IN THE CIRCUIT COURT OF THE 15'h 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. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL AND AMEND PROTECTIVE ORDER Plaintiff, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, moves this Court to compel the production of documents from Defendant, BRADLEY J. EDWARDS ("Edwards") and to amend and lift a protective order relating to a subpoena to the Bankruptcy Trustee. The grounds for this Motion are as follows: 1. On April 12, 2010, Epstein sent a Request to Produce to Edwards requesting the following documents: 3. All emails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger, and Russell Adler and/or any attorney or representative of RRA and any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 2. On May 11, 2010, Edwards served his response to this request by stating: 3. Objection as to communications to or from investigators as that is protected by the work-product and/or attorney-client privilege. EFTA01111310