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, PlaintifKounter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants/Counter-Plaintiffs. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY J. EDWARDS' REQUEST FOR PRODUCTION SERVED JUNE 9.2011 Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350, of the Florida Rules of Civil Procedure, files this his Response to the Request for Production from the Defendant/Counter-Plaintiff, Bradley J. Edwards' ("Edwards"), Request for Production Served June 9, 2011, and would state as follows: 1. Since Epstein has not be able, due in large part to the objections of Edwards to obtain all relevant documents that would reflect, suggest, or relate to Edwards' knowledge of Rothstein's conduct, it is not possible to to produce all documents responsive to this request. However, exhibits to the deposition of A.J. Discala, Dean Kretschmar, and Michael Legamaro due fit and are responsive to this request. In addition, the documents that are exhibits to Epstein's Motion to Use Confidential Documents are also responsive. 2. See Response to Number 1 above. 3. Undetermined at this time. FOWLER WHITE BURNER P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DR/VE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA01082058 Epstein v Rothstein, et al. CASE NO. 502009CA040800XXXXMBAG Epstein's Response to Edwards' RFP Served June 9, 2011 4. Objection. Work product. See Grinnel Corp. v. Palms 2100 Ocean Boulevard Limited, 924 So 2d 887 (Fla. 4th DCA 2006). 5. Objection. Work product. See Grinnel Corp. v. Palms 2100 Ocean Boulevard Limited, 924 So 2d 887 (Fla. 4th DCA 2006). ,THEREBY I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this of July, 2011 to: Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, Jack Scarola, Esq., Searcy Denney Scarola et al., and Martin G. Weinberg, Esq., Respectfully submitted, 2se:h L Ackerman, Jr. Fla. Bar No. FOWLER WHITE BURNETT P.A. WASOMARESPON3T-Epstein's Response to Edwasclt RFP 6.9•114LA.docx - 2 FOWLER WHITE BURNETT P.A. • 901 PHILUPS POINT WEST, 777 SOUTH FLAOLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802.9044 EFTA01082059