EFTA01081105.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation Fla.R.Civ.Pro. 1201- Civil — Div. Plaintiff, Case No. 502009CA040800XXXXMB v. Judge: AG — David Crow SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and.., individually, Defendants. PLAINTIFF, JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER RELATING TO DEPOSITION OF ROBERT CRITTON Plaintiff, Jeffrey Epstein ("Epstein"), by and through his undersigned representative and pursuant to the Florida Rules of Civil Procedure file this his Motion for Protective Order Relating to the Deposition of Robert Critton for the reasons set forth below: 1. The Plaintiff has presently scheduled the deposition of Robert Critton in this matter for January 10, 2011. 2. The undersigned counsel is unavailable that day due to specially set trials in the case of Penelope Lankheim v Florida Atlantic University, beginning January 10th through January 12th, 2011 before Judge Rosenberg and the case of Toll Bros., Inc. v. The Decorators Unlimited, Inc. and Nationwide Mutual Insurance Company, January 13th through January 18, 2011 before Judge Sasser. 3. The undersigned has requested counsel for the Defendant to reschedule the deposition but has not obtained or received a response. 4. The undersigned counsel certifies that this motion is made in good faith and not for the purpose of delay. 5. The undersigned counsel certifies that he has and will continue to make an effort to resolve this matter without the need of a hearing. EFTA01081105 Epstein v. Rothstein, et al. Case No. 502009CA040800MOCXMBAG Plaintiff's Motion for Protective Order re: Critton Depo WHEREFORE, Plaintiff, Jeffrey Epstein, respectfully requests that this court enter an order preventing the deposition of Robert Critton from occurring in this matter on January 10, 2011 and requiring it to be rescheduled at a time mutually convenient to the witness and counsel for all parties. CERTIFICATE OF SERVICE I HEREBY CERTIFy that a true asd-correct copy of the foregoing has been duly furnished via O Email, 2' Facsimile, E U.S. Mail, O Hand Delivery, O Federal Express this ZVThay of December, 2010 to: Jack Scarola, Esq. Sears Denne Scarola Barnhart & Shipley, Marc S. Nurik, Esq. Law Offices of Marc S. Nurik Jo ph L. Ackerman, Jr. Fla. Bar No. 235954 FOWLER WHITE BURNETT.. mr Attorneys for Jeffrey Epstein, Plaintiff (not] WA$0743lMotioo foe Protective Order re Robert Critter' Depo JLA{12/29/10-14:32) 2 EFTA01081106