EFTA00599654.pdf

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, BRADLEY J. EDWARDS, individually, and =ndividually, Defendant(s). MOTION FOR PROTECTIVE ORDER BRADLEY EDWARDS, by and through his undersigned attorneys, move this Honorable Court for the entry of an Order of Protection limiting the production required in response to the attached Amended Notice of Taking Deposition Duces Tecum on the grounds that production requested is overly broad, irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence, and is unnecessarily intrusive into the financial privacy of BRADLEY EDWARDS. I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this day of Jack Sczarola Florida Bar iimary E-mail: /Secondary E-mail(s): hipley, West Pal ach 'da 33409 Phone: Fax: Attorneys or L • Y J. EDWARDS EFTA00599654