Y EPSTEIN'S MOTION FOR A PROTECTIVE ORDER RBLATING TO HIS DEPOSITION AND IN SUPPORT OF EDWARDS' MOTINO TO COMPEL AND IMPOSE SANCTIONS j Defendant/Counterplaintiff, Bradley J. Edwards (hereinafter EDWARDS), by and throligh his undersigned attomeys, respectfully responds in opposition to Plan tiff/Count

COTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, REPLY TO AFFIRMATIVE DEFENSES TO COUNTERCLAIM Counterplaintiff, BRADLEY J. EDWARDS, replies to the Affirniative Defenses asserted by JEFFREY EPSTEIN by stating that such defenses do not constitute legally cogniz

ories 4. The use of written interrogatories is the least burdensome, least expensive and ml expeditious discovery means available to the Defendant/Counterplaintiff by which to obtain nejessary information and narrow trial issues. 5. The Plaintiff/Counterdefendant will not be prejudiced through the granting of

EPSTEIN IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG Defendant/Counterplaintiff, Bradley J. Edwards, hereby gives notice that pursuant to Rule 1.340(e), Florida Rules of Civil Procedure, Expert Interrogatories numbered 1 through

ICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003OOaMBAG EDWARDS' RESPONSE TO FIRST REQUEST FOR ADMISSIONS Defendant/Counterplaintiff, BRADLEY J. EDWARDS, hereby files his Response to Plaintiff, JEFFREY EPSTEIN'S First Request for Admissions to Edwards dated June 18, 2010 as hollo

800XXXXIvD3AG Plaintiff/Counterdefendant, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually Defendant/Counterplaintiff. NOTICE OF VOLUNTARY DISMISSAL OF COUNTERCLAIM WITH PREJUDICE Bradley J. Edwards, by and through his undersigned attorneys, hereby files this Noti

8/007 4. The use of written interrogatories is the least burdensome, least expensive and ml expeditious discovery means available to the Defendant/Counterplaintiff by which to obtain nejessary information and narrow trial issues. 5. The Plaintiff/Counterdefendant will not be prejudiced through the granting of

, FLORIDA CASE NO.: 502009CA040800XXXXMBAG NOTICE OF PROPOUNDING EXPERT INTERROGATORIES TO PLAINTIFF/COUNTERDEFEN'DANT, JEFFREY EPSTEIN Defendant/Counterplaintiff, Bradley J. Edwards, hereby gives notice that pursuant to Rule 1.340(e), Florida Rules of Civil Procedure, Expert Interrogatories numbered 1 through

H JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLOM] )A CASE NO.: 502009CA040800XXXXMBAO NOTICE OF FILING PAGE AND LINE DESIGNATIONS Defendant/Counterplaintiff, BRADLEY J. EDWARDS, by and through his undersigned attoirneys, submits the designation of the entire deposition of PlaintifECormterclefendant, JE

COTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, REPLY TO AFFIRMATIVE DEFENSES TO COUNTERCLAIM Counterplaintiff, BRADLEY J. EDWARDS, replies to the Affirniative Defenses asserted by JEFFREY EPSTEIN by stating that such defenses do not constitute legally cogniz

IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XX3CXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS COMES NOW the Counterplaintiff, BRADLEY J. EDWARDS, by and through his undersigned attorneys and hereby lists his exhibits for trial as follows: DEF. NO. PLF. NO. DATE OFFER

T, DI AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAO AMENDED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS COMES NOW the Counterplaintiff, BRADLEY J. EDWARDS, by and through his undersigned attorneys and hereby lists his exhibits for trial as follows: DEF. NO. PLF. NO. DATE OFFER