Filing # 65751262 E-Filed 12/22/2017 11:49:24 AM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)OCOCMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN individually, J. individually, and L.M., Defendant, C P I% DEFENDANT/COUNTER-PLAINTIFF'S SUPPLEMENT TO PROPOSED JURY INSTRUCTIONS AND VERDICT FORM Defendant/Counter-Plaintiff, J. Edwards, by and through undersigned counsel, hereby files his Supplement to Proposed Jury Invoftions and Verdict Form, and as grounds therefor states as follows: 1. On November 9, 2QJ7Ed ids filed his Proposed Jury Instructions and Verdict Form. 2. e,poir reby aids the following additional proposed jury instruction to that likc pleading: Federal Rule of Evidence 415 and Florida Statute 90.404 provide that in a civil case involving a claim for relief based on a party's alleged sexual assault or child molestation, the Court may admit evidence that the party committed any other sexual assault or child molestation. As a consequence of these o ,' visions in both federal and state law, proper pretrial discovery by in the civil lawsuits against Jeffrey Epstein was not limited to the investigation of the offenses alleged to have been committed by Jeffrey Epstein against the three clients represented by . The law expressly allowed Mr. to conduct discovery of and to fully investigate any other sexual assault or child molestation which may have been committed by Jeffrey Epstein. FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 12/22/2017 11:49:24 AM EFTA02763588