IN THE CIRCUIT COURT OF THE 1 JUDICI L CIRCUIT IN AND FOR PALM EACH COUNTY, FLORID JEFFREY EPSTEIN, CASE O.: 502009CA040800 AG Plaintiff, v. SCOTT ROTHSTEIN, etc., et al., o Defendants. MOTION FOR PROTE TIVE ORDER 446) er and would state: S. Adler, Esquire, files this Motion 1. The undersigned was served with a Subpoe cause of action, set for January 20, 2011, at 9: 54) otYetibsition in the above referenced - a'-rq , which was unilaterally set by Ackerman. 2. The undersig d is a practicit 3. This deposition was un tera ey in oward County. set by Mr. ckerman, without clearing a date with the undersigned. 4. The unde i 5. deposi 's dounsel, Fred Haddad, w l be out of State until Februa Thee ime 2011. has called and emailed Mr. ckerman with regard to reset ng the d date mutually convenient f the undersigned as well as hir counsel. 6. Mr. Ackerma has not responded and ignore the undersigned's telephone calls and emails to him. WHEREFO , the undersigned prays that t s Honorable Court enter an Order granting his Motion for Protect ve Order and such further reli f as this Court deems just and proper. 1 EFTA02769254