IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA S CASE NO: Plaintiff, 50200SCA037319XXXXMB AB vs. JEFFREY EPSTEIN, Defendant. I PLAINTIFF'S RESPONSE TO EPSTEIN'S MOTION FOR SANCTIONS AND TO IDENTIFY Plaintiff, M. files this Response to Epstein's Motion for Sanctions and to Identify. introduction Apparently Epstein and his counsel do not have a problem with press, they just have a problem with bad press. To put the quotes cited by defense in their motion in context, the court must also see some of the numerous quotes given by Epstein's defense team. "These women are liars. We've established that " "It was just a childish performance by the Palm Beach Police Department " - Any. Jack Goldberger, August 8, 2006, Palm Beach Post. (Ex. I). "There was never any victims." (sic) - Any. Jack Goldberger, July 23, 2009, Palm Beach Post. (Ex. 2). EFTA00723522