHTTE BURNETT P.A. • 901 PHILLIPS POINT WEST. 777 sount FLAGLER DRIVE. WEST PALM BEACH. FLORIDA 33901 • EFTA01111280