IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, J. ,individually, and L.M., individually, Defendants. NOTICE OF TAKING DEPOSTtIO *Duces Tecumv ) TO: All counsel on the attached Counsel List SY S, S PLEASE TAKE NOTICE that the undersigneciaSte A NAME AND ADDRESS Representative(s) of The Wackenhut Corporation with the most knowledge of the matters set forth below pursuant to Fla. R. Civ. 1.310(b)(6) DA s will take deposition(s) of: N'\ AND TIME ember 6, 2011 AM. LOCATION Searcy Denney Scarola Barnhart & Shipley, PA 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 *DUCES TECUM: TO HAVE AND BRING WITH YOU AT THE TIME OF THE DEPOSITION THE FOLLOWING: Any and all documents** reflecting or relating to services rendered: 1. at or in the general vicinity of 358 El Brillo Way, Palm Beach, FL 33480-4730; and 2. for the benefit of or at the direction of Jeffrey Epstein and/or Jack Goldberger including but not limited to documents reflecting when the services were performed, how long they were performed, the nature of the services, and by whom they were performed. EFTA02769990