• 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 individually, J. and L.M., individually, r CO -0 Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFF DEFENDANT/COUNTER-PLAINTIFF PRODUCTION SER Plaintiff/Counter-Defendant, Jeffrey j stei EIN'S RESPONSE Ti REQUEST FOR pstein"), by and through his undersigned counsel and pursuant to Rule 1.350, e Response to the Request for from the Defendant/Counter-Plaintiff, (e), I. Reques Since Epst obtain all relev orida Rules of Civil Procedure, files this his J. uction Served June 9, 2011, and would state as follows: s not be able, due in large part to the objections of uments that would reflect, suggest. or relate to i to knowledge of , it is not possible to to produce all documents responsive to this request. Rothstein' its to the deposition of A.J. Discala, Howeve Kretschmar, and Michael Legamaro due fit and are responsive to this request. In addition, the documents that are exhibits to Epstein's Motion to Use Confidential Documents are also responsive. 2. See Response to Number 1 above. 3. Undetermined at this time. -Sumer( P.A. • 901 POINT WEST. 777 SOUTH PLAGUE DRIVE. WEST PALM BEACH. FLORIDA 33401 • (561)802.9044 EFTA02769926