Stipulation Jury Instructions and Verdict Forms as those documents should focus on the issues that will be tried In addition the outcome of the pending Motions will likely lead to amendments of the parties respective Exhibit and Witness Lists and further discovery Plaintiff disagrees with Defendants statement that the Court rejected all grounds raised for the continuance and that the parties must adhere to the current pre-trial schedule based on the December trial date For instance if Defendant is allowed to conduct multiple mini trials of the victims cases then Plaintiff will need to conduct further discovery including taking or more depositions Furthermore Defendants recently disclosed expert report evidences that Defendant has changed his position regarding the relevance of printed or published media connecting Defendant to Plaintiff which requires further discovery and the hiring and disclosure of Plaintiffs own expert witness es In addition if Plaintiffs Supplemental Motion to Compel Discovery is granted that could lead to further discovery and disclosures Plaintiff recognizes that the Courts Order granting his Motion for Continuance does not specifically address his request to extend the pretrial deadlines and respectfully asks the Court to clarify its ruling and grant that request Plaintiff further suggests that the parties comply with the timeframes set forth in the Courts July Order Specially Setting Jury Trial Exhibit A which would provide for the following pre-trial schedule Due Date Days Provided by Deadline Trial Order days prior to trial DUE Trial Exhibit Lists Witness Lists Expert Witness Lists and Expert Disclosures and Reports days prior to trial DUE Rebuttal Witness Lists days prior to trial DEADLINE To confer to discuss settlement simplify the facts and issues prepare a Pretrial Stipulation list objections to exhibits etc days prior to trial DUE Pretrial Stipulation Jury Instructions Verdict Forms and Deposition Designations DEADLINE To have Daubert Motions heard days prior to trial DEADLINE To complete discovery DUE Counter Deposition Designations and Objections to Deposition Designations Plaintiff did not request the extension of the pre-trial deadlines as a means to delay this matter as Defendant infers in his Motion to Reconfirm Existing Pretrial Deadlines Rather because it is unclear what issues will be tried it is simply impossible to reasonably prepare for trial and adhere to the current pre-trial deadlines Defendant will not be prejudiced by the extension of the pre-trial deadlines Accordingly Plaintiff renews his request for an extension of the pre-trial deadlines as set forth herein and in his original Motion for Continuance of Trial and to Extend Pre-trial Deadlines and for the Court to deny Defendants Motion CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on November through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Angela linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Secondary Tanya linkrocklaw.com Secondary Eservice linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Burlington Rockenbach P.A Palm Beach Lakes Boulevard Courthouse Commons Suite West Palm Beach FL West Railroad A venue mep searcylaw.com West Palm Beach FL jsx searcylaw.com njs FLAppellateLaw.com scarolateam searcylaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews A venue Suite One Broward Boulevard Suite Fort Lauderdale FL Ft Lauderdale FL brad epllc.com marc nuriklaw.com staff.efile pathotojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Tonja Haddad Coleman Fred Haddad S.E Seventh Street Suite Haddad Navarro PLLC Ft Lauderdale FL Financial Plaza Suite tonja tonjahaddad.com Fort Lauderdale FL efiling tonjahaddad.com dee haddadandnavarrolaw.com Co-Counsel for Plaintiff/Counter-Defendant Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Jeffrey Epstein Jack A Goldberger Atterbury Goldberger Weiss P.A Australian Avenue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein EXHIBIT A IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CIRCUIT CIVIL DIVISION AG CASE NO JEFFREY EPSTEIN Plaintiff SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and individually Defendant I ORDER SPECIALLY Order Specially Setting Jury Trial Case No a copy of any written reports issued by the expert regarding this case and a copy of the experts curriculum vitae On the last business day no later than DAYS PRIOR TO TRIAL the parties shall confer and discuss settlement simplify the issues and stipulate in writing as to as many facts and issues as possible prepare a Pre-Trial Stipulation in accordance with paragraph and list all objections to trial exhibits Order Specially Setting Jury Trial Case No schedules attached to the Pre-Trial Stipulation prepared in accordance with paragraphs and absent agreement specifically stated in the Pre-Trial Stipulation or order of the Court upon good cause shown Failure to reserve objections constitutes a waiver A party desiring to use an exhibit or witness discovered after counsel have conferred pursuant to paragraph shall immediately furnish the Court and other counsel with a description of the exhibit or with the witness name and address and the expected subject matter of the witness testimony together with the reason for the late discovery of the exhibit or witness Use of the exhibit or witness may be allowed by the Court for good cause shown or to prevent manifest injustice DISCOVERY Unless permitted by court order all discovery must be completed no later than DAYS BEFORE THE DA TE Order Specially Setting Jury Trial Case No the depositions or portions thereof originally designated No later than trial each party shall serve his her or its objections to counter designations served by an opposing party I MEDIATION A All parties are required to participate in mediation The appearance of counsel who will try the case and representatives of each party with full authority to enter into a complete compromise and settlement is mandatory If insurance is involved an adjuster with authority up to the policy limits or the most recent demand whichever is lower shall attend At least ONE WEEK BEFORE THE CONFERENCE all parties shall file with the mediator a brief written summary of the case containing a list of issues as to each party If an attorney or party filing the summary wishes its content to remain confidential he/she must advise the mediator in writing when the report is filed All discussions representations and statements made at the mediation conference shall be privileged consistent with Florida Statutes sections and The mediator has no power to compel or enforce a settlement agreement If a settlement is reached it shall be the responsibility of the attorneys or parties to reduce the agreement to writing and to comply with Florida Rule of Civil Procedure unless waived The Plaintiffs attorney shall be responsible for scheduling mediation The parties should agree on a mediator If they are unable to agree any party may apply to the Court for appointment of a mediator in conformity with Rule Fla Civ The lead attorney or party shall file and serve on all parties and the mediator a Notice of Mediation giving the time place and date of the mediation and the mediators name The mediator shall be paid per hour unless otherwise agreed by the parties Completion of mediation prior to trial is a prerequisite to trial If mediation is not conducted or if a party fails to participate in mediation the case at the Courts discretion may be stricken from the trial calendar pleadings may be stricken and other sanctions may be imposed Any party opposing mediation may proceed under Florida Rule of Civil Procedure IV NONCOMPLIANCE NONCOMPLIANCE WITH ANY PORTION OF THIS ORDER MAY RESULT IN THE STRIKING OF THE CASE WITNESSES OR EXHIBITS OR IMPOSITION OF SUCH OTHER SANCTIONS AS ARE JUST Page of Order Specially Setting Jury Trial Case No DONE AND ORDERED in West Palm Beach Palm Beach County Florida this 20th day of July to Ct Elt CIRCUIT ald Hafele cv 267QJi Judie i An I Orr ti COURT JUDGE DONALD HAFELE Circuit Judge Copies furnished to Ola fowler-white.com Andrew A Harris aah flappellatelaw.com Bradley James Edwards brad pathtojustice.com Fred Haddad haddadfm aol.com John Scarola mep searcylaw.com JOSEPH ACKERMAN JR JACKERMAN FOWLER-WHITE.COM Maria Kelljchian maria pathtojustice.com Matthew Weissing matt pathtojustice.com PHILIP BURLINGTON PMB FLAPPELLATELAW.COM service jurytrial.co Russell Adler service jurytrial.com Tonja Haddad Coleman tonja tonjahaddad.com William Bennett King wbk searcylaw.com William Chester Brewer Jr wcblaw aol.com William King Lkingteam searcylaw.com John Scarola Lscarolateam searcylaw.com Rodney Romano alex matrixmediation.com John R.Beranek csullivan ausley.com Fred Haddad Dee fredhaddadlaw.com James Chaplin efile mediationfirminc.com Tonja Haddad Coleman efiling tonjahaddad.com Fred Haddad fredhaddad fredhaddadlaw.com Page of Order Specially Setting Jury Trial Case No Jayme Lynn Day Jayme tonjahaddad.com John Beranek Uberanek ausley.com Jack A Goldberger Ugoldberger agwpa.com Andrew A Harris Urh flappellatelaw.com Philip Burlington kbt flappellatelaw.com Marc 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