IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT ; IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800MXMB Judge David F. JEFFREY EPSTEIN, Plaintiff, -n v. SCOTT ROTHSTEIN individually and J. individually, Defendants. 9 PLAINTIFF JEFFREY EPSTEIN'S RE WED MOTION FOR _4 PROTECTIVE ORDER RELATING TO MS DEPOSITION Plaintiff Jeffrey Epstein moves Court for entry of a protective order, pursuant to Florida Rule of Civil Procedure 1.280, to vent the taking on November 14, 2011 of his further deposition which Defendant J. ("Mn) has noticed over the Plaintiff's objection. The grounds for this Motion are: 1. On or about October 27, 2011, counsel to noticed the video deposition of the Plaintiff for November 14, 2011 in West Palm Beach, Florida to retake the deposition of the Plaintiff. A copy of the Notice is attached as Exhibit A. 2. The Plaintiff seeks a protective order to prevent his further deposition at this time because (a) he has already been deposed at length; (b) no meaningful grounds have been alleged to justify the taking of a second deposition other than the unsubstantiated assertion that the Plaintiff has somehow waived his rights under the Fifth Amendment to the U.S. Constitution which he has not; (c) the timing is in conflict with the Court's recent order requiring the EFTA02770148