IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, v. Case No. 50 2009CA040800XXXXMB AG SCOTT ROTIISTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually, Defendants. ANSWER TO COUNTERCLAIM Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this his answer to the Counterclaim and states: 1. Without knowledge and deny. 2. Admit. 3. Deny. 4. Epstein admits that he is a convicted felon having entered into a Plea Agreement with the State of Florida. As to the remaining allegations in paragraph 4, Epstein asserts his Fifth Amendment privilege against self-incrimination. See DeLisi v. Bankers Ins. Company 436 So.2d 1099 (Fla. 4th DCA 1983); Malloy v. Hogan 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth Amendment - "[i]t would be incongruous to have different standards determine the validity of a claim of privilege based on the same feared prosecution, depending on whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny — Privilege Against Self-Incrimination ("...court must treat the defendant's 1 - oP EFTA00597942