PALM BEACH COUNTY. FL SHARON R BOCK. CLERK.•" Electronically Filed 09/21/2013 05:46:52 PM ET IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Case No. 50 2009 CA 040800)OOaMBAG Plaintiff/Counter-Defendant, vs. SCOTT ROTHSTEIN individually, J. , individually, Defendant/Counter-Plaintiff. -a PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO QUASH SUBPOENAS DUCES TECUM AND FOR SANCTIONS Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned • • counsel and pursuant to Rules 1.351 and Rule 1.401 of the Florida Rules of Civil Procedure, 121 U- hereby files this Motion to Quash Defendant/Counter-Plaintiff improperly and impermissibly served Subpoenas Duces Tecum and for sanctions, and states: RODUCTION On September 11, 20Crallwards served upon Epstein "Subpoenas Duces Tecum Without Deposition" for following non-party individuals; all of whom are Epstein's former counsels: Darren Indyke, Esq., Roy Black, Esq., Knight, Esq., Robert Critton, Esq., L. Ackerman, Jr., Esq., Alan Dershowitz, Esq., and Jack Goldberger, Esq. True and correct copies of these subpoenas are attached hereto as composite "Exhibit A." While there was not a proper Notice of Production from Non-Party as required by Rule 1.351(b) of the Florida Rules of Civil Procedure, Epstein acted in accordance with Rule 1.351 and timely filed a Notice of Objection to the Subpoenas on September 19, 2013. A true and correct copy of same is attached hereto as "Exhibit B." On September 20, 2013, Epstein became aware that EFTA02772386