IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXX'MBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN individually, J. , individually, and L.M., individually, Defendant(s). MOTION FOR PROTECTIVEtIQ J. through counsel, moves this Honorable Court for the entry of a protective order precluding or limiting the taking of a second deposition of and would show in support that Mr. has been previously deposed in this matter and any further deposition would serve no legitimate purpose except to annoy, harass, and embarrass the deponent. I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this 2 S k- day of 0 1-1- • 2012. Jack Scarola Florida Bar No.: 169440 Primary E-mail: [email protected] Secondary E-mail(s): mep®searcylaw.com Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for J. EFTA02771681