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