IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually and J. individually, and L.M., individually, cos Defendants/Counter-Plaintiffs. -v PLAINTIFF/COUNTER-DEFENDANT JEFF IN'S RESPONSE TO DEFENDANT/COUNTER-PLANTIFF, MOTION FOR PROTECTIVE ORDER REGARDING SU O TRUSTEE, HERBERT STETTIN FOR RECORDS OF COM A ONS BY AND BETWEEN ROTHSTEIN, ROSENFELDT & . AND GOVERNMENT/LAW ICERS ENFORCE Plaintiff/Counter-Defendant, J counsel and pursuant to the Fl Motion for Protective Order fi re, relatin (s oi a em ("Epstein"), by and through his undersigned of Civil Procedure, files this his Response to the y the Defendant/Counter-Plaintiff, bpoena issued by Epstein to the bankruptcy trustee for Rothstein, . ("RRA"), for records of communications by and between RRA and Rosenfeldt & , government enforcement officials relating to Jeffrey Epstein. 1. J. On January 4, 2011, counsel for Epstein sent a subpoena for records of emails and documents by and between RRA and government and law enforcement officials relating to Jeffrey Epstein. A copy of the subpoena is attached as Exhibit "1". 2. The records requested are relevant because of the allegation in Epstein's Amended Complaint relating to Defendant's plan to interfere with the Non-Prosecution BURNI !I PA • 901 POINT WEST, 777 SOW V FLAGIF,R DRIVE. WEST PALM BEACH, FLORIDA 33401 • (5611802-9044 EFTA02769903