IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and ■l., individually, Defendants. RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR COURT TO DECLARE RELEVANCE AND NON-PRIVILEGED NATURE OF DOCUMENTS AND REQUEST FOR ADDITIONAL LIMITED DISCOVERY, EVIDENTIARY HEARING, AND APPOINTMENT OF A SPECIAL MASTER Counter-Plaintiff Edwards, by and through undersigned counsel, hereby files this Response in Opposition to Epstein's Motion for Court to Declare Relevance and Non-Privileged Nature of Documents and Request for Additional Limited Discovery, Evidentiary Hearing, and Appointment of a Special Master', and in support states as follows: I. Edwards incorporates by reference the timeline and arguments contained in his Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log, filed on March 5, 2018. 2. In addition to those arguments, Edwards states as follows: I For brevity, Edwards shall refer to Epstein's motion as the "Motion for Court to Declare Relevance." EFTA00808645