Electronically Filed 09/12/2013 03:16:19 PM ET IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA C.) 8 CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), ti u x Lt) SCOTT ROTHSTEIN individually, J. individually, and L.M., Cos Defendant(s). BEOUEST TO PRODUCE J. by and through hi 1.350 of the Florida Rules of Civil Procedu to inspect and copy each of e 1. All documents* \ d counsel, requests, pursuant to Rule ey Epstein produce and permit J. lewing documents*: any and all communications between you or anyone acting on your behalf and any atisltlby consulted by you or on your behalf regarding the basis for and/or the viability *"Doc any at is by you against II include, but not be limited to all non-identical copies of writings, drawings, charts, photographs, phono-records, recordings, and/or any other data compilatio 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. "Documents" also include all electronic data as well as application metadata and system metadata. All inventories and rosters of your information technology (IT) systems—e.g., hardware, software and data, including but not limited to network drawings, lists of computing EFTA02772336