UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION www.flsb.uscourts.gov CASE NO.: 09-34791-RBR Chapter 11 IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. AGREED EX PARTE MOTION FOR ENTRY OF STIPULATED PROTECTIVE ORDER AND CONFIDENTIALITY ORDER BY AND BETWEEN TRUSTEE AND JEFFREY EPSTEIN (Expedited Relief Requested) Herbert Stettin, the Chapter 11 Trustee ("Trustee") of the Debtor, Rothstein Rosenfeldt Adler, P.A. ("RRA"), and Plaintiff, Jeffrey Epstein ("Epstein"), Plaintiff in action, Jeffrey Epstein v. Scott Rothstein and Bradley Edwards, Circuit Court of the Fifteenth Judicial Circuit, Palm Beach County, Florida, Case No. 502009CA040800XXXXMB, by and through undersigned counsel, do hereby file this Stipulated Protective Order ("SPO") and Agreed Confidentiality Order ("ACO") by and between the Trustee and Epstein, attached hereto as Exhibits "A" & "B", and in support thereof state: I. Pursuant to this Court's Order Granting Trustee's Motion Seeking a Protective Order and Approving Proposed Document Production Protocol ("Order") [D.E. #672] and Order Granting Trustee's Motion to Modify Document Production Protocol ("Modified Order") [D.E. #1989], the Trustee and Epstein jointly move for the entry of the SPO and ACO attached hereto as Exhibits "A" & "B". EFTA01176822