IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502009CA040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
EL, individually,
Defendant.
MEMORANDUM IN SUPPORT OF BRADLEY J. EDWARDS'
MOTION FOR PROTECTIVE ORDER
Bradley Edwards has moved for protection against the discovery of personal financial
information sought by Jeffrey Epstein in discovery. Epstein supports his broad ranging requests
on the grounds that the information sought is reasonably calculated to lead to admissible
evidence regarding the economic loss Mr. Edwards claims to have suffered as a consequence of
the tortious conduct to which Epstein subjected him. To justify his attempted broad intrusion into
Mr. Edwards' economic privacy, the economic privacy of Mr. Edwards' law firm, and the
economic privacy of Mr. Edwards' clients, Epstein misrepresents, mischaracterizes, or simply
fails to understand the nature of the losses Mr. Edwards is claiming.
EFTA00592506