IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)OOOCMBAG JEFFREY EPSTEIN, Plaintiff(s), VS. ro SCOTT ROTHSTEIN individually, J. , individually, and L.M., individually, rn Av Cr' Defendant(s). =kr nns al . • Sa tos Aria :<rn -n r-= REQUEST TO PRQDjece. Counter-plaintiff, J. a, by pursuant to Rule 1.350 of the Florida Rul produce and permit J. o eiNi tpcliL pect s is undersigned counsel, requests, Procedure, that JEFFREY EPSTEIN d copy each of the following documents*: 1. All invoices, commC ica ions, reports, summaries, and other documents of any description constituting, re any effort to subjeciccadley activities of ' , or relating directly or indirectly to any effort or the results of to surveillance or to otherwise monitor the movements or wards. *"Documents" shall include, but not be limited to all non-identical copies of writings, drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data compilations from which information can be obtained, translated, if necessary, by the party to whom the request is directed through detection devices into reasonably usable form. EFTA02771363