Filing # 62481523 E-Filed 10/05/2017 08:50:35 PM JEFFREY EPSTEIN, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Plaintiff, v. SCOTT ROTHSTEIN, individually, J, Individually, and L.M., individually. CASE NO.502009CA040800XXXXMBAG JUDGE: HAFELE Defendants. DEFENDANT/COUNTER-PLAINTIFF JEFFREY EPSTEIN' SANCTIONS PURSUANT TO VIOLATION OF CONFIDE A t AGREEMENT AGAINST PLAINTIFF/COUNTER-DEFE A AND HIS COUNS] Plaintiff/Counter-Defendant Jeffrey Epstein ("Ep counsel, hereby files this Motion requesting that th J. and his co- ('it') and through his undersigned o l ON FOR EMENT ction Defendant/Counter-Plaintiff this case, Jack Scarola ("Scarola"), for their flagrant violation of the confidenti • a L.M., E.W., and Jane Doe, as well Order of entitlement to costs and attorneys' fees in e e ents between Epstein and clients favor of Epstein and against Ed{yardsl d Scarola. In support thereof, Epstein states: tali.' As this C is a , INTRODUCTION represented three clients in civil suits against Epstein; E.W., L.M., d e Doe. Each of these parties entered into a Settlement Agreement and Gener ("Agreement") in July 2010. As an express term and condition thereof, each Party agreed to confidentiality provisions, to which each party and his or her attorneys were bound. The germane portions of each of the Agreements provides as follows: 4. Reciprocal Confidentiality. The Parties agree that the amount of this settlement shall be kept strictly confidential and shall not be disclosed at any Tonja Haddad, P.A. • 315 SE 71° Street, Fort Lauderdale, FL 33301* 954.447.1223 FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 10/05/2017 08:50:35 PM EFTA02760007