Filing # 64593714 E-Filed 11/27/2017 12:37:02 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. Cos SCOTT ROTHSTEIN, individually, and J. ,individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY IN OPPOSITION TO DEFENDANT/CO FOUR MO c( Plaintiff/Counter-Defendant Jeffrey Defendant/Counter-Plaintiff S OMNIBUS RESPONSE AINTIFF COMPEL "Epstein") responds in opposition to wards") four Motions to Compel served on September 21, 2017, relating to s' 2 1 , 2012 Interrogatories (Net (3) December 21, 2012 Request for Production (Punitive Damages), and (4) Feb April 15, 2011 Requests to Produce, (2) December 013 Requests for Admissions (Net Worth), and states: INTRODUCTION ur generic motions must be denied because they are moot and contain only one um ence stating that he "moves for an Order compelling Jeffrey Epstein to provide a substantive response to [the discovery request]." The discovery requests and responses were served over four to six years ago. Epstein stipulated that his present net worth is more than $100 million. Most importantly, Epstein invoked his Fifth Amendment privilege, which was accepted by trial counsel and recognized by the predecessor trial judge at the hearing on FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/27/2017 12:37:02 PM EFTA02762450