Epstein Secrets

wsuits were transferred to a newly formed firm of Farmer, Jaffee, Weissing, Edwards, Fistos & Lehrman, LP

Defendant, Scott Rothstein Marc Nurik, Esq. G. NECESSITY FOR A PROTECTIVE ORDER TO FACILITATE DISCOVERY Unknown at this time. .1 EFTA00722379 Epstein v Rothstein, et al. I 4 Case No. 502009CA040800XXXXMBAG H. PROPOSAL FOR TILE FORMULATION AND SIMPLIFICATION OF ISSUES/ TIMING OF MOTIONS FOR SUMMARY JUDGMENT

wsuits were transferred to a newly formed firm of Farmer, Jaffee, Weissing, Edwards, Fistos & Lehrman, LP

(iii) To identify any non-parties: 30 days after the production of the records from RRA by the bankruptcy trustee/special master; EFTA00722474 Epstein v Rothstein, et al. I 4 Case No. 502009CA040800XXXXMBAG (iv) To disclose expert witnesses: 60 days before calendar call, deadline is November 29, 2010; F. N

ue copy of the foregoing was sent by fax and U.S. Mall to the following addressees on this 12th day of April , 2010: Gary M. Farmer, Jr., Esq. Farmer, Jaffe, Weissing, Edwards, Flstos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Attorneys for Defendant, LM. Jack Scaro

- 2 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER MOVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00606609 Epstein v Rothstein, Edwards CASE NO. 502009CA040800XXXXMBAG 9. Paragraph 18 seeks records similar to those described in Paragraphs 9 and 10. Defendant Edwards has n