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EFTA01206766

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JEFFREY EPSTEIN, Plaintiff, vs. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CIRCUIT CIVIL DIVISION AO CASE NO. 502009CA040800/OOOMB SCOTT ROTHSTEIN, individually; SE DLEY J. EDWARDS, individually, and , individually, Defendants. / JOINT DISCOVERY SCHEDULE Pursuant to this Court's Order, dated April 22, 2015, counsel for Plainti&Counter￾Defendant, JEFFREY EPSTEIN ("EPSTEIN"), and counsel for Defendant/Counter-Plaintiff, BRADLEY J. EDWARDS ("EDWARDS"), hereby agree to the following Joint Discovery Schedule: 1. DISCLOSURES EPSTEINthall disclose to EDWARDS by FRIDAY - JUNE 5, 20151- all attorney time recorcts7oriteMertntees rendered in connection with this matter fesembleirESPST-RaSeiaints ,entidetnes. These records may be redacted to properly protect any attorney/client and/or work product information. EPSTEIN shall discloje all taxable costs claimed by him, as well as all agreements/ invoices pursuant to which tlierticitsamWtro incurred, as well as any and all documents reflecting payment of same by WEDNESDAY - JULY 15, 2015. 2. EXHIBITS The parties shall =haw lists of all hearing exhibits no later than MONDAY - JULY 20, 2015. I Because Appellate Fees have yet to be addressed by the Court, tWs Discovery Order is inapplicable to those costs and fees and may be amendedhnodified upon the Court's ruling on same. EFTA01206766 Jeffrey Epstein vs. Scott Rothstein, et al 15th Judicial Circuit Casa No 502009CA040800)OOaMB Joint Discovery Schedule Page 2, 3. WITNESSES The parties shall exchange Lists of names and addresses of all Witnesses and Expert Witnesses - no later than FRIDAY, JUNE 19, 2015. Rebuttal witnesses shall be disclosed no later than FRIDAY, JULY 10, 2015. For all Expert Witnesses, the parties shall provide: a. the subject matter about which the Expert is expected to testify; b. the substance of the facts and opinions to which the Expert is expected to testify; o. a copy of any written reports issued by the Expert regarding this case; and d. a copy of the Expert's curriculum vitae 4. DISCOVERY All discovery must be completed no later than FRIDAY, JULY 31, 2015. -5. MEDIA-new Tµe `PARTIES ARC lid THAT TWERE IS acio s.surrez day of 2015. No cuts Poe CEA sescces-s rut. DATED ktermericas Riga Reseuittea this W. CHESTER BREWER, IRS. Attorneys for Jeffrey Epstein OF PENOlek; APPEZ4Ater ente.s. SEARCY, DENNEY, SCAROLA BARNHART & SHIPLEY, P.A. Attorneys for Bradley J. Edwards By: By: W. CHESTER BREWER, JR. JACK SCAROLA Florida Bar No, 261858 Florida Bar No. 169440 EFTA01206767