IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, LEY J. EDWARDS, individually, and individually, Defendant(s). MOTION TO COMPEL DISCLOSURE REGARDING FEE CLAIM Bradley J. Edwards, by and through his undersigned, moves this Honorable Court to compel the disclosure of the amount and basis for the Counter-Defendant, Epstein's claim for fees and in support would show: 1. Epstein claims fees pursuant to the rejection by Edwards of Epstein's proposal for settlement and the subsequent entry of Summary Judgment in favor of Epstein. 2. The Court has ordered mediation in this matter to encompass all issues between the parties including Epstein's claim for fees which has been stated to exceed a million dollars. 3. Epstein has retained Attorney Jay White as his expert regarding fees, and has had months in which to prepare his case in support of his fee claim which until recently had been scheduled on the Court's current trial calendar. 4. Edwards has made repeated efforts over an extended period of time to obtain discovery regarding the fee claim including either a report from or deposition of Jay White, but EFTA00595677