IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F, Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants, / PLAINTIFF'S MOTION FOR PROTECTIVE ORDER TO PREVENT VIDEO DEPOSITION Plaintiff Jeffrey Epstein moves the Court for entry of a protective order, pursuant to Florida Rule of Civil Procedure 1.280, to prevent the taking on April 13, 2011 of Mr. Epstein's further deposition which Defendant Bradley J. Edwards ("Edwards") has noticed over the Plaintiff's objection. The grounds for this Motion are: 1. On or about March 30, 2011, counsel to Edwards noticed the video deposition of the Plaintiff for April 13, 2011 in West Palm Beach, Florida to retake the deposition of the Plaintiff, despite the fact that he was advised by Plaintiff's counsel that the Plaintiff was unavailable during this time and that there was no basis for the taking of a second deposition when the Plaintiff had already been deposed in 2010. A copy of the Notice is attached as Exhibit A. 2. The Plaintiff seeks a protective order to prevent his further deposition at this time because (a) he has already been deposed at length; (b) no meaningful grounds have been alleged to justify the taking of a second deposition other than the unsubstantiated assertion that the FowLer Waire BurNetr I 901 PiiLtips Point West, 777 SOUTH FLAGLER Drive, WEST PALM BEACH, FLORIDA 33401 + (561) 802-9044 EFTA00621428

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CASE NO, 502009CA040800XXXXMBAG Plaintiff has somehow waived his rights under the Fifth Amendment to the U.S. Constitution which he has not; and (c) the timing is in conflict with the Court's recent order requiring the filing of new pleadings by all parties which may determine the scope of inquiry. Moreover, the taking of a video deposition in light of the publicity surrounding these parties would be particularly prejudicial to the Plaintiff who is also seeking in a separate motion an order preventing Edwards's counsel from discussing this case with the media. A video deposition is truly fodder for internet gossip machines and can be of no benefit to any party. 3. Rule 1.280(c) affords the Court discretion to grant protective orders for good cause shown and to protect a party from annoyance, embarrassment, oppression, or undue burden or expense. See also Logitech Cargo v. JW Perry, 817 So. 2d 1033 (Fla. 3d DCA 2002). Moreover, the Court may determine the time and place of a deposition. Fla. R. Civ. P. 1.280(c)(2). In this case, the Court should determine whether a further deposition of the Plaintiff is justified or necessary and whether video is a proper medium. WHEREFORE, for the above stated reasons, Plaintiff Jeffrey Epstein moves for entry of a protective order to preventing the taking of his deposition again as noticed by Plaintiff on April 13, 2011 and for such other relief as the Court deems proper in the circumstances. CERTI TE OF VI I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this 8th day of April, 2011 to Gary M. Farmer, Jr., Esq., Farmer, Jaffee, Weissing, Edwards, Fistos, et al, 425 N. Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, i. 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012; Mare S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301; and Jack Scarola, Esquire, Searcy Denney -2- FowLer Warts Burnett fi + 901 Priurps Porst West, 777 SOUTH FLAGLER Drive, WEST PALM BEACH, FLORIDA 33401 + (561) 802-9044 EFTA00621429

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CASE NO. 502009CA040800XXXXMBAG Scarola et al., 2139 Palm Beach Lakes Boulevard, [J- Drawer 3626, West Palm Beach, FL 33409, / Joseph L. Acke: Fla, Bar No. 235954 FOWLER WHITE BURNETT, [i 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 W:\80743\MTNPRO93-to prevent deposition of Plaintiff in April JLA.docx “3e FOWLER WHITE BURNETT [i * 90] PHILLIPS Pov West, 777 SOUTH FLAGLER Drive, WEST PALM BEACH, FLORIDA 33401 + (561) 802-9044 EFTA00621430

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ig 78g SOLE LOTBL FAL BOLOURELE Pe a eT) °, TY #291874/mep IN THE CIRCUIT COURT OF THE FIFTRENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEHFREY EPSTEIN, Plaintif{(s), vs. SCOTT ROTHSTEN, individually, BRIADLEY J. EDWARDS, individually, and L.M., individually, ; Defendant(s). | / NOTICE OF TAKING VIDEO DEPOSITION All counsel on the attached Counsel List PLEASE TAKE NOTICE that the undersigned attorneys will take deposition(s) of: _- DATE AND TIME LOCATION Jeffrey Epstein April 13, 2011 Searcy Denney, et al : 9:30 2139 Palm Boach Lakes Boulevard, WPB VIPBOGRAPHER: To be arranged by Phipps Reporting upda oral examination before Phipps Reporting, a Notary Public; or any other officer authorized by haw to take depositions in the State of Florida, The oral examination is being taken for the ! Pp ¢ of discovery, for use at trial, or for such other purposes as are permitted uncler the icable Statutes or Rules. i EXA( bik A EFTA00621431

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Edwards adv. Epstein No, $02009CA040800XXXXMBAG Notice of Taking Video Deposition Page 2 1 HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by ' . \ ood Fax and U.S. Mail to all Counsel on the attached list, this 20 day of March, 2011. Denncy Scarola Barnhart & Shipley 39 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorney for Bradley J. Edwards | ce: Phipps Reporting | [ s ASCI ‘OR DVD REQUESTED ' t i AMERICANS WITH DISABILITIES ACT In jaccordance with the Americans With Disabilities Act, persons in need of a special mmodation to participate in this proceeding should contact the Human Resources Manager, Ss Denney Scarola Barnbart & Shipley, . no later than seven days prior to the ding. Please telephone (561) 686-6300. EFTA00621432

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BS SOP BULL LEECH FAX COLERAINE BRARCY BBNNEY OTe reer weos7e0s Edwards adv. Epstein No. 502009CA040800XXXXMBAG Notice of Taking Video Deposition 3 SEL LIST A. Goldberger, Esquire Atterbury, Goldberger & Weiss, 250 Australian Averiue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fan: (561)-835-8691 F , Jaffe, Weissing, Edwards, Fistos & Le PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 Josbph L, Ackerman, Jr, Esquire Fowler White Burnett, 901 Phillips Point West 777 S Flagler Drive Wa Palm Beach, FL 33401-6170 Phone: (561)-802-9044 Fay: (561)-802-9976 EFTA00621433