IN THE CIRCUIT COURT OF THE 111 thENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XMCCMBAG JEFFREY EPSTEIN, Plaintiff, Ack - 4..., . i c-) ▪ c r VS. SCOTT ROTHSTEIN individually, J. individually, and L.M., individually, At 2 .z. co — co c ._c_ •-_. rn Z k•a O M0 - n N.) ar ft -0 <CD Defendant, NJ :<14; - rt r- *CA; r " REQUEST FOR PRODUCTION TO COUNTER-DEFENDANT (PUNITIVE DAMAGES' J. by and through his undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, hereby requests Production from JEFFREY EPSTEIN of the documents and Things described below for the purpose of inspection, copying, photographing, testing or sampling and any other purposes permitted under the Florida Rules of Civil Procedure at the office of the undersigned within thirty (30) days of service of this request. DEFINITIONS AND INSTRUCTIONS: A. The tam "documents" as used in this Request is defined as including, but not limited to, the original and any non-identical copy (which is different from the original because of notations on such copy or otherwise) of all correspondence, telegrams, teletype messages, contacts (including drafts, proposals and any and all exhibits thereto), draft minutes and addenda, memoranda (including inter and infra office memoranda), memoranda for file, pencil jottings, diary entries, desk calendar entries, reported recollections and other written form of EFTA02771872