Filing # 62456833 E-Filed 10/05/2017 02:26:33 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCO"FI RorilSTEIN individually, J. L.M., individually, , individually, and Defendant(s). RESPONSE TO PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S REQUEST FOR P ODUCTION TO DEFENDANT/COUNTER-PLAINTIFF J. by and through hisndersigned attorneys and pursuant to Rule 1.350, Florida Rules of Civil Procedure, here nds to Jeffrey Epstein's, Request for Production dated September 5, 2017 as folio 1. Objection. Attorne 2. Objection. ambigt or product. erence to "the period in question" is undefined, vague and the request is overly broad and seeks information that is irrelevant, al, and not reasonably calculated to lead to the discovery of admissible evi ence; information requested includes attorney work product; attorney-client privileged information, and information protected by rights to financial privacy. 3. Objection. The request is overly broad and seeks information that is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence; information requested includes attorney work product; attorney-client privileged information, and information protected by rights to financial privacy. FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 10/05/2017 02:26:33 PM EFTA02760003