Filing # 66243524 E-Filed 01/08/2018 03:26:41 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXABAG JEFFREY EPSTEIN, A Plaintiff/Counter-Defendant, v. Cos SCOTT ROTHSTEIN individually, and J. individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDAN F tY EPSTEIN'S RESPONSE IN OPPOSITION TO DEFE OUNTER-PLAINTIFF TO MOTION IN LIMINE SECOND SUP SSIBLE EVIDENCE ADDRESSING SCOPE OF Plaintiff/Counter-Defendant Je Plaintiff J. ("Ed Liminc Addressing Scope of ("Epstein"), opposes Defendant/Countermber 11, 2017, Second Supplement to Motion in vidence (D.E. 1113) and states: JNTRODUCTION seeks to prevent Epstein from introducing any testimony and evidence regarding the criminal duct that occurred with the Rothstein, Rosenfeldt & Adler law firm ("RRA") during the the that he was employed there, but that was not known to Epstein until after December , 2009. Epstein agrees that the existence of probable cause for initiating a claim is determined based on information known at the time the original civil proceeding is filed. However, counsel placed the "continuation" of probable cause at issue before this Court at a recent hearing. Additionally, counsel added the "continuation" of the original civil proceeding FILED: PALM BEACH COUNTY. FL. SHARON R BOCK. CLERK, 01/08/2018 03:26:41 PM EFTA02763650