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EFTA02763150

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Filing # 65223687 E-Filed 12/11/2017 02:24:37 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)OOO(MBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN individually, J. , individually, and L.M., individually, cos Defendant(s). SECOND SUPPLEMENT TO MO 01* IiV LIMINE ADDRESSING SCOPE OF ADMISSIBLE EVIDENCE Counter-Plaintiff, J. by and through undersigned counsel, hereby files this Second Supplement to his November 13, 2017 Motion in Limine to address the scope of admissible evidence in the trial of the pending malicious prosecution claim, and as grounds therefore states as follows: 1. On November 16, 2017, Counter-Defendant Jeffrey Epstein filed his Deposition Designations for use at trial. 2. Included in that submission were designations to testimony regarding misconduct that occurred within the Rothstein, Rosenfeldt & Adler law firm ("RRA") during the six (6) months in which Bradley was an employee of the firm.' Coupled with certain arguments that have been raised by Epstein's counsel in their papers and at recent pre-trial hearings, it appears that Epstein mistakenly believes that this evidence, which Epstein was unaware of at the time he had no involvement whatsoever in the improprieties being committed by Scott Rothstein and had absolutely no knowledge of any illicit activities until learning about them through media reporting after RRA'a implosion. FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 12/11/2017 02:24:37 PM EFTA02763150

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