IN THE CIRCUIT COURT OF THE 15th 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 PRODUCTION OF DOCUMENTS BY DEFENDANTS AND FOR SANCTIONS Plaintiff, Jeffrey Epstein, by and through his undersigned counsel, hereby moves to compel Defendants to produce the documents listed in Defendants' privilege log or, in the alternative, seeks entry of an Order compelling Defendants to serve a privilege log that complies with Fla. R. Civ. P. 280(b)(5), together with an Order For Imposition of Sanctions and in support thereof would show as follows: SUMMARY OF ARGUMENT On or about February 23, 2011, Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, in response to several orders entered by Judge Raymond Ray, filed a one hundred and fifty-nine (159) page privilege log, claiming that over two thousand (2000) documents are privileged. This represents the second log which fails to meet the requirements for a legally sufficient Privilege Log. The Special Master required a master list of names contained in the log, EFTA01111326