Filing # 62138114 E-Filed 09/28/2017 02:13:39 PM 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, J. , individually, and L.M., individually, Defendant, MEMORANDUM IN OPPOSITION TO JEFFREY EPSTEIN'S MOTION TO CO P L D COVERY RESPONSES FROM Counter-Plaintiff J. ), by and through his undersigned counsel and pursuant to Rule 1.380 of the Floridntules Of Civil Procedure, hereby moves this Court to enter an order Denying the Coun Discovery Responses, and in s ant Jeffrey Epstein's ("Epstein") Motion to Compel ereof states as follows: INTRODUCTION Counterto obfusca approac dant's recently filed motion represents nothing more than a delayed effort inent pending issues in this case in hopes of further delaying the rapidly al date. As noted in Counter-Defendant's motion, this Court entered Orders relevant to the underlying discovery more than five years ago - on April 10, 2012, May 7, 2012, and August 17, 2012. Conveniently excluded from Epstein's Motion is timely compliance with the direction of the Court. In fact, on August 3, 2012, this Court held a hearing regarding outstanding discovery. On August 7, 2012—after that hearing filed his FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 09/28/2017 02:13:39 PM EFTA02759952