UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION www.flsb.uscourts.gov IN RE: ROTHSTEIN ROSENFELDT ADLER, M., Debtor. CASE NO. 09-34791-RBR CHAPTER 11 JEFFREY EPSTEIN'S REPLY TO THE INTERVENORS' RESPONSE TO EPSTEIN'S MOTION TO TAKE THE INTERVENORS' DEPOSITIONS AND TO COMPEL THEIR MENTAL EXAMINATIONS Jeffrey Epstein ("Epstein") replies to the Intervenors, IM and Jane Doe's Response (D.E. 6446) to Epstein's Motion to Take the Intervenors' Depositions and to Compel their Mental Examinations (Epstein's "Motion") (D.E. 6440), and states: INTRODUCTION Inexplicably, the Intervenors' counsel insists on making the Intervenors relive (and attempt to re-litigate) their settled sexual abuse claims against Jeffrey Epstein. Although the Intervenors' counsel vitriolically claims that Epstein is traumatizing the Intervenors by seeking reasonable discovery in defense of their "significant emotional distress" claim, the reality is that the Intervenors' counsel is inventing their "significant emotional distress" claim and perpetuating the "victims" label and "sexual abuse" mantra.' To be clear, these proceedings are not about the alleged sexual abuse claims settled in 2010 — eight years ago. Indeed, each of the Intervenors' claims for damages arising out of alleged sexual abuse were resolved in July 2010, and each of the Intervenors executed a full release in favor of Epstein. Any attempt to relitigate the settled 'In the Response, the Intervenors' counsel uses the improper label "victims" 51 times to describe the Intervenors and "sexual abuse" or "sexual assault" 10 times. EFTA00808426