Filing # 64550595 E-Filed 11/22/2017 03:05:33 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO. 502009CA040800XXX.XMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, -vs- SCOTT ROTHSTEIN, individual) and J. individually, Defendants/Counter-Plaintiffs. 44\ RESPONSE TO PLAINTIFF'S MOTION TO AMEND ANSWER AND AFFIRMATIVE DEFENSES Defendant/Counter-PI • to the Motion to Am hereby files this Response Answer and Affirmative Defenses filed by Plaintiff/Counter- efetZillt Jeffrey Epstein. For the reasons stated below, the motion shoO 'ed. ears after this lawsuit was filed and just prior to a special set trial date, Epstein has filed a motion to amend to raise five new affirmative defenses. No explanation has been offered as to why Epstein waited eight years to raise these defenses. 1 FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/22/2017 03:05:33 PM EFTA02762429