• IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY CIVIL DIVISION CASE NO.: 502009CA040800 AG JEFFREY EPSTEIN, Plaintiff(s), vs. -0 r SCOTT ROTHSTEIN, etc., et al., / OMNIBUS ORDER IN REGARD TO UPDATE DEPOSITION THIS CAUSE came before the Court upon v J. . t p rn S yn v.o (-^ DSO ..13 Defendant(s). Defendant, 'Gs --- request for upda kfi ions in regar1:1-* tat tne on of JEFFREY EPSTEIN, as well as a Request to Produce served upon EDW S against JEFFREY EPSTEIN. d argument and has reviewed the The Court h pleadings and is otherwise fully advised CONSIDERED, ORDER The Defendant C in regard to the specific is 1 . LA Motions to Impose Sanctions premises. Based upon the foregoing, it is ND ADJUDGED as follows: exh itled to take an update deposition of the Plaintiff "identified and more specifically relating to public statements made by thetAitiff regarding his criminal activity, testimony dealing with any claim the Pliichas waived his Fifth Amendment rights and/or has otherwise lost Motion to Compel and Impose his Fifth A dm nt rights. The Defendant Sanctidcll Failure to Attend the Deposition is denied. In regard to the Request to Produce submitted to the Defendant by the Plaintiff under certificate of service the 7th day of April, 2011, the Court recognizes that there is a difference between "fact work product", "opinion work product", and "contention discovery". "Opinion work product" is almost never discoverable, "fact work product" is discoverable under limited circumstances, and, according to the most recent pronouncements from the Fourth District, "contention discovery" is allowed. Therefore, the Defendant shall respond to the EFTA02769924