Filing # 64855972 E-Filed 12/01/2017 02:40:38 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, J. individually, and L.M., individually, Defendant, CO 'S' DEFENDANT/COUNTER-PLAINTIFF'S SECOND SUPPLEMENT TO PROPOSED JURY INSTRUCTIONS AND VERDICT ?ORM Defendant/Counter-Plaintiff. J. Edw hereby files his Second Supplement to Propose4 d through undersigned counsel, Instructions and Verdict Form, and as grounds therefor states as follows: 1. On November 9, 201 2. On November 14, 2017, s filed his Proposed Jury Instructions and Verdict Form. filed his Supplement to Proposed Jury Instructions and Verdict Rim, which added an additional proposed jury instruction based upon Federal Rule of Evidente 415 and Florida Statute Section 90.404. hereby adds the following additional proposed jury instruction, pursuant to Liabos v.liannan, 215 So. 2d 487, 489-90 (Fla. 2d DCA 1968) (copy attached): In order for probable cause to exist on the part of Jeffrey Epstein, the facts known to Jeffrey Epstein must be such that a prudent man would set in motion the filing of a civil lawsuit. Where, however, it would appear to a cautious man that further investigation is justified before filing a civil lawsuit, then the failure to perform that additional investigation may form the basis to conclude that such person lacked probable cause to file the civil lawsuit. FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 12/01/2017 02:40:38 PM EFTA02762643