Filing # 64542656 E-Filed 11/22/2017 01:45:16 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, individually, and J. L.M., individually, Defendant, RESPONSE IN OPPOSITION TO EPSTc MOTION IN LI J. Counter-Plaintiff, grounds therefor states as follows:,S through undersigned counsel, hereby files . by a this Response in Oppositions to Jeffrey Est ISED OMNIBUS s Revvised Omnibus Motion in Limine, and as ) Summary Jeffrey Epstein's `Epstein Revised Omnibus Motion in Limine makes a desperate, 32ea) burden page attempt to ch e the cts of this case in order to alter of proof. Ep cl r purpose is to avoid the admission of evidence that he lacked probable cause t tl motion in HL Underlying claims against tail, it is important that . Prior to addressing and refuting Epstein's burden in proving his malicious prosecution claim is accurately defined. has the burden to prove that there was no reasonable basis for Epstein to believe that manufactured and fabricated the claims was pursuing on behalf of FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/22/2017 01:45:16 PM EFTA02762364