Filing # 64924801 E-Filed 12/04/2017 03:23:30 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. o G SCOTT ROTHSTEIN individually, J. individually, and L.M., individually, Defendants. NOTICE OF FILING DEPOSITION TRANSCRI RESPONSES BY JEFFREY EPSTEIN IMPLI PRIVIL Counter-Plaintiff, J. y AND DISCOVERY HE ATTORNEY-CLIENT rough undersigned counsel, hereby files this Notice of Filing Deposition Transc • xce ts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client P d as grounds therefor states as follows: s5t At the November J. Edw implicatin t answers , na 17 pre-trial hearing, the Court requested that Counter-Plaintiff ifically identify the discovery responses provided by Jeffrey Epstein mey-Client privilege. This Notice of Filing outlines the specific questions and p n's March 17, 2010 deposition testimony in which Epstein raised the privilege, as well as citations to Epstein's Answers to Interrogatories dated September 16, 2010 and Amended Answers to Interrogatories dated August 20, 2013, which proffers for introduction at trial and relies upon to preclude Epstein from offering testimony concerning matters as to which discovery was precluded through privilege assertions. FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 12/04/2017 03:23:30 PM EFTA02762781