IN THE CIRCUIT COURT OF THE

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 L.M., individually, Defendant(s). MOTION TO COMPEL DISCLOSURE REGARDING FEE CLAIM Bradley J. Edwards, by and through his undersigned, moves this Honorable Court to compel the disclosure of the amount and basis for the Counter-Defendant, Epstein's claim for fees and in support would show: 1. Epstein claims fees pursuant to the rejection by Edwards of Epstein's proposal for settlement and the subsequent entry of Summary Judgment in favor of Epstein. 2. The Court has ordered mediation in this matter to encompass all issues between the parties including Epstein's claim for fees which has been stated to exceed a million dollars. 3. Epstein has retained Attorney Jay White as his expert regarding fees, and has had months in which to prepare his case in support of his fee claim which until recently had been scheduled on the Court's current trial calendar. 4. Edwards has made repeated efforts over an extended period of time to obtain discovery regarding the fee claim including either a report from or deposition of Jay White, but EFTA01205212 Edwards adv. Epstein Case No.: 502005.CA040800XXXXMBAG Motion to Compel Disclosure Regarding Fee Claim Epstein has refused to provide this discovery. As a consequence, Edwards has no knowledge of the amount of the fee claim or the manner in which it is intended to be calculated. Wherefore, Edwards requests entry of an order requiring Epstein to either provide a detailed expert witness report from Jay White, to produce White for deposition, or to strike Epstein's claim for fees. 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 , 2015. ack Scarola Florida Bar No.: ISMS Attorne E-Mail s : and Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorneys or ra ey wards 2 EFTA01205213 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Motion to Compel Disclosure Regarding Fee Claim COUNSEL LIST William Chester Brewer. Es uire 250 S Australian Avenue, Suite 1400 West Palm Beach, FL 33401 Pho Fax: Attorneys ore yEpstein Jack A. Goldberger,Esguire Atterbury Goldberger & Weiss, M. 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Pho Fax: Attorneys for Jeffrey Epstein Farmer Jaffe Weissing Edwards Fistos & Lehrman, 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone... Fax: Fred Haddad, Esquire Fred Haddad, One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Pho Fax: Attorneys for Jeffrey Epstein Tonja Haddad Coleman, Esquire Tonja Haddad, . 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Ph Attorneys or Je y pstein Marc S. Es 'dr unk, e One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Attorneys for Scott Rothstein EFTA01205214