IN THE CIRCUIT COURT OF THE 15Th JUDICIAL CIRCUIT 'WAND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, CASE NO. 502009CA040800)OOO(MBAG Plaintiff, vs. SCOTT ROTHSTEIN, individually, , individually and J. L.M., individually, 'V Li) Xwr7.W • A;2m co o rnz >23 "c c 222 Defendant(s). r- 71 NOTICE OF DOCUMENT REGARDING WORK PRODUCTWiLM c- ) COMES NOW Jeffrey Epstein, through the undersigned counsel, and fiRF,n-the;sttac and rhirs;counsel and document, that is the Statement of Undisputed Facts submitted by would suggest it weighs upon any "work product" argument, as such is be made vis a vis the Motion to Disqualify the undersigned, and the undersigned 1. M, state as follows: in support of, apparently, his Motion for Summary Judgment and to "facilitate Epstein's required compliance with FIa.R.Cr.P. 1.150(c)" [see page 1 of the attached document], filed a forty two (42) page document that details and, ipso facto, his firm's involvement in the cages which were civilly prosecuted against Epstein that are the basis of the current litigation. 3. That document details each claim that Epstein made against and details that which Edwards asserts is his good faith basis for each action taken in the prosecution of his clients claims against Esptein in the underlying litigation. These assertions clearly set forth [and his firm's] thought process, and reasons for each action. What is set forth in the "Statement" is in fact what he now asserts is his work product. 4. There is, in fact, no work product; presented everything but the proverbial kitchen sink in this pleading, and in fact provides more in discovery in this document than could any deposition [compare paragraphs 52-59, and then 62 et seq.]. Page 1 of 3 CLERKS OFFICE EFTA02771734