*** FILED: PALM BEACH COUNTY. FL SHARON R BOCK. Electronically Filed 09/20/2013 12:20:15 PM ET IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), VS. SCOTT ROTH STEIN, individually, J. individually, and L.M., individually, Defendant(s). REOUESVFO PRODUCE Defendant, J. by and through the undersigned counsel, request, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that Plaintiff, Jeffrey Epstein, produce and permit J. to inspect and copy each of the following document?: 1. Please provide copies of tdhinEiterials reasonably expected or intended to be used at trial for witness impeachment iricludirtg/depositions, medical literature and any and all other impeachment materials of any t e, kyrd or variety. See Northup v. AcR *"Docum drawings, compil iS So.2d 1267 (Fla. 2004). shall include, but not be limited to all non-identical copies of writings, harts, photographs, phono-records, recordings, and/or any other data m 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 EFTA02772376